Compliance Program Training
|
|
- Dale Richard
- 7 years ago
- Views:
Transcription
1 Compliance Program Training June 21, 2016 Presented by: BHN Compliance Department
2 Overview Banner Health Network s (BHN) Mission, Vision and Values Culture of Compliance Ethics Do The Right Thing! Compliance Program Basics BHN Resources Additional Resources
3 BHN s Mission, Vision And Values Mission Vision Values We exist to make a difference in people s lives through excellent patient care. We will be a national leader recognized for clinical excellence and innovation, preferred for a highly coordinated patient experience, and distinguished by the quality of our people. People Above All by treating those we serve and each other with compassion, dignity, and respect; Excellence by acting with integrity and striving for the highest quality care and service; Results we show we value results by exceeding the expectations of the people we serve, as well as expectations we set for ourselves.
4 A Culture Of Compliance Within Banner Health Network Do the right thing Prevents noncompliance Detects non compliance Corrects non compliance
5 Ethics Do The Right Thing! BHN is committed to possessing and demonstrating the reliability, honesty, trustworthiness and high degree of integrity expected of a leading healthcare organization and a participant in federally funded health-care programs. It is important that you conduct yourself in an ethical and legal manner. It s about doing the right thing! Act fairly and honestly Comply with the letter and spirit of the law Adhere to high ethical standards in all that you do Report suspected violations
6 How Do I Know What Is Expected Of Me? The BHN Code of Conduct state compliance expectations and the principles and values by which an organization operates. Each Employee and delegate/vendor must report any issue or practice that they believe in good faith may constitute a violation of a law or BHN s compliance policies. BHN strictly prohibits retaliation against any individual who in good faith reports a suspected violation or suspected illegal or unethical conduct. People who are found to have engaged in unlawful conduct or conduct in violation of BHN policies, or who have failed to detect, report and/or correct any offense, are subject to corrective action, up to and including termination.
7 Compliance Program Basics The Office of Inspector General (OIG) has outlined 7 components of an effective compliance program. Banner Health Network has incorporated these into our comprehensive compliance program. 1. Written Policies, Procedures and Standards of Conduct; 2. Compliance Leadership and Structure; 3. Effective Training and Education; 4. Effective Lines of Communication; 5. Effective System for Routine Monitoring and Identification of Compliance Risks; and 6. Enforcement of Compliance Standards; 7. Procedures and System for Prompt Response to Compliance Issues
8 Written Policies And Procedures And Standards Of Conduct Banner Health Network (BHN) has corporate policies and procedures (P&Ps) that address laws that affect all BHN associates, such as the Code of Conduct, reporting suspected non-compliance and HIPAA. Business departments and delegates/vendors are required to develop and distribute P&Ps that address the laws specific to their business functions. P&Ps should include the legal citations for the compliance requirements. P&Ps should be reviewed and updated as needed, but no less than annually, to assess compliance with any current requirements. P&Ps should be reviewed when changes are made in business activities that may impact compliance or when new compliance requirements are identified.
9 Compliance Leadership And Structure BHN has designated the leadership and defined a structure to oversee implementation and maintenance of the Compliance Program. Appropriate compliance committees are charged with the responsibility and authority to direct and monitor components of the Compliance Program. The Compliance Department reports monitoring results, regulator audits, and compliance issues and concerns to these committees.
10 Compliance Leadership And Structure (continued) The purpose of the Compliance Department is to assist the company to be compliant with all laws and to monitor compliance to identify compliance issues. Some of the key responsibilities of the Compliance Department are: Interpret new laws and assist business departments to implement compliant processes Complete a compliance risk assessment and conduct compliance oversight activities Assist business departments to understand existing compliance requirements and develop and maintain compliant processes Coordinate audits and responses and any subsequent CAPs Monitor the Integrity Line and investigate and triage calls
11 Effective Training And Education BHN has regular compliance education and training programs for all associates. Compliance Training programs Formal training 1. Initial and annual compliance training programs required for all associates. 2. Specialized training in compliance requirements for specific business functions, such as claims payment, medical management and service center. 3. Focused training as needed Informal and ongoing training 1. s 2. Newsletters 3. Posters
12 Effective Line Of Communication BHN has established lines of communication for compliance issues, including an open line of communication between the compliance department and all associates and delegates/vendors. The BHN ComplyLine ( ) or at are available to submit potential ethics issues or other compliance concerns. The Compliance Department is available to all associates and delegates/vendors to report compliance issues or to respond to compliance questions. BHN has a non-retaliation policy to protect anyone who makes a report in good faith about a potential compliance; fraud, waste and abuse; or ethics issue.
13 Auditing And Monitoring BHN monitors compliance to identify compliance deficiencies so that the deficiencies can be corrected. The Compliance Department conducts a risk assessment, at least annually, to establish priorities for monitoring. The Compliance Department uses a variety of methods to monitor compliance that include, but are not limited to: Reviews critical documents used by business departments, including but not limited to policies, template letters, and provider & member communication to evaluate correct interpretation of compliance requirements.
14 Auditing And Monitoring (cont d) Collects results of compliance metrics. Metrics are most often used for reportable data, such as turnaround times and report rates. The Compliance Department monitors metrics submitted by the business departments. Conducts compliance assessments on processes that are not easily measured by data and activities that are not audited by Internal Audit Department. 1. Priorities for assessments may be identified: During the risk assessment. During implementation or transition of implementation of new laws. As part of Corrective Action Plans or monitoring requirements.
15 Auditing And Monitoring (cont d) Compliance monitoring is not just the responsibility of the Compliance Department. Business departments and delegates/vendors are expected to conduct ongoing compliance monitoring, too. Appropriate compliance monitoring and reporting activities should be developed and implemented during implementation of any new or changed requirements. The ability to produce evidence of compliance often requires some method of ongoing compliance monitoring to ensure that processes remain compliant and corrective actions are taken when deficiencies are identified. The Compliance Department is available to discuss compliance monitoring activities upon request during implementation or at any time a department or delegate/vendor would like to initiate a new monitoring activity or review the effectiveness of an existing monitoring activity.
16 Auditing And Monitoring (cont d) Business departments and delegates/vendors should be able to provide evidence of compliance at all times. Evidence of compliance may be requested for many reasons, including regulatory audits, market conduct requests, legal requests, or concerns about compliance. Evidence of compliance is documentation that can be produced on a periodic basis, or as requested, to demonstrate that a business department and delegate/vendor is maintaining sustained compliance with a regulatory requirement. Evidence of compliance often requires evidence of compliant outcomes, such as claims payment, not just processes, such as P&Ps.
17 Enforcement Of Compliance Standards BHN has implemented disciplinary mechanisms to consistently enforce standards and address dealings with sanctioned and other specified individuals. BHN s P&Ps provide disciplinary guidance for associates who fail to comply with the Compliance Program or with compliance requirements. BHN s policy requires a reasonable and prudent background investigation to determine whether prospective associates, sub-contractors, agents or providers were ever criminally convicted, suspended, debarred or excluded from participation in a federal program.
18 Procedures And System For Prompt Response To Compliance Issues BHN has P&Ps about responding to detected compliance offenses, to initiate corrective action to prevent similar offenses, and to report to Government authorities when appropriate. Compliance issues should be reported to the Compliance Department. Compliance issues may initially be reported by an associate to their supervisor and then escalated/reported to Compliance, as appropriate. Business departments with an identified compliance issue are required to develop and implement a corrective action plan (CAP). The Compliance Department will review and monitor the CAP until the compliance issue is resolved. The Compliance Department will determine when a compliance issue must be reported to a Government authority and will facilitate the report.
19 Who Is Responsible For Compliance? Compliance Everyone is responsible for compliance. The Board of Directors and Executive Leaders have overall responsibility for the company s Compliance Program, but each associate and delegate/vendor is responsible to know and comply with all laws related to his/her job and to report non-compliance to a supervisor, the ComplyLine, and/or the Compliance Department.
20 Why Is Compliance Important? Compliance is lights on. BHN must be a compliant company to stay in business. Being a compliant company makes good business sense. The extent to which we are compliant affects our ability to grow our business, to maintain a positive reputation, and to become the innovative industry leader that we aspire to be. Our focus on compliance underscores our core values of honesty, integrity, transparency and accountability. Correcting compliance problems costs money and resources and reduces activities to grow and improve our company. If compliant programs are implemented and sustained, Banner Health Network can focus on its business opportunities.
21 What Does Non-Compliance Cost? Non-compliance costs the company many ways in the shortterm and long-term. In the short-term, it can lead to fines, lawsuits, increased regulatory scrutiny, bad publicity and even increased regulations. In the long-term, non-compliance can lead to loss of business, reputation, and revenue. Once the company is fined or sanctioned, the story is often repeated in related articles for many years continuing to damage the company s reputation.
22 BHN Resources Terri (Theresa) Dorazio BHN Compliance Director Banner Code of Conduct Banner Compliance Handbook BHN Compliance Program and FWA Plan ComplyLine (888)
23 Social Security Act: Title 18 Additional Resources Code of Federal Regulations*: 42 CFR Parts 422 (Part C) and 423 (Part D) and 425 (ACO) CMS Guidance: Manuals HPMS Memos CMS Contracts: Private entities apply and contracts are renewed/non-renewed each year Other Sources: OIG/DOJ (fraud, waste and abuse (FWA)) HHS (HIPAA privacy)
24 Additional Resources Title XVIII of the Social Security Act Medicare Regulations governing Parts C and D (42 C.F.R. 422, 423 and 425) Offshore Attestation Guidance 2008 CMS Call Letter issued 4/19/2007 HPMS Offshore Attestation memos dated 7/23/2007, 9/20/2007 and 8/26/2008 Civil False Claims Act (31 U.S.C ) Criminal False Claims Statute (18 U.S.C. 287,1001) Anti-Kickback Statute (42 U.S.C. 1320a-7b(b)) Antitrust Laws (15 U.S.C. 1-7) (15 U.S.C ) Stark Law Statute (Physician Self-Referral Law) (42 U.S.C. 1395nn) Intellectual Property Law (U.S. Patent and Trademark Office) Exclusion entity instruction (42 U.S.C. 1395a-7) The Health Insurance Portability and Accountability Act of 1996 (HIPAA) (Public Law ) (45 CFR Part 160 and Part 164, Subparts A and E) OIG Compliance Program Guidance for the Healthcare Industry:
AppleCare. 2013 General Compliance Training
AppleCare 2013 General Compliance Training Goals After completing this course, you will understand: The Principles of Ethics and Integrity and the Compliance Plan How to report a suspected or detected
More information2012-2013 MEDICARE COMPLIANCE TRAINING EMPLOYEES & FDR S. 2012 Revised
2012-2013 MEDICARE COMPLIANCE TRAINING EMPLOYEES & FDR S 2012 Revised 1 Introduction CMS Requirements As of January 1, 2011, Federal Regulations require that Medicare Advantage Organizations (MAOs) and
More informationCompliance Training for Medicare Programs Version 1.0 2/22/2013
Compliance Training for Medicare Programs Version 1.0 2/22/2013 Independence Blue Cross is an independent licensee of the Blue Cross and Blue Shield Association. 1 The Compliance Program Setting standards
More informationCODE OF CONDUCT. Our commitment to ethical conduct and compliance depends on all UHS personnel.
CODE OF CONDUCT Our commitment to ethical conduct and compliance depends on all UHS personnel. If you find yourself in an ethical dilemma or suspect inappropriate or illegal conduct, discuss it with your
More informationCODE OF CONDUCT. Providers, Suppliers and Contractors
CODE OF CONDUCT Providers, Suppliers and Contractors Table of Contents Code of Conduct... Honesty and integrity... Quality and Service... Responsibilities of Providers, Suppliers and Contractors... Compliance
More informationAccountable Care Organization. Medicare Shared Savings Program. Compliance Plan
Accountable Care Organization Participating In The Medicare Shared Savings Program Compliance Plan 2014 Corporate Location: 3190 Fairview Park Drive Falls Church, VA 22042 ARTICLE I INTRODUCTION This Compliance
More informationStandards of Conduct for First Tier, Downstream, and Related Entities (FDR)
Standards of Conduct for First Tier, Downstream, and Related Entities (FDR) The Health Plan 52160 National Road East St. Clairsville, Ohio 43950-9365 740.695.7902, 1.888.847.7902 TDD: 740.695.7919, 1.800.622.3925
More informationMedicare Parts C & D Fraud, Waste, and Abuse Training and General Compliance Training
Medicare Parts C & D Fraud, Waste, and Abuse Training and General Compliance Training Developed by the Centers for Medicare & Medicaid Services Issued: February, 2013 Important Notice This training module
More informationMSO/IPA Compliance Program
MSO/IPA Compliance Program PROSPECT MEDICAL HOLDINGS, INC. MSO/IPA COMPLIANCE PROGRAM Coverage The terms of the Compliance Program set forth herein shall apply to, and govern, the medical group business
More informationMedicare Parts C & D Fraud, Waste, and Abuse Training and General Compliance Training. Important Notice
Medicare Parts C & D Fraud, Waste, and Abuse Training and General Compliance Training Developed by the Centers for Medicare & Medicaid Services Issued: February, 2013 Important Notice This training module
More informationCompliance Requirements for Healthcare Carriers
INFORMATION DRIVES SOUND ANALYSIS, INSIGHT REGULATORY COMPLIANCE ADVISORY Compliance Requirements for Healthcare Carriers Introduction With the introduction of the new healthcare exchanges in January 2014
More informationThe following presentation was based on the
Fraud Waste and Abuse Presentation The following presentation was based on the Medicare Parts C & D Fraud, Waste, and Abuse Training and General Compliance Training developed by the Centers for Medicare
More informationHope In-Home Care CODE OF CONDUCT AND ETHICS
Hope In-Home Care CODE OF CONDUCT AND ETHICS September 2014 Table of Contents A MESSAGE FROM OUR DIRECTOR... 3 INTRODUCTION TO THE CODE OF CONDUCT AND ETHICS... 4 ELEMENT 1: QUALITY OF CARE... 5 ELEMENT
More informationCompliance Program Code of Conduct
Compliance Program Code of Conduct INTRODUCTION All personnel must not only act in compliance with all applicable legal rules and regulations, but also strive to avoid even the appearance of impropriety.
More informationPrepared by: The Office of Corporate Compliance & HIPAA Administration
Gwinnett Health System s Annual Education 2014 Corporate Compliance: Our Commitment to Excellence Prepared by: The Office of Corporate Compliance & HIPAA Administration Objectives After completing this
More informationStandards of. Conduct. Important Phone Number for Reporting Violations
Standards of Conduct It is the policy of Security Health Plan that all its business be conducted honestly, ethically, and with integrity. Security Health Plan s relationships with members, hospitals, clinics,
More informationWhat is a Compliance Program?
Course Objectives Learn about the most important elements of the compliance program; Increase awareness and effectiveness of our compliance program; Learn about the important laws and what the government
More informationFraud, Waste, and Abuse
These training materials are divided into three topics to meet the responsibilities stated on the previous pages: Fraud, Waste, Compliance Program Standards of Conduct Although the information contained
More informationCode of Conduct. 3. SCOPE: All PHI Air Medical Personnel
Page No. 1 of 8 1. POLICY: This policy defines the commitment that PHI Air Medical, L.L.C (PHI Air Medical) has to conducting our activities in full compliance with all federal, state and local laws. Our
More informationPHI Air Medical, L.L.C. Compliance Plan
Page No. 1 of 13 Introduction: The PHI Air Medical, L.L.C. is to be used by employees, contractors and vendors to get a high level understanding of the key regulatory requirements relating to our participation
More informationCODE OF CONDUCT I. POLICY
CODE OF CONDUCT American Ambulance continually strives to provide high quality emergency care and medical transportation services to our patients, and to maintain high standards of integrity in our dealings
More informationThe United States spends more than $1 trillion each year on healthcare
Managed Care Fraud and Abuse Compliance Guidelines I. Introduction The United States spends more than $1 trillion each year on healthcare representing approximately 15 percent of the gross national product.
More informationDeveloped by the Centers for Medicare & Medicaid Services. Issued: February, 2013
CMS Fraud, Waste, and Abuse Training and General Compliance Training Developed by the Centers for Medicare & Medicaid Services Issued: February, 2013 Important Notice This training module consists of two
More informationApproved by the Audit and Compliance Committee of the Providence Health & Services Board of Directors
Integrity and Compliance Description Approved by the Audit Committee of the Providence Health & Services Board of Directors December 7, 2009 Contents: Introduction Page 1 Purpose Page 2 Compliance Administration
More informationMEDICAID AND MEDICARE (PARTS C&D) FRAUD, WASTE AND ABUSE TRAINING
MEDICAID AND MEDICARE (PARTS C&D) FRAUD, WASTE AND ABUSE TRAINING Why Do I Need Training/Where Do I Fit in? Why Do I Need Training? Every year millions of dollars are improperly spent because of fraud,
More informationPreferred IPA Medicare Fraud, Waste, and Abuse Training General Compliance Training HIPAA Compliance Training 2014-2015
Preferred IPA Medicare Fraud, Waste, and Abuse Training General Compliance Training HIPAA Compliance Training 2014-2015 This training program consists of three parts: 1. Medicare Parts C & D Fraud, Waste,
More informationUSC Office of Compliance
PURPOSE This policy complies with requirements under the Deficit Reduction Act of 2005 and other federal and state fraud and abuse laws. It provides guidance on activities that could result in incidents
More informationFraud, Waste and Abuse Prevention Training
Fraud, Waste and Abuse Prevention Training The Centers for Medicare & Medicaid Services (CMS) requires annual fraud, waste and abuse training for organizations providing health services to MA or Medicare
More informationBusiness Conduct, Compliance and Ethics Program. important
Business Conduct, Compliance and Ethics Program important Table of Contents Letter from Troy Kirchenbauer As healthcare s first online direct contracting market, aptitude is committed to upholding the
More informationMental Health Resources, Inc. Mental Health Resources, Inc. Corporate Compliance Plan Corporate Compliance Plan
Mental Health Resources, Inc. Mental Health Resources, Inc. Corporate Compliance Plan Corporate Compliance Plan Adopted: January 2, 2007 Revised by Board of Directors on September 4, 2007 Revised and Amended
More informationCORPORATE COMPLIANCE PROGRAM
CORPORATE COMPLIANCE PROGRAM BACKGROUND AND POLICY: The Oakwood Accountable Care Organization, LLC. ( ACO ) corporate policy relating to compliance with applicable laws and regulations is embodied in this
More information13.4 PHI Air Medical Code of Conduct
I. PURPOSE PHI Air Medical continually strives to provide high quality emergency care and medical transportation services to our patients, and to maintain high standards of integrity in our dealings with
More informationFraud Waste and Abuse Training First Tier, Downstream and Related Entities
Fraud Waste and Abuse Training First Tier, Downstream and Related Entities Revised: 04/2010 OVERVIEW Centene Corporation Purpose Bridgeway Compliance Program Definitions of Fraud Waste & Abuse Laws and
More informationCORPORATE COMPLIANCE: BILLING & CODING COMPLIANCE
SUBJECT: CORPORATE COMPLIANCE: BILLING & CODING COMPLIANCE MISSION: Quality, honesty and integrity, in everything we do, are important values to all of us who are associated with ENTITY NAME ( ENTITY NAME
More informationMEDICARE COMPLIANCE AND FRAUD, WASTE AND ABUSE PLAN
MEDICARE COMPLIANCE AND FRAUD, WASTE AND ABUSE PLAN 2015 Alignment Healthcare LETTER FROM THE PRESIDENT DEAR ALIGNMENT HEALTHCARE ASSOCIATES, Alignment Healthcare USA is strongly committed to ethical
More informationCOMPLIANCE PROGRAM GUIDANCE FOR MEDICARE FEE-FOR-SERVICE CONTRACTORS
Department of Health and Human Services CENTERS FOR MEDICARE & MEDICAID SERVICES COMPLIANCE PROGRAM GUIDANCE FOR MEDICARE FEE-FOR-SERVICE CONTRACTORS March 2005 TABLE OF CONTENTS INTRODUCTION...3 ELEMENTS
More informationEstablishing An Effective Corporate Compliance Program Joan Feldman, Esq. Vincenzo Carannante, Esq. William Roberts, Esq.
Establishing An Effective Corporate Compliance Program Joan Feldman, Esq. Vincenzo Carannante, Esq. William Roberts, Esq. November 11, 2014 Shipman & Goodwin LLP 2014. All rights reserved. HARTFORD STAMFORD
More informationFraud Waste and Abuse Training First Tier, Downstream and Related Entities. ONECare by Care1st Health Plan Arizona, Inc. (HMO) Revised: 10/2009
Fraud Waste and Abuse Training First Tier, Downstream and Related Entities ONECare by Care1st Health Plan Arizona, Inc. (HMO) Revised: 10/2009 Overview Purpose Care1st/ ONECare Compliance Program Definitions
More informationMEDICAID AND MEDICARE (PARTS C&D) FRAUD, WASTE AND ABUSE TRAINING
MEDICAID AND MEDICARE (PARTS C&D) FRAUD, WASTE AND ABUSE TRAINING Why Do I Need Training/Where Do I Fit in? Why Do I Need Training? Every year millions of dollars are improperly spent because of fraud,
More informationCode of Conduct. All GlobalHealth employees, officers, directors, and agents must read the Code of Conduct and sign a Compliance Certification form.
Code of Conduct Commitment GlobalHealth, Inc. ( GlobalHealth ) and its affiliates are committed to doing business in compliance with all applicable Federal and State laws and regulations. This Code of
More informationFraud/Abuse and False Claims Act Compliance Education for Providers, Contractors, and Vendors. Presented by: by: Compliance Department
Fraud/Abuse and False Claims Act Compliance Education for Providers, Contractors, and Vendors Presented by: by: Compliance Department 6/26/2013 Purpose Welcome to JHHC Corporate Compliance Training Program
More informationSAINT FRANCIS HEALTHCARE PARTNERS ACO, INC. CORPORATE COMPLIANCE PLAN. Adopted by Resolution of the Board of Directors on June 24, 2014
SAINT FRANCIS HEALTHCARE PARTNERS ACO, INC. CORPORATE COMPLIANCE PLAN Adopted by Resolution of the Board of Directors on June 24, 2014 TABLE OF CONTENTS PAGE CORPORATE COMPLIANCE PLAN... 1 MISSION STATEMENT
More informationCompliance, Code of Conduct & Ethics Program Cantex Continuing Care Network. Contents
Compliance, Code of Conduct & Ethics Program Cantex Continuing Care Network Contents Compliance, Code of Conduct & Ethics Program 1 What is the CCCN Code of Conduct? 2 Operating Philosophies 2 Employee
More informationBanner s ComplyLine (888) 747-7989
Compliance Handbook Our Nonprofit Mission We exist to make a difference in people s lives through excellent patient care. Our Values We Value: People above all... by treating those we serve and each other
More informationProviders are expected to conduct their business activities in full compliance with all applicable state and federal laws.
8. Compliance KP strives to demonstrate high ethical standards in its business practices. The Agreement details specific laws and contractual provisions with which you are expected to comply. This section
More informationDescription of a First Tier, Downstream, and Related Entity
We at Health Partners Plans (HPP) would like to thank you for your partnership with HPP and helping us to provide exceptional service to our Medicare beneficiaries. The Centers for Medicare and Medicaid
More informationHealth Management Annual Compliance Training
Health Management Annual Compliance Training 2011 1 Introduction Welcome to 2011 Annual Compliance Training! The purpose of Annual Compliance Training is to: 1. Remind all associates of the elements of
More informationCOMPLIANCE PROGRAM AND COMPLIANCE CODE OF CONDUCT
COMPLIANCE PROGRAM AND COMPLIANCE CODE OF CONDUCT I. COMPLIANCE PROGRAM IN GENERAL A. MISSION. B. PURPOSE. It is the mission of My Choice Family Care ( MCFC ) to respect the dignity and personal autonomy
More informationFWA Program. Program Description. Issued by: Regulatory Compliance Department
FWA Program Program Description Issued by: Regulatory Compliance Department July 2016 2016 FWA Program Description Page 1 of 16 Table of Contents Introduction Introduction..3 Definitions 4 Examples..6
More informationFraud, Waste and Abuse Training for Medicare and Medicaid Providers
Fraud, Waste and Abuse Training for Medicare and Medicaid Providers For Use By: Licensed affiliates and subsidiaries of Magellan Health Services, Inc. Contents and Agenda Define Fraud, Waste, and Abuse
More informationHealthcare Compliance and Hybrid Entity Designation
[New OP initial posting 8/28/14] Operating Policy and Procedure : Healthcare Compliance and Hybrid Entity Designation DATE: August 28, 2014 PURPOSE: The purpose of this Texas Tech Operating Policy and
More informationPOLICY SUBJECT: EFFECTIVE DATE: 5/31/2013. To be reviewed at least annually by the Ethics & Compliance Committee COMPLIANCE PLAN OVERVIEW
Compliance Policy Number 1 POLICY SUBJECT: EFFECTIVE DATE: 5/31/2013 Compliance Plan To be reviewed at least annually by the Ethics & Compliance Committee COMPLIANCE PLAN OVERVIEW Sound Inpatient Physicians,
More informationBAPTIST HEALTH CORPORATE COMPLIANCE PLAN
BAPTIST HEALTH CORPORATE COMPLIANCE PLAN BAPTIST HEALTH and its subsidiaries have a long-standing reputation for conducting both business and patient care activities with the highest level of ethical behavior
More informationPOLICY AND PROCEDURES MANUAL FRAUD, WASTE, AND ABUSE
Page Number: 1 of 7 TITLE: PURPOSE: FRAUD, WASTE, AND ABUSE The Harris County Hospital District implemented a Corporate Compliance Program in an effort to establish effective internal controls that promote
More informationI. Introduction. 1919 Madison Avenue, New York, NY 10035 tel: 212-987-1777 toll free: 866-778-6827 fax: 212-987-1776
I. Introduction The Ralph Lauren Center for Cancer Care ( RLCCC or The Center ) operates a freestanding diagnostic and treatment center, licensed under Article 28 of the New York State health law, located
More informationIntegrity. Providence Integrity and Compliance Program Description
Integrity and Compliance Description Approved by the Audit Committee of the Providence Health & Services Board of Directors December 9, 2014 Contents: Introduction Page 1 Purpose Page 2 Compliance Administration
More informationCompliance and Program Integrity Melanie Bicigo, CHC, CEBS mlbicigo@uphp.com 906-225-7749
Compliance and Program Integrity Melanie Bicigo, CHC, CEBS mlbicigo@uphp.com 906-225-7749 Define compliance and compliance program requirements Communicate Upper Peninsula Health Plan (UPHP) compliance
More informationPuerto Rican Family Institute, Inc.
Puerto Rican Family Institute, Inc. Stronghold for Families, a Pathfinder for Children Corporate Compliance Program Plan - 2014 Updated by: Approved by: Yolanda Alicea Winn, LCSWR Vice President/Corporate
More informationFIRST TIER, DOWNSTREAM AND RELATED ENTITIES (FDR) ANNUAL TRAINING
FIRST TIER, DOWNSTREAM AND RELATED ENTITIES (FDR) ANNUAL TRAINING The Compliance Team appreciates your attention and cooperation during this CMS mandated annual training! DEFINITIONS ADVANTAGE utilizes
More informationCompliance Program and HIPAA Training For First Tier, Downstream and Related Entities
Compliance Program and HIPAA Training For First Tier, Downstream and Related Entities 09/2011 Training Goals In this training you will gain an understanding of: Our Compliance Program elements Pertinent
More informationGENERAL COMPLIANCE TRAINING CIA YEAR ONE REVIEW AND CERTIFICATION
GENERAL COMPLIANCE TRAINING CIA YEAR ONE REVIEW AND CERTIFICATION INTRODUCTION Supporting the mission and vision of Broward Health requires commitment to compliance, integrity and dedication to the highest
More informationVCU HEALTH SYSTEM Compliance Program. Updated August 2015
VCU HEALTH SYSTEM Compliance Program Updated August 2015 Table of Contents Section I. Purpose of the Compliance Program... 3 Section II. Elements of an Effective Compliance Program... 3 A. Written Policies
More informationCoordinated Health Mutual, Inc. d/b/a InHealth Mutual. Compliance Plan. Since November 2013 As last modified on 4/28/2015. We were built for you.
Coordinated Health Mutual, Inc. d/b/a InHealth Mutual Compliance Plan Since November 2013 As last modified on 4/28/2015 We were built for you. Table of Contents Letter from Jesse Thomas, CEO... 1 Introduction...
More informationTEMPLE UNIVERSITY HEALTH SYSTEM CORPORATE COMPLIANCE PROGRAM TABLE OF CONTENTS PAGE A LETTER FROM THE CHAIR OF THE BOARD...2
TEMPLE UNIVERSITY HEALTH SYSTEM CORPORATE COMPLIANCE PROGRAM TABLE OF CONTENTS PAGE A LETTER FROM THE CHAIR OF THE BOARD...2 TEMPLE UNIVERSITY HEALTH SYSTEM, INC.: MISSION VISION AND VALUES...3 A. THE
More informationMedicare (Pioneer) Accountable Care Organization. Annual Compliance Training
Medicare (Pioneer) Accountable Care Organization Annual Compliance Training Overview While health care professionals have long been concerned about patient safety, increased public awareness and transparency
More informationFRAUD, WASTE & ABUSE. Training for First Tier, Downstream and Related Entities. Slide 1 of 24
FRAUD, WASTE & ABUSE Training for First Tier, Downstream and Related Entities Slide 1 of 24 Purpose of this Program On December 5, 2007, the Centers for Medicare and Medicaid Services ( CMS ) published
More informationFalse Claims Act CMP212
False Claims Act CMP212 Colorado Access is committed to a culture of compliance in which its employees, providers, contractors, and consultants are educated and knowledgeable about their role in reporting
More informationOSF Healthcare System Pioneer Accountable Care Organization (ACO) Compliance Plan
OSF Healthcare System Pioneer Accountable Care Organization (ACO) Compliance Plan Approved: July 2012 TABLE OF CONTENTS Page Definitions...5 Introduction...8 Benefits of a Compliance Program... 10 Elements
More informationOSF HealthCare. Compliance Plan
OSF HealthCare Compliance Plan Approved: June 1999 Revised: January 2000 Revised: February 2001 Revised: February 2005 Revised: July 2012 Revision Approved: September 2012 TABLE OF CONTENTS Page Introduction...
More informationSUBJECT: FRAUD AND ABUSE POLICY: CP 6018
SUBJECT: FRAUD AND ABUSE POLICY: Department of Origin: Compliance & Audit Responsible Position: Vice President of Compliance and Audit Date(s) of Review and Revision: 07/10; 04/11; 11/11; 02/12; 6/12;
More informationMolina Medicare Compliance Program. Revised 3/28/16 by Medicare Compliance
Molina Medicare Compliance Program Revised 3/28/16 by Medicare Compliance 1 Letter from the Chief Executive Officer Dear Molina Healthcare Associates, Molina Healthcare is strongly committed to ethical
More informationTo: All Vendors, Agents and Contractors of Hutchinson Regional Medical Center
To: All Vendors, Agents and Contractors of Hutchinson Regional Medical Center From: Corporate Compliance Department Re: Deficit Reduction Act of 2005 Dear Vendor/Agent/Contractor: Under the Deficit Reduction
More informationMissouri Medicare Select. Standards of Conduct
Missouri Medicare Select Standards of Conduct 1 Contents INTRODUCTION... 3 BUSINESS ETHICS AND CONDUCT... 3 CONFLICTS OF INTEREST... 4 EMPLOYEE PROCEDURES AND CONDUCT... 4 HIPPA Privacy and Security Plan...
More informationPOUGHKEEPSIE CITY SCHOOL DISTRICT PUPIL PERSONNEL DEPARTMENT S MEDICAID BILLING COMPLIANCE PROGRAM AND PROCEDURES
POUGHKEEPSIE CITY SCHOOL DISTRICT PUPIL PERSONNEL DEPARTMENT S MEDICAID BILLING COMPLIANCE PROGRAM AND PROCEDURES INTRODUCTION This Poughkeepsie City School District Medicaid Billing Compliance Program
More informationThe Brody School of Medicine Policy and Procedure Manual
I. Purpose The purpose of this policy is to inform all employees, contractors, and agents of the Brody School of Medicine ( BSOM ) about (i) the federal False Claims Act; (ii) North Carolina Medical Assistance
More informationBayer HealthCare s Comprehensive Compliance Program Pursuant to California Health and Safety Code 119400-119402
Bayer HealthCare s Comprehensive Compliance Program Pursuant to California Health and Safety Code 119400-119402 I. INTRODUCTION Bayer HealthCare LLC [including Bayer HealthCare LLC Dermatology Division
More informationSUBJECT: BUSINESS ETHICS AND REGULATORY COMPLIANCE PROGRAM & PLAN (BERCPP)
Effective Date: 6/17/2008; 1/3/2007; 6/2/2004, BOD #04-028 Revised Date: 9/5/2012 Review Date: 9/13/2012 North Sound Mental Health Administration Section 2000-Compliance: Business Ethics and Regulatory
More informationCompliance Plan. Table of Contents
Compliance Plan Compliance Plan Table of Contents Introduction... 3 Administrative Structure... 4 A. CorporateCompliance Officer... 4 B. Compliance Committee... 5 C. Hospital Compliance Officer..6 Communications...
More informationFraud, Waste and Abuse Training
Fraud, Waste and Abuse Training 1 Why Do I Need Training? Every year millions of dollars are improperly spent because of fraud, waste and abuse. It affects everyone, Including YOU. This training will help
More informationCorporate Compliance and Ethics Program Effective as adopted on February 21, 2012
Corporate Compliance and Ethics Program Effective as adopted on February 21, 2012 Page 1 of 7 SECTION 1. STATEMENT OF INTENT As a specialty pharmaceutical company and diagnostic laboratory, Prometheus
More informationMEDICARE PARTS C&D GENERAL COMPLIANCE AND FRAUD, WASTE AND ABUSE TRAINING
MEDICARE PARTS C&D GENERAL COMPLIANCE AND FRAUD, WASTE AND ABUSE TRAINING WHY THIS TRAINING? The Centers for Medicare and Medicaid Services (CMS) requires Medicare Part C and Part D Sponsors (such as Highmark)
More informationPATIENT SAFETY & RIS K SOLUTIONS GUIDELINE. Developing an Effective Compliance Plan: A Guide for Healthcare Practices
PATIENT SAFETY & RIS K SOLUTIONS GUIDELINE Developing an Effective Compliance Plan: A Guide for Healthcare Practices This document should not be construed as medical or legal advice. Because the facts
More informationSample Healthcare Compliance Program
P.O. Box 153 Shell, WY 82441 307-765-2241 (direct) 888-286-2095 (e-fax) info@hcma-consulting.com www.hcma-consulting.com Sample Healthcare Compliance Program 1. Introduction COMPANY is committed to establishing
More informationFrequently Asked Questions (FAQs) Medicare First Tier, Downstream, and Related Entity (FDR) Compliance Program Requirements
TABLE OF CONTENTS I. FDR General Compliance & Fraud, Waste, and Abuse Training and Standards/Code of Conduct 1. Why am I receiving notice to complete training for Aetna? 2. Why is this training necessary?
More informationDeveloped by the Centers for Medicare & Medicaid Services
Developed by the Centers for Medicare & Medicaid Services Every year millions of dollars are improperly spent because of fraud, waste, and abuse. It affects everyone. Including YOU. This training will
More informationMedicare Compliance and Fraud, Waste and Abuse Detection and Prevention Program 2015
Medicare Compliance and Fraud, Waste and Abuse Detection and Prevention Program 2015 Date Approved by Quality & Compliance Committee of the Governing Body: April 22, 2015 Effective Date: January, 2007
More informationFraud, Waste and Abuse Prevention and Education Policy
Corporate Compliance Fraud, Waste and Abuse Prevention and Education Policy The Compliance Program at the Cortland Regional Medical Center (CRMC) demonstrates our commitment to uphold all federal and state
More informationDeficit Reduction Act Information for Employees, Contractors and Agents
Nationally Ranked. Locally Trusted. Denver Health Deficit Reduction Act Information for Employees, Contractors and Agents EFFECTIVE DATE: DECEMBER 31, 2006 PAGE 1 OF 5 Purpose: Provide a written policy
More informationU.S. CORPORATE ETHICS AND COMPLIANCE POLICY
U.S. CORPORATE ETHICS AND COMPLIANCE POLICY Table of Contents Page 1. Letter from the President & CEO 3 2. Introduction 4 3. How to Handle and Report Ethical and/or Compliance Issues 5 3.1 Violations of
More informationCAYUGA COUNTY HEALTH DEPARTMENT CORPORATE COMPLIANCE PLAN
CAYUGA COUNTY HEALTH DEPARTMENT CORPORATE COMPLIANCE PLAN CAYUGA COUNTY HEALTH DEPARTMENT CORPORATE COMPLIANCE PLAN TABLE OF CONTENTS Page I. Introduction...1 A. Overview...1 B. The Program s Elements...2
More informationFraud, Waste and Abuse Page 1 of 9
Page 1 of 9 Overview It is the policy of MVP Health Care, Inc. and its affiliates (collectively referred to as MVP ) to comply with all applicable federal and state laws regarding fraud, waste and abuse.
More informationFraud, Waste and Abuse: Compliance Program. Section 4: National Provider Network Handbook
Fraud, Waste and Abuse: Compliance Program Section 4: National Provider Network Handbook December 2015 2 Our Philosophy Magellan takes provider fraud, waste and abuse We engage in considerable efforts
More information1. Compliance with Laws, Rules and Regulations
CODE OF BUSINESS CONDUCT - EXAMPLE INTRODUCTION This Code of Business Conduct covers a wide range of business practices and procedures. It does not cover every issue that may arise, but it sets out basic
More informationCompliance and Ethics Program
Compliance and Ethics Program Compliance and Ethics Program Introduction Inova, including its corporate subsidiaries, is committed to promoting an organizational culture that encourages ethical conduct
More informationINDIANA UNIVERSITY SCHOOL OF OPTOMETRY HIPAA COMPLIANCE PLAN TABLE OF CONTENTS. I. Introduction 2. II. Definitions 3
INDIANA UNIVERSITY SCHOOL OF OPTOMETRY HIPAA COMPLIANCE PLAN TABLE OF CONTENTS I. Introduction 2 II. Definitions 3 III. Program Oversight and Responsibilities 4 A. Structure B. Compliance Committee C.
More informationMedicare Compliance Program Effectiveness Training - Table of Contents Overview
Medicare Compliance Program Effectiveness Training Care1st Compliance Department Calendar Year 2012 1 Table of Contents Overview Compliance Program Requirements Why are the Compliance Program Requirements
More informationTITLE: Scripps Compliance Program
PAGE 1 of 7 TITLE: Scripps Compliance Program IDENTIFIER: S-FW-LD-1003 APPROVED: Executive Cabinet 08/14/12 ORIGINAL FORMULATION: 11/00 REVISED: 02/06, 11/06, 10/09, 08/12 REVIEWED: EFFECTIVE: Acute Care:
More informationAveta, Inc. Corporate Compliance Program 2009
Aveta, Inc. Corporate Compliance Program 2009 1 P age Aveta, Inc. Code of Business Conduct (Updated 6/2/2009) Corporate Compliance Program Preface Aveta, Inc. established a Corporate Compliance Program
More information* SAMPLE * COMPLIANCE PROGRAM GROUP PRACTICE
[NOTE: This is a sample compliance plan based on OIG Compliance Program Guidance. Groups should modify it as appropriate to fit their circumstances] * SAMPLE * COMPLIANCE PROGRAM GROUP PRACTICE (Revised
More informationUMDNJ COMPLIANCE PLAN
UMDNJ COMPLIANCE PLAN INTRODUCTION...2 COMPLIANCE OVERSIGHT 3 COMPLIANCE COMMITTEE STRUCTURE...4 CHIEF COMPLIANCE OFFICER S RESPONSIBILITIES...5 RESEARCH COMPLIANCE.5 UNIT IMPLEMENTATION.6 COMPLIANCE POLICIES
More information