Transcript HEALTHCARE TRUSTEES OF NEW YORK STATE

HEALTHCARE
TRUSTEES OF NEW
YORK STATE
Compliance and Governance
Update
August 8, 2012
Realities
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Renewed Federal Interest in Governance
Health Reform Brings Governance
Challenges
State Government’s Reach May Exceed Its
Grasp
Board Oversight of Issues is Expanding
A Few of the Issues
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Executive Compensation
OMIG Compliance Guidance
Recovery Audit Contractor (RAC) and
Other Audits
Expanded Surveillance Focus – Quality
Conflicts of Interest
Increased IRS Scrutiny
Executive Compensation
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Executive Branch Process
Limits on Reimbursement, Compensation
and Use of State Revenue
Very Expansive Reach
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“Covered Executive” Definition
“Related Entity” Definition
Hospitals are Not Focus But are Covered
Aggressive Government Audits
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Carried Out by Contractors
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Often Paid on Contingency Basis
RACs, MACs, ZPICs, CERTs,
Comprehensive Medicare Compliance – To
Name a Few
Very Burdensome Document Demands
Clinical Judgment Calls
Government Audits (cont)
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All-or-Nothing Recoveries
Hundreds of Millions of $$ At Issue
Post-Payment Reviews
Pre-Payment Reviews
Lengthy Appeals Process
Comprehensive Medicare Audits – OIG
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Internal Controls
Process from Patient to Claim Submission
Office of Medicaid Inspector General
(OMIG) Compliance
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OMIG Now Organized by Teams
Hospital Compliance Guidance - May ’12
Compliance Audits Will Increase as
“Gotcha” Decreases
Document Request Includes Board Minutes
Expectation of Broad Board Oversight
Directors Interviewed During Audit
Governance and Quality
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Increased Regulatory Focus on Quality
Oversight
Prompted by Feds; Implemented by State
Focus on Full Board Awareness
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Reports to Board Committee May Be Inadequate
Dovetails with OMIG Compliance Program
Expectations
Conflicts of Interest
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Doing Business with Hospital
Trustee Joint Venturing
State – Attorney General, Governor
Federal – IRS, Fraud Agencies
Board Minutes Should Reflect
Transparency
Internal Revenue Service
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Proposed Rules – Community Benefit
Reports
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Providing Charity Care Not Enough
Mandatory Reporting of Financial
Arrangements – Directors
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With Each Other & With the Facility