welcome….!!! corporate compliance program presented by the office of corporate integrity 1
TRANSCRIPT
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Welcome….!!!
CORPORATE COMPLIANCE PROGRAM
Presented by
The 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
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Corporate Compliance Program Structure
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Corporate Compliance is Everyone’s Responsibility
• Board : Duty of Care / Duty of Loyalty
• Executive Staff: Highest Moral Character and Integrity
• Leadership: Exhibit Professionalism and Right Relationships
• All Employees:– Perform duties in a professional and responsible manner– Adhere to all GHS policies– Report any violation of policies or suspected unethical behavior– Read, understand and follow the Code of Excellence
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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 Policies
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GHS Policies and Initiatives
• Harassment• Gifts and Gratuities• Social Media• Photography • 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 Conduct• Patient Safety and Quality • University Medical Group
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Compliance Reviews
• Documentation of tests/procedures/charges/coding• Charge capture reconciliations• Medical necessity verification• Investigation of employee/patient complaints• Actions of independent contractors (agents)• Privacy/Confidentiality• Auditing 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 Supervisor• Department Director • Department Compliance Manager / Liaisons• Human 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 Integrity797-7720 [email protected]
J. Scott Pietras - Corporate Compliance Officer797-7712 [email protected]
Tracy Morris – Privacy Officer 797-7724 [email protected]
Jan Latham, Compliance Analyst / UMG Compliance Liaison797-7725 [email protected]
Linda Robinson, Compliance Administrative Assistant 797-7726 [email protected]
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Code of Excellence
• The Hotline Reporting Options:
– You may call anonymously– You 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 Numbers–1-888-243-3611 –1-800-297-8592 (en español)–Go to GHSNet main page under Employee
Reference, Employee Hotline & HIPAA Privacy Line
http://www.ComplianceResource.com/Hotline. 14
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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 = treatment, payment or operations
• PHI includes (but is not limited to):– Patient demographics– Clinical or health information– Images or photographs– Financial information
If it identifies a patient, it is likely considered to be PHI!16
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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:• Encryption• Protection of electronic devices• Access rules
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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 records• New fines for violations• Breach reporting• Business Associate requirements
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HITECH
Health Information Technology for Economic and Clinical Health Act
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Applying the Rules
• Reasonableness- Don’t Delay Treatment• Minimum Necessary & Need-to-Know
– Audits • Duty to Protect & Report
– Maintain Reasonable Safeguards– Protect Your User ID & Password – No Sharing!
• Attention to Detail– Social Media
• Privacy Violations = Civil Rights or Criminal Violations• Accessing Your Own Medical Records
When in doubt, don’t give out contact the Compliance Office.
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Remember……
Corporate Compliance
is
Everyone’s
Responsibility
Thank you!