Compliance. TODAY January Meet Art Weiss, JD, CCEP, CCEP-I. Chief Compliance and Ethics Officer TAMKO Building Products Joplin, Missouri

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1 Compliance TODAY January 2013 a publication of the health care compliance association Meet Art Weiss, JD, CCEP, CCEP-I Chief Compliance and Ethics Officer TAMKO Building Products Joplin, Missouri See page OIG 2013 Work Plan sheds light on new compliance projects: Part 1 39 Structuring the Chief Ethics and Compliance Officer position: Frequently asked questions 45 Avoiding liability: Consistent screening of both permanent and temporary staff 51 Best practices: Training programs to combat fraud, waste, and abuse Nathaniel Lacktman Donna Boehme Vu T. Do Ellen Leinfuss

2 Network and stay up-to-date on managed care hot topics Managed Care Compliance Conference February 24 26, 2013 Hyatt Regency Phoenix Phoenix, AZ Join us in Phoenix, Arizona, for the primary networking and educational event for those involved with the management of compliance at health plans. Plan to attend if you are a compliance professional from a health plan (all levels from officers to consultants), in-house and external counsel for a health plan, internal auditor from a health plan, regulatory compliance personnel, or managed care lawyer. Join us in February to hear the following hot topics! Conducting Internal Investigations and Preparing for Government Investigations Overseeing Your Delegated Entities & FDRs The Final CMS Compliance Program Guidelines Health Plan Compliance with the Final HIPAA Rule Fraud, Waste & Abuse And much more! Learn more at

3 Letter from the President by Shawn DeGroot, CHC-F, CCEP, CHRC Year in review Shawn DeGroot is an Associate Director at Navigant Consulting in Denver. Shawn also serves as President of the HCCA Board of Directors. DeGroot The Health Care Compliance Association has had a great year! We now have more than 8,000 members. Together with our sister organization, the Society of Corporate Compliance & Ethics, we have more than 11,200 members of our 501 c(6) nonprofit professional membership organization. Our annual meeting had over 2,400 attendees and vendors! We have over 3,800 certified compliance professionals: CHC-F = 7 CHC = 3,235 CHRC = 286 CHPC = 350 Membership has grown at more than 9% a year for the last few years. The annual meeting has had comparable growth. Certification grew 20% this year. The numbers are great, but what is most important to the board is the improvements we have made to the services we provide to the compliance profession. Our goal is to constantly improve our educational programs, certification, and networking. Together our two organizations will have more than 60 educational conferences in Because the attendance at the annual meeting has grown, we can add more sessions, speakers, and content. We have added a very high-quality conference attendee app to allow you to manage your time at the annual meeting; speed networking and speed mentoring to help connect compliance professionals; and a head shot for an individual professional photo. Finally, the board recognized the level of stress in the industry and responded by adding a complete track at the Compliance Institute on how to succeed as a compliance professional. From an operational standpoint, HCCA has made the following improvements: The social media and website were integrated. The improved service gave our members better functionality to manage their certification and CEUs, and other new features. The IT system was significantly enhanced. The Compliance Today magazine was redesigned. We now have an app for the magazine so you can get your membership magazine on your phone and tablet. The Financial department was revamped. All of this was accomplished while continuing to build a strong financial reserve that will assure that spikes in the economy, travel, weather, or other variables will not significantly impact the services we provide our members. The HCCA staff has grown in size, yet we have retained many wonderful people who help us provide our members continuity of service. Our biggest accomplishment of the year is that we continued to focus our attention on the compliance professionals in the trenches. We do not focus on having nine course dinners with important people that result in little benefit to our members. We give the microphone to practical, experienced, and knowledgeable compliance and ethics professionals who eat and breathe compliance and ethics. As a result, HCCA fulfills the mission of helping compliance professionals become more effective in their job and implement effective compliance programs. Despite all the other successes, helping our members this past year was our greatest accomplishment!

4 Improving Governance Practices Audit & BUY ONE registration for $695 and GET ONE for $395 Compliance COMMITTEE CONFERENCE February 25 26, 2013 Scottsdale, AZ MONDAY, FEBRUARY 25 8:00 AM 5:15 PM Registration 8:00 8:45 AM Continental Breakfast 8:45 9:00 AM Opening Remarks 9:00 11:15 AM Introduction to Healthcare Risk Areas & Compliance DAN ROACH Vice President Compliance and Audit Dignity Health San Francisco, CA 11:30 AM 12:30 PM Introduction to Health Care Accounting GRETCHIN S. HECKENLIVELY Health Care Consulting Senior Manager Seim Johnson, LLP Omaha, NE 12:30 2:00 PM Luncheon Presentation: Enforcement Actions GABRIEL IMPERATO, CHC Managing Partner Broad & Cassel Fort Lauderdale, FL 2:15 3:15 PM Setting the Tone at the Top: Board Leadership in Healthcare Compliance LEWIS MORRIS Adelman, Sheff & Smith, LLC Annapolis, Maryland 3:30 4:30 PM Physician-Hospital Integration FRANK SHEEDER Partner DLA Piper Dallas, TX 4:45 5:45 PM External Audit and the Audit Committee CHRIS IDEKER, CPA Managing Director Alvarez & Marsal Atlanta, GA 5:45 6:15 PM Q&A Session (All Speakers) 6:15 7:15 PM Networking Reception TUESDAY, FEBRUARY 26 7:00 AM 3:00 PM Registration 7:00 8:00 AM Continental Breakfast 8:00 9:00 AM Understanding Risk and the Balance of Internal Controls KELLY NUESKE Managing Director, Enterprise Risk Services Internal Audit & Compliance Sinaiko Healthcare Consulting, Inc. Los Angeles, CA 9:15 10:15 AM Enterprise Risk Management CARY SPAIN Partner PricewaterhouseCoopers LLP Risk Assurance Practice Denver, CO 10:30 11:30 AM Committee Charter: The Role and Responsibility of the Audit and Compliance Committee DEBBIE ANGUS Senior Director, Finance Seton Family of Hospitals Austin, TX 11:30 AM 12:30 PM Internal Audit, Compliance, & the Audit Committee KELLY SAUDERS Partner Deloitte & Touche LLP New York, NY REGISTER NOW! Space is limited to 70 attendees LEARN MORE AT

5 Letter from the CEO by Roy Snell, CHC, CCEP F Code of conduct Please don t hesitate to call me about anything any time Cell Direct corporatecompliance.org Snell I think most codes of conduct are too long. Many are 10 to 20 pages. We have lost our way with the code of conduct. It has been taken over by people who think it s a legal document. Whatever message you want to send to the employees about your expectations regarding their conduct gets lost in paragraph after paragraph about the laws that affect your organization. People seem to think they should cover every law and high risk area they can think of in the code of conduct. TEACHING THE RULE OF LAW IS IMPORTANT! Just don t do it in the code of conduct because once you do it, it is no longer a code of conduct, it is a legal manifesto. I would cover laws and risk areas in policies, procedures, during education, new employee orientation, management meetings, etc. You have ample opportunity to educate people about the rule of law. You have only one document that commits employees to a code of conduct. It is the Code of Conduct not the Code of Every Law I Can Think of. I would write a one page code of conduct. Boeing has and it is beautiful. The code is intended to say to the people, This is what we stand for, and if you don t follow this code you will be disciplined up to and including dismissal. Harsh you say? Enron, WorldCom, Tyco, Penn State, etc. didn t have a problem with people understanding the laws. They knew they were breaking the law. What they all failed to do was convince employees that their organization was serious about the employees conduct regarding following the rule of law. They didn t follow their code if they had one. If they had a code, it likely had a list of all the laws. Laws they were consciously breaking. People seem to think they should cover every law and high risk area they can think of in the code of conduct. TEACHING THE RULE OF LAW IS IMPORTANT! Just don t do it in the code of conduct because once you do it, it is no longer a code of conduct, it is a legal manifesto. Society has trouble with employees who choose not to follow the law and behave ethically. Employees need to know that it is not tolerated. Some people who break the law tell investigators that their leadership told them to do whatever it takes to get the job done. They tell the investigators the implication was that leadership wanted them to break the law or behave unethically. A signed, clear and short code of conduct (like Boeings) that states you will be disciplined if you break the law or behave unethically makes it difficult for people to say I did this with the encouragement of leadership

6 Contents January 2013 Features Columns 18 Meet Art Weiss an interview by John Falcetano 25 OIG 2013 Work Plan sheds light on new compliance projects: Part 1 by Nathaniel Lacktman with contributing authors at Foley & Lardner LLP A look at some of the planned enforcement projects for Medicare Parts A and B. 39 Structuring the Chief Ethics and Compliance Officer position: Frequently asked questions by Donna Boehme Who the CECO reports to, the levers of independence, and the strength of a Compliance Committee are important factors for a successful compliance program. 45 [CEU] Avoiding liability: Consistent screening of both permanent and temporary staff by Vu T. Do A cautionary tale about vicarious liability for medical employers who use temporary agencies to fill staff positions. 51 Best practices: Training programs to combat fraud, waste, and abuse by Ellen Leinfuss Four key areas to address as CMS signals its intent to take a proactive approach to assessing effective compliance. 3 Letter from the President Shawn DeGroot 5 Letter from the CEO Roy Snell 23 Exhale Shawn DeGroot 57 Social networking John Falcetano Departments 8 News 14 People on the move 86 HCCA congratulates new designees 88 HCCA welcomes new members Compliance Today index 93 Takeaways 94 Events calendar Compliance Today is printed with 100% soy-based, water-soluable inks on recycled paper. Interior pages are double-coated sheets made from 80% recycled content, which includes 60% post-consumer waste. The remaining 20% is virgin fiber that comes from responsibly managed forests and is FSC certified. Cover stock is made from 10% post-consumer waste and is produced near the printing facility in Minnesota. The energy used to produce the paper is 100% renewable. Certifications for the paper include The Forest Stewardship Council (FSC), Sustainable Forestry Initiative (SFI), and Green-e.org

7 We are now equally focused on the tone at the top and on creating and maintaining an ethical culture in addition to watching for violations of law. Articles See page Five guidelines for a compliant shared savings arrangement by Alexandra Higgins Cost savings arrangements between hospitals and physicians are becoming an increasingly important tool for hospital service lines and outpatient clinics. 63 Coding and documentation crimes: Are you a suspect? by Gretchen Dixon What TV crime shows can teach us about correct coding of evaluation and management services. 65 Radiation dose safety: Best practices by Brandon Taggart and Neomi Mullens Practical tips for implementing a dose monitoring system to ensure that radiation exposures are safe and reasonable for patients. 69 [CEU] HIPAA audits: Are you ready? by Rita Bowen Preliminary HIPAA audit findings and key insights into the specific compliance issues and weaknesses that auditors are expected to explore. 73 The changing role of the executive assistant: A hidden opportunity? by Valerie Loyola and Jeff Sinaiko Finding the right industry-experienced assistant to support the Compliance department can be a true win-win situation. 77 Changes in community mental health center scrutiny by Susan E. Nance Facilities that serve severely and persistently mentally ill Medicare and Medicaid beneficiaries are being examined for fraud, waste, and abuse. 81 [CEU] Compliance 101: Developing an effective compliance training program by Rebekah Crosby Step-by-step tips for developing relevant training the will engage the learner and promote compliant behavior. Compliance TODAY Editorial Board Gabriel Imperato, Esq., CHC, CT Contributing Editor, Managing Partner, Broad and Cassel Ofer Amit, MSEM, CHRC, Research Compliance Administrator, Baptist Health South Florida Janice A. Anderson, JD, BSN, Shareholder, Polsinelli Shughart, PC Christine Bachrach CHC, Chief Compliance Officer, University of Maryland Dorothy DeAngelis, Managing Director, FTI Consulting Gary W. Herschman, Chair, Health and Hospital Law Practice Group, Sills Cummis & Gross P.C. David Hoffman, JD, President, David Hoffman & Associates Richard P. Kusserow, President & CEO, Strategic Management F. Lisa Murtha, JD, CHC, CHRC, SNR Denton US LLP Robert H. Ossoff, DMD, MD, CHC, Assistant Vice Chancellor for Compliance and Corporate Integrity, Vanderbilt Medical Center Jacki Pemrick, Privacy Officer, Mayo Clinic Deborah Randall, JD, Law Office of Deborah Randall Emily Rayman, General Counsel and Chief Compliance Officer, Community Memorial Health System Rita A. Scichilone, MSHA, RHIA, CCS, CCS-P, Director of Practice Leadership, American Health Information Management Association James G. Sheehan, JD, Chief Integrity Officer, New York City Human Resources Administration Lisa Silveria, RN, BSN, Home Care Compliance, Catholic Healthcare West Jeffrey Sinaiko, President, Sinaiko Healthcare Consulting, Inc. Debbie Troklus, CHC-F, CCEP-F, CHRC, CHPC, Managing Director, Aegis Compliance and Ethics Center Cheryl Wagonhurst, JD, CCEP, Partner, Law Office of Cheryl Wagonhurst Linda Wolverton, CHC, CPHQ, CPMSM, CPCS, CHCQM, LHRM, RHIT, Vice President Compliance, Team Health, Inc. Executive Editor: Roy Snell, CHC, CCEP F, CEO, HCCA, hcca-info.org News and Story Editor/Advertising: Margaret R. Dragon, , hcca-info.org Copy Editor: Patricia Mees, CHC, CCEP, , hcca-info.org Copy Editor: Brook Matthiesen, , hcca-info.org Design & Layout: John Goodman, , hcca-info.org Compliance Today (CT) (ISSN ) is published by the Health Care Compliance Association (HCCA), 6500 Barrie Road, Suite 250, Minneapolis, MN Subscription rate is $295 a year for nonmembers. Periodicals postage-paid at Minneapolis, MN Postmaster: Send address changes to Compliance Today, 6500 Barrie Road, Suite 250, Minneapolis, MN Copyright 2012 Health Care Compliance Association. All rights reserved. Printed in the USA. Except where specifically encouraged, no part of this publication may be reproduced, in any form or by any means without prior written consent of the HCCA. For Advertising rates, call Margaret Dragon at Send press releases to M. Dragon, 41 Valley Rd, Nahant, MA Opinions expressed are not those of this publication or the HCCA. Mention of products and services does not constitute endorsement. Neither the HCCA nor CT is engaged in rendering legal or other professional services. If such assistance is needed, readers should consult professional counsel or other professional advisors for specific legal or ethical questions. Volume 15, Issue

8 News OIG Roundtable Report: Focus on Compliance: The next generation of Corporate Integrity Agreements In October the OIG issued a report on a roundtable meeting held on August 7, 2012 with representatives from 32 companies that have entered into Corporate Integrity Agreements (CIA) since The companies ranged from hospitals and ambulance companies to medical device manufacturers, physician practices, and skilled nursing facilities. According to the As the US health care industry continues its transformation to a patient-centric system, health care providers face a new imperative to collaborate with other entities to deliver quality care and improved outcomes with greater efficiency at lower costs. Whether driven by financial pressures, demands to improve quality of care, or new payment and delivery models focused on quality outcomes, health care organizations are Recently PricewaterhouseCoopers announced in a press release a new tool for board directors who are concerned with IT oversight. Overseeing a company s information technology (IT) activities is a significant concern for today s board directors, according to the PwC US Center for Board Governance. The rapid pace of change, complicated subject matter, and technical jargon used to describe emerging technology and associated risks make this a challenging area. This Associated Press reported on October 19, 2012 that Exeter Hospital said Friday it will correct serious problems, discovered after a hepatitis C outbreak last spring, in time to stop federal officials from cutting off its Medicare funding. The hospital has been trying to correct deficiencies identified in July by the Centers for OIG report, the purpose of the roundtable was to solicit feedback from the representatives regarding their compliance best practices and their efforts to implement the requirements of their CIAs. OIG will consider the feedback when deciding what terms to include in future CIAs. To view the report, use this link: https://oig.hhs.gov/ compliance/compliance-guidance/docs/focus_on_compliance.pdf. Ernst & Young health care report explores collaboration faced with challenges that require collaboration with others. These and other observations were released recently in Health Care Provider Industry Report 2012, Ernst & Young LLP s annual publication for the US health care provider industry. Use this link to download the publication: New_Horizons_2012_health_care_provider_report/$FILE/ New_horizons_2012_final_August_23.pdf. Center for Board Governance creates new IT oversight tool Read the latest news online latest research from PwC concludes that some directors are not comfortable overseeing IT for several identified reasons, creating an IT confidence gap. What can the board do to bridge this gap and more effectively oversee a company s information technology activities? PwC explains how in its new user-friendly board TM guide, Directors and IT: What Works Best. For more information and to download a copy of the guide, please visit: CMS may terminate Exeter Hospital s Medicare funding Medicare & Medicaid Services. Among them are efforts to improve the hospital s policies on controlling infections and administering drugs. For more on this: news/local/new-hampshire/2012/10/19/hospital-danger-losingmedicare-funding/rnfzqvze6f7f5rcaqso8oj/story.html

9 News Regulatory News New process for beneficiary name/number mismatches CMS has implemented a change in how it handles name and number mismatches. In the past, when a claim was submitted with a beneficiary name that did not match the name associated with the Health Insurance Claim Number (HICN) in CMS records, CMS assumed that the submitter made a mistake in listing the name. Accordingly, when the contractor returned the claim, it returned the name of the beneficiary that was associated with that HICN. If the submitter entered the wrong HICN, this could have resulted in the submitter receiving information belonging to a beneficiary the provider had not treated. If this happens in the future, the provider will instead receive the name it originally submitted with the claim. As part of this change, CMS will no longer perform name searches. A name search used to occur where there was a name/number mismatch and the system looked for a slight variation of the name, such as a switch of adjoining letters. In other words, a claim may have been processed even though the information submitted with the claim was not an exact match with CMS records. In the future, such claims will be returned. If that occurs, the provider will need to verify the beneficiary s entitlement information, correct its records, and resubmit the claim. Medicare Fraud Strike Force charges 91 medical professionals for false billing Medicare Fraud Strike Force operations in seven cities have led to charges against 91 individuals including doctors, nurses, and other licensed medical professionals for their alleged participation in Medicare fraud schemes involving approximately $429.2 million in false billing, Attorney General Eric Holder and Health and Human Services (HHS) Secretary Kathleen Sebelius announced in October. Dozens of charged individuals were arrested or surrendered as indictments were unsealed across the country. Together, those indictments charge more than $230 million in home health care fraud, more than $100 million in mental health care fraud, more than $49 million in ambulance transportation Read the latest news online fraud, and millions more in other frauds. HHS also suspended or took other administrative action against 30 health care providers, following a datadriven analysis and based upon credible allegations of fraud. Under the Affordable Care Act, HHS is able to suspend payments until the resolution of an investigation. For more: press/2012pres/10/ a.html From the MLN: Advance Beneficiary Notice of Noncoverage Part A and Part B booklet Revised The Advance Beneficiary Notice of Noncoverage Part A and Part B booklet was revised and is now available in hard copy format. This booklet is designed to provide education on the Advance Beneficiary Notice (ABN). It includes information on when an ABN should be used and how it should be completed. To access a new or revised product available for order in hard copy format, go to Medicare-Learning-Network-MLN/ MLNProducts and click on MLN Product Ordering Page under Related Links at the bottom of the web page

10 January New York, NY SOLD OUT february 4 7 San Francisco, CA LIMITED SEATS REMAIN march New Orleans, LA april 8 11 Chicago, IL June 3 6 Scottsdale, AZ register early Registration limited to 75 for each Academy to reserve your place 2013 basic CoMPLIAnCE academies august 5 8 New York, NY september Las Vegas, NV october Denver, CO november Orlando, FL december 2 5 San Diego, CA HCCA s basic Compliance Academy is an intensive three-and-a-half-day program focusing on subject areas at the heart of health care compliance practice. The Academy is designed for participants with a basic knowledge of compliance concepts and some professional experience in a compliance function. Want to become Certified in healthcare Compliance (ChC)? take the certification exam on the last day of the academy. Learn more and register at

11 HCCA News HCCA conference news Reduced pricing for web conferences HCCA is pleased to announce value pricing for our web conferences. An individual web conference is now priced at just $99, and the member price for a subscription to 10 conferences is just $750. And remember, you can have as many colleagues as you like join you in the same location on the same phone line for the web conference, making HCCA web conferences an extremely affordable way to earn CEUs and stay current on compliance challenges. To learn more and see the list of upcoming web conferences, visit New privacy academy added for 2013 A third Health Care Privacy Basic Compliance Academy has been added for HCCA s privacy academies are four-day comprehensive conferences that cover a broad spectrum of laws and regulations affecting health care organizations. Each academy s faculty has extensive experience in health care compliance and is well versed in health care privacy. The Certified in Healthcare Privacy Certification (CHPC) exam is offered at the conclusion of the academy for those participants looking to become CCB certified in health care privacy. November 4 7, Chicago, IL 003_CAP1113.aspx New regionals added for 2013 Regional conferences are one-day programs designed to provide the hot topics and practical information that compliance professionals need to create and maintain compliance programs in a variety of industries. Puerto Rico May 2 3, San Juan, PR 003_AREA2113.aspx Cascade Range June 28, Portland, OR 003_AREA2213.aspx HCCA News Are you subscribed to This Week in Corporate Compliance? If not, you should be. It s informative. And FREE. Once subscribed, TWCC will arrive every Friday in your with a wrap-up of the week s health care compliance-related news. To subscribe, visit HCCA s website and click on Resources. Find the latest conference information online

12 HCCA News HCCA website news Contact Tracey Page at or her at hcca-info.org with any questions about HCCA s website Events HCCA has more than 35 different events this year. All the information you need is available online. You can register for an event, find hotel information, or print the handouts. You can view the speakers, sign up for an exam (if it is offered at the event), or see if the event qualifies for any other CEUs you need. The Events section of the website is filled with important information. To check out your next event, go to Compliance Institute HCCA s Compliance Institute website is filled with great information for people attending and for people who can t make it this year. We have all the highlights, Twitter feed, speakers, and sessions available to view online. Make sure to purchase your CD-ROM recording of the conference early to get the best discount. Learn more at Certification questions Are you thinking about becoming certified, but you have a few questions before you jump in? Don t worry, so does everyone else. CCB has created a Candidates Frequently Asked Questions page with the most common questions the certification department receives. From what to study, how to apply, and when to renew, check out CCB s frequently asked questions at Corporate Compliance and Ethics Week Find great tips on how to engage your staff during Corporate Compliance and Ethics Week, May 5-11, The website offers posters, a web conference, and products to purchase and hand out during your events. Raise awareness and educate your employees on the importance of compliance and ethics in the workplace. For these and more great ideas, visit Start planning for Corporate Compliance and Ethics Week Corporate Compliance & Ethics Week May 5 11, 2013 Compliance Begins With You Find the latest HCCA website updates online See the brochure mailed with your magazine, or visit:

13 HCCA News news Contact Eric Newman at or him at hcca-info.org with any questions about HCCAnet. HCCAnet is the most comprehensive social network for health care compliance professionals, now with more than 10,800 members. Subscribe to discussion groups and get your compliance questions answered. Stay informed on the latest health care compliance news and information. Participate in 3 easy steps: 1. Login with your HCCA username and password at 2. Click My Subscriptions to subscribe to discussion groups 3. Click Post to participate in a group by posting a question Reply to these popular discussions on HCCAnet 2013 HCCA Compliance Institute Ideas Auditing and Monitoring Health Care Survey Length Chief Compliance and Ethics Officer Health Care Looking for a new opportunity Privacy Risk of Harm Assessment ABN Detail Questions Not in the CMS Processing Manual OIG Report on CMS and Breach Handling HIPAA Intranet Warning Statement For Employees Compliance Program Risk Assessment Compliance Plan Outside Review HHS/OIG Guidance on Compliance and Ethics Programs Under PPACA Health Care Billing and Reimbursement Physician payments Find the latest HCCAnet updates online HIPAA Warning message before accessing electronic patient records Ten Commandments of BYOD $5 for Social Security Number Disclosure Bargain? Need for authorization Cloning in the EHR HIPAA Audits Wrap Up Independent Medical Exams Hospital Photography/Videography Policy Privacy Officer s Roundtable DHS Clarification for EMS Access to Hospital/ED Outcomes Information Disclosure to Insurances by Logical Observation Identifiers Names and Codes (LOINC) Clinical Navigators HCCA Social Media Join the HCCA Group on LinkedIn, now with over 12,000 members! Follow the HCCA Company Page on LinkedIn Like HCCA on Facebook on Twitter Add HCCA to your circles on Google+ Watch compliance videos on the HCCA YouTube Channel

14 People on the Move Cynthia M. Patton has been appointed Senior Vice President and Chief Compliance Officer for Amgen, the company recently announced in a press release. In this role, Patton will report to Robert A. Bradway, President and Chief Executive Officer, and will be responsible for Amgen s worldwide compliance and business ethics organization. Patton joined Amgen in 2005, and was most recently a vice president in the Amgen Law department with responsibility for commercial legal activities in the United States. Previously, she served as the lead commercial lawyer for both the oncology and inflammation business units. Recently Sheridan Healthcare, Inc., a national hospital-based, multispecialty practice management company, announced the promotion of Denise Longman to Vice President and Chief Compliance Officer. Longman will oversee the Compliance and Internal Audit department, which promotes and monitors employees adherence to the company s policies and procedures. She also will supervise the execution of Sheridan s annual audit plan, comprising of all internal audits performed from a financial and operational controls perspective, as well People on the Move as medical record documentation and coding audits to ensure compliance with regulatory guidelines. She joined Sheridan in 2006 as the director of Internal Audit. The Battle Creek Enquirer reported in October 2012 that Neil Nyberg, retired vice president and chief ethics and compliance officer for Kellogg Company and current chair of the Bronson Battle Creek Hospital Community Partners board of trustees is the 2012 recipient of the Dale G. Griffin Healthcare Leadership Award. According to the notice, the award recognizes exemplary contributions that improve the quality and accessibility of healthcare in greater Battle Creek. More at viewart/ /neighborhoods01/ /Nyberg-receives-healthcareleadership-award Recently Kaleida Health named Robert G. Trusiak as Senior Associate General Counsel and Chief Compliance Officer, according to a company press release. In this role, Trusiak will be responsible for legal affairs concerning the health system and will ensure Kaleida Health s commitment to conformance with all federal, state, and local healthcare regulations as well as internal policies. Prior to Kaleida Health, Trusiak served as Assistant United States Attorney, Western District of New York. Trusiak s previous positions also include Assistant United States Attorney, Northern District of Ohio, and assistant prosecuting attorney. Received a promotion? Have a new hire in your department? If you ve received a promotion, award, or degree; accepted a new position; or added a new staff member to your Compliance department, please let us know. It s a great way to keep the Compliance community up-to-date. Send your updates to hcca-info.org

15 Help Keep Your Compliance Program Fully Staffed List Your Job Openings Online with HCCA It s hard to have an effective compliance program when you have openings on your team. Help fill those openings quickly list your compliance job opportunities with the Health Care Compliance Association. Benefits include: Listing is posted for 90 days to maximize exposure Targeted audience Your ad is also included in our monthly HCCA Jobs Newsletter, which reaches more than 14,000 s Don t leave your compliance positions open any longer than necessary. Post your job listings with HCCA today. Visit Or call us at

16 We don t want to scare you. We re pretty sure the auditors and the OIG have that covered. Besides, you already know that your bottom line in healthcare today depends upon your ability to manage risk. What you need is real help, and we re here with real solutions to proactively assess, understand, communicate and, most importantly, mitigate risk across your entire enterprise. Enterprise Risk When you re stuck relying on risk assessment software retrofitted to the healthcare industry, it can feel as if your risk is managing you. Particularly when that software turns out to be an empty shell with no content to inform or guide your decision making. Our solutions combine ComplyTrack, the #1 tool for managing risk in hospitals, with the unparalleled breadth and depth of regulatory content available in the MediRegs Reference Suites, the in-depth expertise reflected in our Risk Assessment Question Sets and Controls, and our unmatched implementation, training, support and education services. Our strategic partnerships with leading companies in coding education, claims audit, breach detection, and HITRUST validation provide you with end-to-end solutions for managing your entire universe of risk, from the top down and from the bottom up.

17 Visit mediregs.com/erm for more information. Go beyond risk management to improving your overall regulatory compliance, all while insuring you get paid fairly for the services you provide. Our SaaS solutions are customized, scalable, complete, and created and supported by experts in healthcare risk, audit and compliance. Financial Audit Risk The volume and complexity of financial audits and appeals in healthcare has grown too high, too fast to manage. And each audit could negatively impact your bottom line. You know you need a solution to track all your claims-based audits. But to proactively reduce your audit risk you need predictive analytics tools and the most complete regulatory reference portal. We ve partnered to develop a complete endto-end solution for efficiently and effectively managing the entire process for all financial audits, both RAC and non-rac. Information Security Risk Your reputation and your bottom line depend on protecting patient data, but your PHI is only as secure as your weakest link. Find those weak links, fix them, report progress in real time and prove you ve done it all correctly with a solution developed specifically for the complex needs of Healthcare IT, IS and Internal Audit professionals. Manage the entire life span of risk assessments and handle audits with ease using our exclusive integration of the HITRUST Common Security Framework (CSF) and the ComplyTrack platform.

18 Feature Art Weiss, JD, CCEP, CCEP-I Chief Compliance and Ethics Officer TAMKO Building Products Joplin, Missouri an interview by John Falcetano Meet Art Weiss John Falcetano, CHC-F, CCEP-F, CHRC, CHPC, CIA, CICA conducted this interview with Art Weiss in October John is the Chief Audit/Compliance Officer for Vidant Health and Vice President of the HCCA Board of Directors. JF: Thank you for doing this interview. Can you please tell our readers a little about your background? AW: I have been practicing law for over 30 years. Prior to that, I was a radio news editor, anchorman, and reporter. I began my legal career working in-house for the National Association of Realtors, the world s largest trade association. After a couple of years doing that, I decided I wanted to go back into prosecution, where I had interned during law school. I spent four years prosecuting criminal cases, from homicide to DUI. The Attorney General of Kansas, whom I had met my first week of law school, when I walked into his outer office and asked if I could meet the AG, called me one day about heading the Consumer Protection Division. I had never prosecuted consumer fraud, but the challenge sounded interesting. I took the job and spent the next 13 years at it. JF: Can you tell our readers a bit about TAMKO? AW: TAMKO Building Products, Inc. is one of the nation s largest independent

19 Feature manufacturers of residential and commercial roofing products, decking and railing products, waterproofing, cements, and coatings. TAMKO is privately owned and has been in business for more than 65 years. We believe our success can be attributed to teamwork and enduring relationships with customers, suppliers, and employees. We believe in 100% compliance, 100% of the time, by 100% of our employees. JF: How did you get into Compliance? AW: I received a call one day, while I was with the Texas Attorney General s Office, from the Governmental Affairs Director and an in-house attorney with Sears, Roebuck and Co. Sears had made several missteps and was working to get back on track and repair its image with the state attorneys general. I greatly respected these gentlemen, since I had negotiated settlements with them over the years on various advertising issues, and had always found them to be honest and trustworthy. They asked me to interview for a senior counsel position with their Law department. I accepted the position with the Sears Law Department in a compliance and regulatory function. The goal was to educate employees on the law and keep the company out of regulatory trouble with my former fellow prosecutors. Six years later, I received a call about a third-generation family-run building products company in Joplin, Missouri that was looking for its first chief compliance officer to establish a compliance and ethics program. That company was TAMKO Building Products, Inc. JF: I see that you serve on the Advisory Board of the Society of Corporate Compliance and Ethics (SCCE). Can you tell me some of the things you do in that capacity? AW: I am fortunate to serve on the board with highly qualified current and former in-house compliance professionals. Their dedication to the Compliance profession knows no bounds. My participation has been primarily in an advisory role to the SCCE staff and leadership on matters such as education and experience enhancements for our members. This includes the Compliance and Ethics Institute, the Basic Academies, regional meetings, and web conferences. We also develop and improve upon membership benefits and communications between SCCE and its members. JF: You are also on the Compliance Certification Board and are faculty for SCCE s Compliance and Ethics Academies. How do you find the time to do all that? AW: Early in my tenure as TAMKO s Compliance Officer, I found that the most beneficial aspect of my participation in SCCE was the amazing opportunities for networking with other compliance professionals. The single largest benefit of SCCE to me and my company is the sharing of ideas with those compliance professionals. The sharing of ideas, strategies, policies, processes, and best practices with other compliance professionals has allowed me to continuously improve my company s compliance and ethics program. JF: How supportive is your organization with you being so involved in the compliance community? AW: TAMKO s CEO speaks frequently of 100% compliance, 100% of the time. One way to achieve that goal is through boundaryless collaboration and continuous improvement. As I became increasingly involved in SCCE activities, our CEO told me he would rather have me networking with my colleagues than sitting in my office trying to come up with ideas on my own. The U.S. Sentencing Commission and the Department of Justice have long favored benchmarking and utilizing best practices. My participation in SCCE activities provides an opportunity to do that. JF: You have been in the compliance profession for a long time. What has changed the

20 Feature most in the roles and responsibilities of the compliance professional? AW: When I left the government in 2000, compliance as a profession was still in its infancy. In my first private-sector organization, we had a group in the Law department that dealt with SEC filings and another that dealt with responding to regulatory inquiries. Those areas constituted a major portion of compliance work at many organizations in the early days. Most compliance programs were aimed toward preventing and detecting violations of law. That was what the government told us to put into place. I think the biggest change since then is the evolution of corporate culture. We are now equally focused on the tone at the top and on creating and maintaining an ethical culture in addition to watching for violations of law. This only makes sense. After all, people who respect each other don t harass co-workers; people who are honest don t take inappropriate gifts or offer bribes. I think our focus has come around to where it needs to be. JF: What would you say is the biggest compliance risk facing your organization today? AW: I think it is keeping up with current laws and regulations, and trying to stay informed of the new ones we are continually being subjected to. You can t obey a law you don t know about. JF: In your organization, where does the chief compliance and ethics officer fit in the organizational structure? AW: At our organization, the compliance function is totally independent. I report directly to the president and CEO and the This only makes sense. After all, people who respect each other don t harass co-workers; people who are honest don t take inappropriate gifts or offer bribes. board. There are no filters or barriers to my access to the governing authority. JF: We sometimes hear of communication difficulties between legal counsel and the compliance officers. What type of working relationship have you developed with your legal counsel? AW: I believe I have an excellent working relationship with our general counsel. We share a common belief in 100% compliance with the law. We work together on training, investigations, and employee communications. Since we are a relatively small company (around 1,500 employees), we are able to conduct live training on important legal and compliance topics. For example, our annual Prevention of Harassment and Ethics training sessions consist of me and an associate general counsel doing a joint session. The general counsel and I often seek each other s input on matters of policy, and we have specific processes in place that define our roles. We meet regularly to keep the lines of communication open. I jokingly told him once that I was not going to throw away my legal hat, but he was free to accept or reject my advice. On matters of legal consequence, he is the first person I consult. On matters of compliance, that same process works in reverse. JF: Do you see any difference between your role as a compliance and ethics officer in your industry compared to health care? AW: Manufacturing and health care are both highly regulated industries. In that, we are similar. Instead of HIPAA or billing and coding, I think about environmental and

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