Corporate%20Compliance%20Education - PowerPoint PPT Presentation

View by Category
About This Presentation
Title:

Corporate%20Compliance%20Education

Description:

... * Have a Strong Corporate Compliance Program Policies and Procedures Code of conduct Confidential Disclosure Program Training ... Have a Corporate ... – PowerPoint PPT presentation

Number of Views:687
Avg rating:3.0/5.0
Slides: 50
Provided by: suza54
Category:

less

Write a Comment
User Comments (0)
Transcript and Presenter's Notes

Title: Corporate%20Compliance%20Education


1
Corporate Compliance Education
  • Add your presenter name here

2
Sample Overview
  • This is a sample overview presentation for
    Corporate Compliance requiring agency
    individualization.
  • As a home health agency, you may wish to add
    specifics regarding CoPs and clinical
    documentation.
  • Feel free to adjust and modify as needed.
  • Please delete this slide.

3
Introduction.
  • Compliance efforts should support a corporate
    culture that promotes prevention, detection, and
    resolution of instances of conduct not conforming
    with Federal and State Law or ethical and
    business practices.
  • Federal Register 629436
  • March 1997

4
  • This Corporation is committed to promoting strong
    business ethics, monitoring compliance with
    applicable rules, regulations, and law. Having a
    strong compliance program with solid internal
    quality control mechanisms assists this
    Corporation to maintain its commitment as a firm
    of integrity and assists to prevent unethical
    conduct.

5
Expectations for Corporate Compliance
  • Continually improving the quality of services and
    products provided as well as consistent
    environmental structure that encourages employees
    to report potential problems
  • Having procedures in place for prompt
    investigation of areas of concern.

6
Educational Objectives of this presentation
  • Describe the mission of a Corporate Compliance
    Program
  • Identify what is the Office of the Inspector
    General (OIG) and its focus
  • Identify potential areas of vulnerability
  • Identify how this Corporation looks to minimize
    Corporate Compliance risk

7
Educational Objectives of this presentation
  • List some of this Corporations responsibilities
    to its clients
  • Identify what the employee should do if they
    suspect violation of Federal Law or ethical
    business conduct.
  • Identify required elements of a compliance
    program and its input on personnel.

8
The OIG has expectations for home health and
hospice agencies as well as third party billers
  • The OIG has identified the following seven
    critical elements of an effective compliance
    plan
  • 1 Written policies and procedures
  • 2. Designation of a Corporate
    Compliance Officer
  • 3. Ongoing education and training
  • 4. Effective lines of communication

9
Expectations continued
  • 5. Enforcement of Standards
  • 6. Auditing and Monitoring
  • 7. Investigation and corrective action

10
Identify the mission of Corporate Compliance?
11
  • Providing easy to understand explicit guidelines
    for Compliance for all employees to follow
  • Ensure that employees understand what is expected
    of them in the conduct of their job

12
  • Ensure that objective quality standards are
    defined for each department.
  • Ensure that those quality standards are
    measurable and metrics are routinely deployed

13
The mission of the Corporate Compliance
department continued..
  • Ensure employees are using Compliance Standards
    in their daily work activity
  • Enhance corporate performance in basic business
    relationships
  • Ensure the business culture at the Corporation
    supports ethical, quality oriented and honorable
    conduct.
  • Develop and maintain trust in the healthcare
    community of firms using services and products of
    this Corporation.

14
In healthcare, sometimes there are gray areas
that may need to be discussed
  • Provide a process for decision making when the
    business standards DO NOT provide a clear answer
    to an issue or dilemma.

15
How will the Corporate Compliance Mission be
accomplished?
16
  • By providing a written Standard of Conduct for
    distribution to all employees upon hiring
  • By training on Compliance Standards with
    Policies and Procedures to employees of the
    Corporation.

17
  • By providing ease of access to the Corporate
    Compliance Officer
  • By providing a hotline to report areas of
    potential non-compliance

18
  • By monitoring and enforcement through the
    Compliance Officer and Compliance Committee
  • By review and update of the Corporate Compliance
    Program annually and as needed
  • By participation of all levels of management in
    the Compliance program

19
Mission Statement
  • To provide efficient, cost effective systems and
    support services in accordance with the highest
    quality and ethical standards.

20
In the Home Health industry, the Office of the
Inspector General (OIG) heavily monitors
  • Coding
  • Billing
  • Accounting

21
Write a statement about services provided and
adherence to regulation. Below is a sample This
Corporation provides Coding and Billing services
to many Clients nationwide. Compliance
guidelines for Billing companies and Coding
conventions for Coding companies have been
developed by regulatory bodies and are followed
by this firm.
22
Risk areas in ICD-9-CM Coding Documentation
Review SOC/ROC/Recertification
  • Upcoding placing patient in a higher case mix
    category than is warranted.
  • Downcoding coding patients at a lower level
    than is appropriate
  • Sequencing arranging Diagnosis in proper order
    from Primary reason for Home Health to lessor
    conditions that may impact on HH Care and ADLs.

23
Risk areas in ICD-9-CM Coding Documentation
Review SOC/ROC/Recertification
  • Correctly assigning primary and primary secondary
    diagnoses
  • Correctly applying therapy diagnosis
  • Diagnosis with wound, ulcer, or surgical detail
    support
  • Assuring all diagnoses have adequate
    documentation supportive detail

24
Risk areas in Clinical
  • Charting entries consistent with Dx coding
  • Evidence of homebound status in charting
  • Following specific state regulation

25
Risk areas in ICD-9-CM Coding and
SOC/ROC/Recertifications
  • Evidence of genuine medical necessity face to
    face
  • Assessment or reassessment of patients
  • Time points
  • Charting/Documentation consistent with original
    Plan of Treatment or change in condition

26
Risk Areas in Home Care Billing
27
Risk Areas in Home Care Billing
  • Failure to return credit balances made by Federal
    Government
  • Billing for services not Medically Necessary
  • Billing for services for a non-homebound patient
  • Routine waiver of co-payments
  • Billing for services without a Physicians Order

28
Risk Areas in Home Care Billing
  • Billing for services without proper clinical
    documentation
  • Overcharging for services or supplies
  • Billing for services before physician orders are
    signed
  • Duplicate billing
  • Inappropriate Coding
  • Improper application of CBSA codes

29
Question
  • Which of the following is a reason the government
    might investigate a billing company for potential
    fraud and abuse?
  • A. Unfavorable analysis of billing patterns
  • B. Billing two different payors for the full
    invoice
  • C. Patient or client complaint
  • D. All of the above

30
Some of the Corporate Responsibilities its
Clients
  • Provide Management Reports to insure
  • There are physician orders for services rendered
  • There are signed Physician Orders

31
Certain Responsibilities to Clients
  • Adherence to current ICD-9-CM coding convention
    to
  • Prevent upcoding or downcoding
  • Monitor for proper sequencing
  • Monitor accuracy of OASIS integrated assessment
  • Notification of potential non-reimbursable visits
    based on 485 (Medical POC) review

32
Certain Responsibilities to Clients
  • Code to the highest level of specificity with
    documentation to support the coding decisions
  • Provide reliable response to documentation and
    coverage questions
  • Provide a tool that assures validation of visits
    made.
  • Release only clean claims

33
How does the Corporation minimize risk?
34
How does the Corporation Minimize risk?
  • Have a Strong Corporate
  • Compliance Program
  • Policies and Procedures
  • Code of conduct
  • Confidential Disclosure Program
  • Training and Education
  • Screening
  • Internal audits Clinical, Coding, Billing
    Departments for Compliance
  • Seeking Data, Data, Data!
  • Disciplinary guidelines

35
How does the corporation minimize risk?
  • B. Have a Corporate Compliance Officer
  • Upper level position with direct access to the
    CEO
  • CCO experienced and credentialed to execute the
    Corporate Compliance plan
  • Employees know how to contact the Corporate
    Compliance Officer

36
How does the Corporation minimize risk?
  • Legal Review
  • Corporate Counsel review of all Client Contracts
  • Corporate Counsel review of Joint Ventures
  • Corporate Counsel availability to Corporate
    Compliance Officer

37
What should you do if you suspect violations of
Federal law or business conduct policies?
38
  • You have the option to speak with your Supervisor
    or contact the Corporate Compliance Officer
  • If you are uncomfortable with this direct
    approach you may complete a Compliance Concern
    Form (located_________) or call the Compliance
    Help Line at________________.

39
Confidentiality
  • The identity of all callers is treated as
    confidential!
  • The information provided will not be disclosed or
    discussed with anyone other than those who have
    legitimate need to know in order to perform their
    duties.
  • If, because of the nature of the complaint or
    issue, it becomes necessary to provide your name,
    that fact and other options will be discussed
    prior to disclosure.

40
Confidentiality
  • All information is expected to be truthful and
    accurate.
  • This Corporation does not condone the making of
    false or malicious reports.
  • This Corporation will not tolerate any
    retaliatory actions taken against any employee
    for providing truthful and accurate information.

41
One of the essential elements of the companys
Compliance Program is the reporting system.
  • DUTY TO REPORT
  • Employees have the duty to report all suspect or
    questionable conduct.
  • HOW TO REPORT
  • Employees should notify their immediate
    supervisor of any suspected impropriety. Once
    notified, the supervisor must immediately notify
    the compliance officer.
  • Employees may notify the Corporate Compliance
    Officer directly in person or by phone or e-mail

42
When do I NOT utilize the Companys Employee
HOTLINE?
43
When do I NOT utilize the Companys Employee
HOTLINE?
  • Oh my!
  • Bobby doesnt like me.
  • My Supervisor isnt fair.
  • My manager overworks me.
  • Im not happy.
  • Although these are important concerns, the
    company has other problem solving procedures for
    employees with issues of this nature.

44
In Summary
  • The Fundamentals of a Compliance Program may be
    expressed as the four Es
  • - Educate
  • - Encourage
  • - Enable
  • - Enforce

45
Corporate Compliance Benefits
46
Corporate Compliance Benefits
  • Gain competitive advantage through greater
    credibility and assurance to employees and client
    partners. What does this mean?
  • Enhance reimbursement and operating margins by
    focusing on personnel improvement and education
    in documentation, coding, billing and operational
    efficiencies

47
Other Benefits Include
  • Decrease the potential of negative audits through
    documentation of procedures and reviews that
    minimize problems before coding and claims
    submission. What does this mean?

48
Other Benefits Include
  • Improve organizational structure to distribute
    legal and corporate policy changes throughout the
    organization.
  • Reduce liability exposure by demonstrating
    commitment to implementing a comprehensive and
    effective compliance program.

49
Other Benefits Include
  • Knowing you are a part of a team committed to
    quality control and ethical conduct in the
    business world.
  • Your comments?
About PowerShow.com