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Depend On Count On Our People Our Advice Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018

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Page 1: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

Depend On Count On

Our People

Our

Advice

Fraud in the Revenue Cycle

2018 MMGMA Winter Conference

March 7, 2018

Page 2: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers
Page 3: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

Why are we here? • Consumer Payments to Providers have

increased: • 2011 to 2014 - 193%

• 2013 to 2016 - 58%

• Consumers moving to high-deductible health plans (HDHP). • 10M plans in 2010 to 75M in 2016

Source: https://www.beckershospitalreview.com/finance/10-things-to-know-about-2016-healthcare-consumer-payment-trends.html Source: https://www.instamed.com/blog/trends-in-consumer-healthcare-payments/

Page 4: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

What will we learn today?

Identify the revenue fraud schemes

Risk areas in medical practices

Internal controls to mitigate those risks.

Page 5: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

Fraud 101 – Revenue Fraud Schemes

Page 6: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

What is Fraud?

From the Association of Certified Fraud Examiners (www.acfe.com)

• In the broadest sense, fraud can encompass any crime for gain that uses deception as its principal modus operandus. More specifically, fraud is defined by Black’s Law Dictionary as: • A knowing misrepresentation of the truth or concealment of a material fact to induce

another to act to his or her detriment.

• Consequently, fraud includes any intentional or deliberate act to deprive another of property or money by guile, deception, or other unfair means.

Page 7: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

Is this Fraud?

• An employee needs cash and writes a personal check to cover for cash taken from patient co-pays.

• An employee writes off a patient balance based on sympathy for patient.

• Management approves a write off of a patient account due to facts and circumstances of that patient.

Page 8: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

“2016 Report to the Nations on Occupational Fraud and Abuse. Copyright 2016 by the Association of Certified Fraud Examiners, Inc.”

Page 9: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

Example

“A check for $8,000 had arrived in the mail from an insurance provider – a settlement from an old claim that had already been written off and was never entered into their new practice management system”

Could this be diverted for personal gain?

Source: http://medicaleconomics.modernmedicine.com/node/441015

Page 10: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

“2016 Report to the Nations on Occupational Fraud and Abuse. Copyright 2016 by the Association of Certified Fraud Examiners, Inc.”

Page 11: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

“2016 Report to the Nations on Occupational Fraud and Abuse. Copyright 2016 by the Association of Certified Fraud Examiners, Inc.”

Theft of Cash Schemes

High risk for Medical Practices:

• Write off Schemes

• Lapping Schemes

• Understated Sales

Page 12: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

“2016 Report to the Nations on Occupational Fraud and Abuse. Copyright 2016 by the Association of Certified Fraud Examiners, Inc.”

High risk for Medical Practices:

• Timing Differences

• Understated Revenues

Page 13: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

“2016 Report to the Nations on Occupational Fraud and Abuse. Copyright 2016 by the Association of Certified Fraud Examiners, Inc.”

High risk for Medical Practices:

• Conflicts of Interest

Page 14: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

Example

“This money is not going to be missed by anyone”

Source: http://medicaleconomics.modernmedicine.com/node/441015

Page 15: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

The Fraud Triangle

Page 16: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

Risk Areas in Medical Practices

Page 17: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

What puts medical practices at risk?

• Skimming: • High volume of adjustments and allowances expected

• Multiple payors

• Small practices that lack segregation of duties

• Significant trust placed in one person

• Financial Statement Fraud: • Compensation Structures / Bonuses

• Budget vs Actual

Page 18: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

Back to Example – What Risk Factors Existed?

Page 19: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

Internal Controls

Page 20: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

Internal Controls – Organizational Level

• Tone at the Top – Integrity and Ethical Values

• Clear organizational structure, roles, responsibilities and authority

• Commitment to competence

• Accountability

• Risk Assessment

• Communication

• Monitoring

Page 21: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

Internal Controls – Functional Level

• Segregation of Duties

• Approval of allowances, adjustments

• Review of aging reports and subsidiary ledgers

• Physical safeguards on cash

• Activity is posted in proper period to proper accounts

Page 22: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

Internal Controls – IT

• Access is limited to a those who need access for their job responsibilities.

Page 23: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

Internal Controls

• Identify and Address Weaknesses

• Ongoing Monitoring

Page 24: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

Back to Example – What Internal Controls were Missing?

Page 25: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

Key Take-Away’s

• Perform regular risk assessments

• Clearly communicate roles, responsibilities

• Clearly communicate levels of authorization

• Segregate duties to extent possible and add other mitigating reviews or processes if unable to segregate duties appropriately.

• Trust but verify!

Page 26: Depend On Our People Fraud in the Revenue Cycle Count On ... · Fraud in the Revenue Cycle 2018 MMGMA Winter Conference March 7, 2018 . Why are we here? •Consumer Payments to Providers

Questions?

Andrea Addo, MBA, CPA, CFE, CITP

Email: [email protected]

Phone: 952-829-3425

Kelly Salwei, CPA, CMA

Email: [email protected]

Phone: 952-829-3400