Transcript Sunset Park Health Council, Inc. Board Retreat September

2010 Region II Conference
Corporate Compliance Panel
June 3, 2010
Tamy Skaist, Compliance Officer
Ezra Medical Center, Brooklyn, NY 11218
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My life before I became the Compliance Officer at
Ezra Medical Center
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My life after I became the Compliance Officer at
Ezra Medical Center
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Overview
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Background on Ezra Medical Center
Organization of Compliance Program
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Compliance Officer
Compliance Committee of the Board
Board of Directors
Compliance Policy Overview
Compliance Training
Compliance Reporting System
Compliance Auditing
Other Relevant Policies and Procedures
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Background on Ezra Medical
Center
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Located in Brooklyn, NY
State-of-the-art facility built in 2008
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EZRA MEDICAL CENTER
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Bird’s-Eye View of EMC Facility
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Reception Area
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Dental Exam Room
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Background on Ezra Medical
Center
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Services offered:
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Primary care, adults and pediatrics
Dentistry, adults and pediatrics, Mobile Dental
Van
Optometry and vision therapy
Dermatology
Podiatry
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Background on Ezra Medical
Center
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Ezra Medical Center opened its doors in
2001. With minimal resources, the health
center created a vital community resource of
medical, dental and social service visits for its
target population.
During the past 5 years, we’ve seen a growth
of over 1,000%.
Currently, we see over 3,000 visits per
month.
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Organization of Compliance
Program
Compliance Officer
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Manages Compliance Program
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Tracks new developments
Ensures compliance reviews are performed
Conducts compliance training
Responds to reports, complaints and questions
Makes reports to Compliance Committee of
the Board
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Organization of Compliance
Program
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Compliance Committee of the Board
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Oversees Compliance Program
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Receives reports from Compliance Officer
Reviews compliance activities
Addresses specific compliance-related
concerns
Makes recommendations for changes
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Organization of Compliance
Program
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Employees
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Given periodic compliance training
Front line in detecting potential compliance
issues
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Compliance Program
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Purpose
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To ensure that Ezra Medical Center operates in full
compliance with all relevant laws, regulations, and
guidelines
Particular areas of focus include:
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Accuracy of coding
Claims development and submission
Documentation of services rendered
Services are reasonable and necessary
False Claims Act issues
Fraud and abuse (kickbacks/self-referrals)
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Compliance Policy Overview
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Privacy and security:
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Security Officer with responsibility for privacy and security
issues
Regular HIPAA training for staff
Workstations are physically secure
Workstations in public areas are protected with privacy
filters
Password protected screen savers when workstations
unattended for 5 minutes or more
User accounts disabled immediately upon termination of
user’s employment
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Compliance Training
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Bi-annual compliance training for all staff
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Review compliance program
Review of staff responsibilities
Discussion of reporting mechanisms
Coding and billing training:
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Done upon hire, and two times a year
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Compliance Reporting System
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Staff are required to report any potential
issues to their supervisor, another person in
management, or the Compliance Officer
Compliance hotline has been established
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Toll-free number
Available 24 hours per day, 7 days per week
Reports are anonymous
Reports go to Compliance Officer and/or the
Executive Director
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Compliance Auditing
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Current and prospective employees are screened
against applicable databases, including:
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HHS OIG’s List of Excluded Individuals and Entities
GSA’s List of Parties Debarred from Federal Programs
New York State Medicaid Office of Inspector General List
of Excluded Individuals and Entities
Regular self-audits
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Done on a quarterly basis
Audit of sample charts to ensure that coding and billing
accurate
Review by medical records personnel
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Responding to Violations
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Investigation by Compliance Officer
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Ensure that investigation is initiated as soon as reasonably
possible.
Identify and review relevant documentation
Identify and interview relevant staff members
Suspension of staff member from job function to protect integrity
of investigation, if necessary
Involvement of legal counsel as required
Report to Compliance Committee of the Board
Corrective action
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Up to and including termination of staff member(s) involved
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Other Relevant Policies and
Procedures
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Whistleblower Protection Policy
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Conflict of Interest Policy
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Prohibits retaliation or discrimination against any person for making a
complaint, assisting in an investigation, or reporting an incident of
suspected illegal or unethical conduct
Subjects anyone engaging in retaliation to appropriate disciplinary
action, which may include termination
Establishes policy for handling potential conflicts of interest
Among other things, requires approval of non-conflicted Board members
for any transaction involving a conflicted party
Document Retention Policy
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Implemented by Compliance Officer
Establishes minimum retention periods for records
Developed in consultation with legal counsel
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Questions?
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