Corporate Compliance Panel
Download
Report
Transcript Corporate Compliance Panel
CAMcare Health Corporation
Corporate Compliance
Program
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
High Risk Areas for Health
Centers
Billing and Coding
Grants Management
Internal Controls
Information Management
Tax Issues
Cost Reporting and Regulatory Filings
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
Corporate Compliance Committee
Corporate Compliance Officer
Medical Director
Nursing Director
Billing Director
Finance Director
MIS Director
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 center’s BOT and all regulatory and
accrediting organizations
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
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)
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
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
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
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