webinar discusses safeguarding your practice with financial controls

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Medical Practice Financial Controls (or Lack Thereof)

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Financial Controls—consider them a security system for your medical practice. With the correct internal controls in place, your practice can better protect its assets and minimize the risk of loss from errors, lawsuits, and fraud. “Medical Practice Financial Controls…or Lack Thereof” was the topic of a recent National Association of Certified Valuators and Analysts (NACVA) Consultants Training Institute (CTI) webinar presented by PYA Principal Lori Foley and Senior Manager Tynan Olechny.

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Page 1: Webinar Discusses Safeguarding Your Practice with Financial Controls

Medical Practice Financial Controls

(or Lack Thereof)

Page 2: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 2November 12, 2013

DISCLAIMER

All rights reserved. No part of this work covered by the copyrights herein may be reproduced or copied in any form or by any means—graphically, electronically, or mechanically, including photocopying, audio/video recording, or information storage and retrieval of any kind—without the express written permission of the CTI, NACVA ,and the presenter.

The information contained in this presentation is only intended for general purposes.

It is designed to provide authoritative and accurate information about the subject covered. It is sold with the understanding that the copyright holder is not engaged in rendering legal, accounting, or other professional service or advice. If legal or other expert advice is required, the services of an appropriate professional person should be sought. The material may not be applicable or suitable for the reader’s specific needs or circumstances. Readers/viewers may not use this information as a substitute for consultation with qualified professionals in the subject matter presented here. Although information contained in this publication has been carefully compiled from sources believed to be reliable, the accuracy of the information is not guaranteed. It is neither intended nor should it be construed as either legal, accounting, and/or tax advice, nor as an opinion provided by the Consultants’ Training Institute (CTI), National Association of Certified Valuators and Analysts (NACVA), the Institute of Business Appraisers (IBA), the presenter, or the presenter’s firm. The authors specifically disclaim any personal liability, loss, or risk incurred as a consequence of the use, either directly or indirectly, of any information or advice given in these materials. The instructor’s opinion may not reflect those of the CTI, NACVA, its policies, other instructors, or materials. Each occurrence and the facts of each occurrence are different. Changes in facts and/or policy terms may result in conclusions different than those stated herein. It is not intended to reflect the opinions or positions of the authors and instructors in relation to any specific case, but rather to be illustrative for educational purposes. The user is cautioned that this course is not all inclusive.

© 2013—1997 NACVA • 5217 South State Street, Suite 400 • Salt Lake City, UT, 84107—ALL RIGHTS RESERVED.

The Consultants' Training Institute (CTI) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted through its web site: learningmarket.org.

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Page 3: Webinar Discusses Safeguarding Your Practice with Financial Controls

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The Presentation will include periodic online Polling Questions/Codes to assess continuous participation and to determine the program’s effectiveness.

You MUST respond to all polling questions (live) or keep track of all polling codes (recorded) in order to receive CPE credit.

If you view the webinar with a Smartphone or Tablet you will NOT be able to answer polling questions that are required for obtaining CPE credit.

If you are viewing this presentation as a recorded webinar it will not qualify for NASBA QAS CPE credit. You can however, obtain CPE credit per the instructions included with your recorded webinar purchase.

How to obtain CPE credit for this webinar:

© 2013 National Association of Certified Valuators and Analysts

Page 4: Webinar Discusses Safeguarding Your Practice with Financial Controls

Medical Practice Financial Controls

(or Lack Thereof)

Page 5: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 5November 12, 2013

This Practice isProtected

by “Financial Controls”

Page 6: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 6November 12, 2013

What Are Internal Controls?

Methods and procedures used to:

• Prevent, detect errors

• Encourage adherence to policies

• Safeguard against misappropriation

Page 7: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 7November 12, 2013

Internal Controls Protect Practice Assets

Reduce the risk of loss from:

• Errors

• Lawsuits

• Fraud

Page 8: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 8November 12, 2013

Internal Controls Protect From:

Too Busy Risk of Errors

Misfiled

Miscount Forgot

Lost

Mistyped

Page 9: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 9November 12, 2013

Internal Controls Protect From:

Government Risk of Lawsuits

Patients

Partners Employees

Managed Care Companies

Suppliers

Page 10: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 10November 12, 2013

Risk of Fraud

$5.3 trillion annually

Median loss of $140,000

Small companies most vulnerable

Physician practices often targeted

1

2

3

4

Source: Association of Certified Fraud Examiners.

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• Desperate people do desperate things

• Regulatory requirements

• Competition

• Rapid changes

• Need for capital

• Complex transactions or structure

• Absentee owners

Fraud Risks

Page 12: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 12November 12, 2013

The Practice is Often at Fault…• No (weak) internal control policies, procedures

• Trust

• Conflict avoidance

• No time, energy, resources

• Complex business environment

• Failure to prosecute

Page 13: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 13November 12, 2013

Who Commits Fraud?

42%

38%

18%

3%

EmployeeManagerOwnerOther

Source: Association of Certified Fraud Examiners.

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Page 14November 12, 2013

How Fraud Occurs

• Poor internal controls

• Management override

• 3rd party collusion

• Other – 2%

Page 15: Webinar Discusses Safeguarding Your Practice with Financial Controls

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Fraud Techniques

Theft of cash or inventory‒ Taking co-pays or petty cash‒ Taking equipment or supplies

­ Using company checks or credit cards for personal items

Theft of blank checks or credit

False employee or vendor­ Creation of a false

employee or vendor for monthly payment

Page 16: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 16November 12, 2013

How Frauds Are Discovered

• Internal controls work• Falling out among thieves• Disgruntled associate• Observant patient,

supplier• Accident

Page 17: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 17November 12, 2013

Red Flags

• Personal financial pressure• Vices• Extravagant lifestyle• Real or imagined grievances against

the company or management• Increased personal stress

Page 18: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 18November 12, 2013

More Red Flags

• Management pressure• Short vacations, unexplained hours• Overly neat, territorial• General lack of ethics• Unusually close vendor relationships

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Page 19November 12, 2013

The Triangle of Fraud

“I was just trying to save the company.”“If I only could have gotten the bank loan, everything would have been fine.”

Need

Opportunity Rationalization

Source: Sage Investigations, LLC.

Page 20: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 20November 12, 2013

Situational Fraud

Always: 5% to 10%

Never: 5% to 10%

Situation Arises: 80% to 90%

Situational Fraud

Page 21: Webinar Discusses Safeguarding Your Practice with Financial Controls

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Myths Surrounding FraudFraud is most often committed by people who have done it before.

Long-term employees will not commit fraud.

Employers (physicians) are good judges of character and understand their employees.

Myths

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More Myths CPAs can be relied upon to discover fraud.

Checks made out to banks or companies cannot be converted to personal use by third parties.

Losses due to fraud are covered by insurance.

Myths

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Factors of Effective Compliance• Internal control policies, procedures

• High-level person responsible for monitoring

• Do not give authority to persons you know or should have known had propensity

• Communicate the policies and procedures

• Reasonable steps to achieve compliance

• Respond appropriately

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Internal Control Procedures

Involvement

Checks and balances

Segregation of duties

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Internal Control System Should Be...

Organized Documented

Communicated

Cost effective

Page 26: Webinar Discusses Safeguarding Your Practice with Financial Controls

10 Key Questions

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Page 27November 12, 2013

Question 11. Does the practice know

the typical daily, weekly, and monthly volume of the practice, and do they promptly investigate any material deviations?

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Page 28November 12, 2013

Question 22. Are charge slips, cash receipt slips,

and checks pre-numbered, controlled, and accounted for, including voids? Are blank documents stored safely and is access limited?

Sally “loses” her friend’s charge ticket.No charge = No write off = No money

Page 29: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 29November 12, 2013

Question 33. Are cash-related duties

appropriately segregatedamong staff members?

Recordkeeping vs. custody vs. approval

• Who opens the mail?• Who posts payments?• Who does the bank reconciliation?• Who reviews the payroll journal?

Page 30: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 30November 12, 2013

Question 44. Are accounting records, including

charge posting, payroll reports, and bank reconciliations, kept up-to-date and balanced daily and monthly?

• Monthly day sheet reconciliation

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Question 55. Does the practice restrict check

signature authority to physician owners only, insist on personal signature instead of a signature stamp, and inspect back-up invoices before signing checks?

• All parts of the check are complete; original invoice approved and canceled; packing slip attached; expenditure is reasonable.

Page 32: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 32November 12, 2013

Question 66. Are all checks stamped with

the practice’s “For Deposit Only” endorsement stamp immediately upon receipt? Are un-deposited checks stored in a safe place pending deposit?

Page 33: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 33November 12, 2013

Question 77. Are all employees required

to take annual vacations? Is there a back-up person for all positions?

• Big bus theory

Page 34: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 34November 12, 2013

Question 88. Are all contractual adjustments,

patient refunds, and non-contractual write-offs approved or monitored by an authorized supervisor?

• Ignorance? Innocent mistake? Deliberate?

Sally’s friend incurs $3,500 in patient responsible services. Sally’s choices:

Put friend through normal collection procedures.Write friend’s balance down to zero.

Page 35: Webinar Discusses Safeguarding Your Practice with Financial Controls

Page 35November 12, 2013

Question 99. Does the practice check the

references of new hires carefully and screen candidates and current employees regularly for exclusion from or sanctions by Medicare and other federal programs? Does the practice obtain a background check/credit report?

• www.exclusions.oig.hhs.gov• www.sam.gov

Page 36: Webinar Discusses Safeguarding Your Practice with Financial Controls

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Question 1010. Does the practice use the “sentinel”

effect? Occasionally sample postings, review the general ledger, inspect reconciliations, check the cash drawer, and ask questions?

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Page 37November 12, 2013

Conclusion

Embezzlement opportunities are plentiful and practices ripe for the picking!

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Page 38November 12, 2013

Thank You!Lori A. Foley, CMA, PHR, CMM

[email protected]

Tynan P. Olechny, MBA/MPH, [email protected]

PYA GatesMoore3424 Peachtree Rd N.E., Suite 700

Atlanta, GA 30326(404) 266-9876

www.pyagatesmoore.com