Corporate ComplianceAnnual Update

2014

Corporate Compliance

• The federal Deficit Reduction Act (DRA) and subsequent Medicaid Integrity Program requires that all health care entities that annually bill or pay out $5 million or more in Medicaid establish a Corporate Compliance Program.

• A program is recommended for all health care entities.

Purpose of P&S Corporate Compliance

To have an effective compliance and ethics program:

– To exercise due diligence to prevent and detect wrong-doing

– To promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.

– To raise awareness

– To positively impact corporate reputation/culture

– To provide a “safe” mechanism(s) for reporting and seeking help

Objectives of P&S Corporate Compliance

To meet the objectives of the 7 elements of a corporate compliance program as

outlined by the (FSG) Federal Sentencing Guidelines:

1. Review Written Policies & Procedures

2. Select Compliance Officer & Committee

3. Training & Education

4. Effective Lines of Communication

5. Discipline & Background Checks

6. Auditing and Monitoring

7. Responding & Corrective Action

Written Policies & Procedures

• The focus of our program is on ethics and integrity in the workplace and

compliance with federal and state laws related to:

– Fraud

– False claims

– Theft or embezzlement

– Kickbacks

– Other violations

• The Compliance Program develop and implement policies, procedures, and best-

practices designed to ensure compliance with state & federal regulations and

programs.

– Accreditation Agency (DNV)

– Medicare/Medicaid requirements (CMS)

– HIPAA/HITECH requirements (OIG/OCR)

A working environment that encourages:

• Ethical and proper ways to do business

• Commitment

• Encourages problems to be reported

• Provides a process with constant monitoring

process which

– Deter

– Detect

– Correct

– Prevent Non-Compliant Behavior

P&S Code of Conduct

• P&S Surgical Hospital strives to provide the highest quality procedural care in a patient-focused environment. P&S Surgical Hospital is committed to our core values of:– Service– Respect– Compassionate Care– Friendliness– Stewardship

• The Code of Conduct provides standards by which all members of the organization will conduct themselves.

• Individual’s conduct must be in a manner that protects and promotes organizational-wide integrity and enhances P&S Surgical Hospital’s ability to achieve its objectives and mission.

• This applies to all employees, officers, administrators, board members, medical staff, vendors, contracted employees, consultants, students, and volunteers.

P&S’s Corporate Compliance Program Includes:

• Corporate Compliance Officer

– Report on a regular basis to the CEO, compliance committee, and when necessary to the governing body.

– Continue to design, implement, oversee, and monitor the compliance program.

• Corporate Compliance Committee

• Policy and procedures

• Corporate Compliance Plan

• Develop, coordinate, and participate in a multifaceted educational & training.

• Ensure that independent contractors and agents are aware of the organization’s compliance program

requirements.

• Assist with internal compliance review and monitoring activities.

• Anonymous hotline

Training & Education

• Communication process to report any compliance issues or concerns

• New Hire Orientation

• Code of Conduct Training – Annually

• 7 Elements of an Effective Compliance Program – Annually

• Conflict of Interest Statements – Annually

• Safe guarding PHI/ePHI

It is every employee’s responsibility to report suspected violations of the laws, regulations and policies, or other questionable conduct.

Effective Lines of Communication

Reporting Compliance Issues or Concerns:

1. Your manager

2. Executive Team Member

3. Director of Human ResourcesI. Chenire Craig- 998-7307

4. Compliance OfficerI. Dirk Rhodes – 998-6135

5. Compliance “Anonymous” Hotline - 1-866-570-2523

Effective Lines of Communication

• Dirk Rhodes, Corporate Compliance Officer – Phone: (318) - 998-6135– Contact via E-mail: DirkRhodes@pssurgery.com

• P&S Corporate “Hotline” ComplianceLine:

1-866-570-2523– 100% anonymous; Available 24 hours a day/ 7 days a

week– There will be no retaliation for reporting concerns in

good faith, but appropriate disciplinary action will be taken against those who commit misconduct.

• All reported allegations will have to be verified before any actions are taken.

Discipline / Background Checks

• Upon hire all employees undergo a background check/ drug screening.

• Monthly SanctionCheck is performed on all employees, medical staff, vendors, & contracts/business associates to show that P&S is compliant with CMS, federal & state regulations and various programs that we participate in.

• Annually employee(s) should receive a copy of the Sanction Policy that supports the Code of Conduct and outlines the disciplinary actions taken in the event of misconduct.

Auditing & Monitoring

• Unethical or inappropriate care of patients

• Lack of correct and sufficient documentation in admitting / discharging patients

• Medical Necessity • Billing for services or

supplies that were not provided

• Altering claims for higher payment

• 2 Annual (External) Billing/Coding Audits

• MCR inpatient one day stays

• Conflict of Interest /Inappropriate vendor relationships

• Inappropriate access and/or release of (PHI)

• Bribes or kickbacks• Business Associate

Agreements (BAA) • Physician Ownership

Disclosure

Responding & Corrective Action

• The Compliance Department reviews all allegations in a serious manner and takes the necessary steps to deter, detect, correct, & prevent any wrong-doing or misconduct.– All reported allegations will have to be verified before any actions are taken.

• All allegations, audits (internal & external), and monitoring is reported directly to the CEO/ Compliance Committee/Board as necessary.

• All allegations, audits (internal & external), and monitoring tools are responded back to in the allotted time frame per the institution guidelines.

• In regards to the P&S “Hotline” ComplianceLine– ≤ 72 hours to respond to any issue or concern (Severity I to III)

– May take longer considering certain factors and seeking P&S Legal Counsel for review

We want to provide a safe patient centered environment for Patients & Employees!!

Quick Facts

• All employees are held responsible and accountable for compliance and can be charged with fraud

• The corporate compliance committee investigates every complaint of noncompliance

• There will be no retaliation for reporting concerns in good faith, but appropriate disciplinary action will be taken against those who commit misconduct

• Law prohibits asking for or receiving anything of value to induce or reward referrals of Federal health care program business

Examples of Compliance Issues

• Never read another employee’s confidential records without permission

• Never use another person’s password to access confidential information

• Only discuss a patient’s condition with those involved in the patient’s care

• Never treat or act differently to someone because they identified a compliance or ethical issue

• Accepting gifts from vendors, providers, or third parties are prohibited as outlined in the conflict of interest policy at P&S. All gifts (>$25.00 per person per transaction) need prior administration approval before accepting.

• Only bill for visits, procedures and/or tests performed

• Always provide complete documentation for ALL services performed

Remember!

DO THE RIGHT THING:

• When you become aware of or observe something you believe to be improper, report it.

• Keep yourself trained and informed.

• No retaliation for reporting in good faith!

No Pointing Fingers!!

• End of Presentation