Welcome….!!! CORPORATE COMPLIANCE PROGRAM - PowerPoint Presentation

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Welcome….!!!

CORPORATE COMPLIANCE PROGRAMPresented byThe Office of Corporate Integrity

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Purpose of a Compliance Program

As defined in the Office of Inspector General (OIG) Compliance Guidance for Hospitals “Fundamentally, compliance efforts are designed to establish a culture within a hospital that promotes prevention, detection and resolution

of instances of conduct that do not conform to Federal and State law, and Federal and State and private payer health care programs, as well as the hospital’s ethical and business policies.”

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Components of GHS Compliance Program

Structural Elements Open Communication – Hotline Compliance Officer Compliance and Practice Standards

Education and Training

Internal Monitoring and Auditing

Enforcement of Rules and Standards of Conduct

Response, Remedies and Resource Planning

Risk Assessment

Substantive Elements Laws and Regulations pertaining to Health Care operations Fraud & Abuse Laws: STARK, Anti-Kickback, CMP (Inducements) False Claims: Qui – Tam / Whistle-blower Exclusionary list, HIPAA, Medical Identity Theft, OIG Guidance, COI

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Corporate Integrity Office Structure Slide5

Corporate Compliance Program Structure

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Corporate Compliance is

Everyone’s ResponsibilityBoard : Duty of Care / Duty of LoyaltyExecutive Staff: Highest Moral Character and Integrity

Leadership:

Exhibit Professionalism and Right Relationships

All Employees:

Perform

duties

in a professional and responsible mannerAdhere to all GHS policiesReport any violation of policies or suspected unethical behaviorRead, understand and follow the Code of Excellence6Slide7

What is a “Compliance Issue

”?A compliance issue is a concern that there is a violation of a law, rule, regulation or policy that governs our industry. ►Fraud and Abuse Issue

False Claims:

Medical Necessity Reasonableness, Quality Coding

Improper Inducements

►HIPAA Violation

Privacy Breach

Security Lapse►Violation of our Code of Excellence and/or related GHS Policies7Slide8

GHS Policies and Initiatives

HarassmentGifts and GratuitiesSocial MediaPhotography Proper Use of Property (Information Systems)

Equal Opportunity

Drug-Free Workplace

Conflicts of Interest

Finance and Billing (Coding and Documentation)

Reporting Concerns and Non-Retaliation

Business Ethics and ConductPatient Safety and Quality University Medical Group8Slide9

Compliance Reviews

Documentation of tests/procedures/charges/codingCharge capture reconciliationsMedical necessity verificationInvestigation of employee/patient complaintsActions of independent contractors (agents)Privacy/ConfidentialityAuditing and Monitoring (IT, Policies, Payments, Risk Areas)

Conflict of Interest

University Medical Group

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Reporting Mechanisms

Your Concerns are Important! Contact your:Immediate SupervisorDepartment Director Department Compliance Manager / LiaisonsHuman Resources

Other Management

Compliance Office or

Hotline (you can report anonymously)

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Office of Corporate Integrity Compliance Office

Skip Morris - Executive Director of Corporate Integrity 797-7720 smorris@ghs.org

J. Scott Pietras -

Corporate

Compliance

Officer

797-7712

spietras@ghs.org Tracy Morris – Privacy Officer 797-7724 tmorris5@ghs.orgJan Latham,

Compliance

Analyst / UMG Compliance Liaison

797-7725

jlatham@ghs.org

Linda

Robinson,

Compliance Administrative Assistant

797-7726

lrobinson@ghs.org

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Code of Excellence

Are new employees and existing employees (including physicians and contracted employees) required to read and acknowledge the Code of Excellence? A few examples of a violation to the Code of Excellence include, however not limited to: Fraud & Abuse

,

Misconduct-harassmen

t and

disruptive behavior

,

asking for and accepting gifts, cash/checks or gift certificates from patients or their family members, business vendors, device manufacturers and pharmacy industry.12Slide13

Code of Excellence

The Hotline Reporting Options:You may call anonymouslyYou are protected from retaliation or retribution

All Hotline reports come to the GHS Corporate Integrity Office for

investigation and resolution of reported concerns

The GHS Corporate Integrity Office may forward the concern to the appropriate department manager, depending on the issue (e.g., Human Resources Department)

OR

depending on the severity of the reported issue, it may require further reporting to authorities for investigation and lawful purposes-

(Examples: Fraud and Abuse, Identify Theft) GHS does not tolerate employees, contractors or other persons who retaliate against a person who makes a good faith report under this policy. We make every effort to handle reports confidentially

.

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Code of Excellence

Hotline Numbers1-888-243-3611 1-800-297-8592 (en español)

Go to GHSNet main page under

Employee

Reference

,

Employee Hotline & HIPAA Privacy Linehttp://www.ComplianceResource.com/Hotline. 14Slide15

HIPAA

Health Insurance Portability and Accountability Act of 1996 Department of Health and Human Services (HHS) established national standards for electronic health care transactions. HIPAA also established the rules for the security and

privacy

of health data.

The Office of Civil Rights is the enforcement agency for HIPAA.

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HIPAA Privacy Rule

Protected health care information (PHI) may not be disclosed without the authorization of the patient unless permitted by one the several exceptions. Major exception is for “TPO”TPO =

t

reatment,

p

ayment or

o

perationsPHI includes (but is not limited to):Patient demographicsClinical or health informationImages or photographsFinancial informationIf it identifies a patient, it is likely considered to be PHI!16Slide17

HIPAA Security Rule

Covered Entities must use specific administrative, technical, and physical security procedures to assure the confidentiality of electronic protected health information. Important components include:EncryptionProtection of electronic devicesAccess rules17Slide18

The American Recovery and Reinvestment Act of 2009 (Recovery Act), among other things, expanded HIPAA Privacy and Security protections.

Important components include:Electronic access to recordsNew fines for violationsBreach reportingBusiness Associate requirements

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HITECH

Health Information Technology for Economic and Clinical Health ActSlide19

Applying the Rules

Reasonableness- Don’t Delay TreatmentMinimum Necessary & Need-to-KnowAudits Duty to Protect & ReportMaintain Reasonable SafeguardsProtect Your User ID & Password – No Sharing!

Attention

to

Detail

Social Media

Privacy Violations = Civil Rights or Criminal Violations

Accessing Your Own Medical RecordsWhen in doubt, don’t give out contact the Compliance Office.19Slide20

Remember……

Corporate Compliance isEveryone’sResponsibility

Thank you!

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