CAMcare Health Corporation Corporate Compliance Program

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CAMcare Health Corporation Corporate Compliance
Program
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Corporate Compliance

• Purpose
• To establish a system of internal controls
  designed to ensure that we regularly evaluate and
  monitor our own adherence to applicable statues,
  regulations and program requirements

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High Risk Areas for Health Centers

• Billing and Coding
• Grants Management
• Internal Controls
• Information Management
• Tax Issues
• Cost Reporting and Regulatory Filings

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Elements of Effective CCP

• Designate Corporate Compliance Officer and
  Committee
• Develop and Implementation of Compliance
  Practice Standards
• Conduct Training Education
• Establish open lines of communication
• Conduct Internal Monitoring and Auditing
• Establish Process for Responding to Potential
  Offenses
• Establish Disciplinary Standards

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Corporate Compliance Committee

• Corporate Compliance Officer
• Medical Director
• Nursing Director
• Billing Director
• Finance Director
• MIS Director

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Implementation of Compliance Practice Standards

• Establishment of policy to promote compliance
• Develop written policies and procedures that
  establish guiding principles or courses of action
  for staff
• Policies and procedures must be consistent with
  the requirements and standards established by
  health centers BOT and all regulatory and
  accrediting organizations

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Training and Education

• Develop and provide ongoing education and
  training for BOT and Staff regarding the
  Compliance Program
• All BOT and Staff will receive a General
  Compliance training
• Specialized training for staff (ie. Staff with
  direct responsibility for coding and billing)
• Focused training for areas identified in an audit
  to be potentially problematic

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Open Lines of Communication

• Establish a toll free hotline for reporting
  issues and concerns relating to compliance
• Ensure that the telephone number is publicized in
  a common staff work area (ie. Break room,
  lunchroom)

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Internal Auditing and Monitoring

• Conduct periodic self audits to assure
• Written standards and policies are in compliance
  with the law
• Operating in compliance with written policies and
  procedures
• Coding and billing are accurate with services
  provided
• Documentation is accurate and complete
• Furnished services are reasonable and necessary

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Response to Detected Offenses

• Upon receiving a report of suspected
  non-compliance, the Compliance Officer will
  initiate steps to investigate the conduct in
  question
• Interviews of persons with knowledge of the
  matter
• Review of relevant documents and applicable laws
• Engage legal counsel, external auditors, or
  health care experts to assist in the
  investigation if necessary

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Establish Disciplinary Standards

• Establish and publish procedures for enforcing
  and disciplining individuals who violate the law
• Disciplinary guidelines should be well publicized
  
• Trainings
• Policy and Procedure
• Employee job descriptions
• Employee handbook
• Standards of Conduct

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Why Corporate Compliance?

• Mandatory
• Establishes a program to identify and respond to
  organizational risks
• Identifies and addresses gaps in existing
  practices,policies and procedures
• Program will deter potential fraudulent activity