COMPLIANCE CONCEPTS Developed by University of Washington School of Dentistry Staff and Faculty 2016

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "COMPLIANCE CONCEPTS Developed by University of Washington School of Dentistry Staff and Faculty 2016"

Transcription

1 COMPLIANCE CONCEPTS Developed by University of Washington School of Dentistry Staff and Faculty 2016

2 Introduction to Compliance Concepts Welcome to University of Washington School of Dentistry web-based general compliance training. This training module is required for all workforce members at the time of hire, appointment or matriculation. You may also be taking this module to meet your annual compliance training requirement.

3 Training Objectives After completing this module, you will be able to: 1. Understand why School of Dentistry has a Compliance Program 2. Identify basic principles and key elements of the School s Compliance Program 3. Determine when and how to report potential compliance concerns 4. Identify some of the regulations School of Dentistry must follow 5. Know your personal compliance role and responsibilities

4 Importance of Compliance The School of Dentistry is an international leader in education, research and clinical services. In this role of leadership and as a public agency, we must be accountable to the public we serve. A strong Compliance Program is essential to ensure our decisions meet legal and ethical requirements and that we protect our patients and their confidential information.

5 Compliance Functions The School s Compliance Program supports the School by seeking to prevent, detect and resolve events and situations that may violate compliance standards. The School is dedicated to providing care to Medicare and Medicaid patients and to following applicable federal and state rules and regulations. Compliance provides assistance in understanding and following rules for documentation, coding, billing, HIPAA and special laws applicable to state employees. Compliance responds to reported concerns by investigating and recommending corrective actions.

6 Compliance Program Benefits Benefits of a compliance program may include: Fulfill legal duty to ensure false and inaccurate claims are not submitted to government or private payers Clearly demonstrate to workforce and the community a commitment to honest and responsible conduct Identify and prevent criminal and unethical conduct Reduced number of appeals and improved appeal success rate Improved quality of patient care Centralized source for distributing information on regulations related to fraud and abuse System that encourages workforce to report potential problems Identify weaknesses in internal systems and management

7 Government Expectations of Compliance The federal government believes that an effective compliance program should address risk areas such as: Billing for services not rendered Providing medically/dentally unnecessary services Teaching physician and resident requirements Up-coding Duplicate billing Failure to refund patient credit balances Failure to return insurance overpayments within 60 days

8 Government Recommendations The federal government recommends seven specific elements for effective compliance programs 1. Written policies and procedures 2. Compliance Officer and Compliance Committee 3. Conducting effective training and education 4. Developing effective lines of communication 5. Auditing and monitoring 6. Enforcement 7. Response and corrective action

9 The School s Compliance Program The School of Dentistry s Compliance Program establishes general principles that guide the School in its compliance efforts. In addition, detailed policies, procedures and guidelines are in place to guide workforce in preventing non-compliant behavior. The School of Dentistry s website has a section dedicated to compliance at: All workforce members also receive the School s Integrity at Work handbook which is available on the website at:

10 Compliance Program Basic Principles The School s Compliance Program Basic Principles are: Integrity Demonstrate the highest levels of professional conduct in all actions/decisions Compliance with Legal Standards Follow all applicable federal and state laws and regulations Accurate Billing and Records Maintain accurate documentation and billing records that reflect services provided. Address and correct errors appropriately.

11 Following Basic Principles Each individual associated with the School is responsible for carrying out the Compliance Program Basic Principles by: Performing personal duties with integrity Learning, understanding and following legal standards that pertain to his/her role Creating and maintaining accurate documentation and billing records that reflect services provided Addressing and correcting documentation and billing errors appropriately Asking questions and reporting any questionable activities or situations

12 Participation & Responsible Officer The School s Compliance Program is structured on ten elements. The 1 st and 2 nd elements are: 1. Participation It is the responsibility of each faculty member, staff, student and independent contractor to follow applicable laws and regulations and support the School s compliance efforts. 2. Responsible Officer The School has designated the Compliance Director as the individual within the School responsible for overall implementation and operation of the Compliance Program.

13 Compliance Committee & Oversight The School s Compliance Program is structured on ten elements. The 3 rd and 4 th elements are: 3. Compliance Committee The School s Compliance and Training Committee advises and assists the Compliance Director with implementation of the Compliance Program. 4. Oversight The Compliance Director reports at least twice a year to the Compliance and Training Committee on the status of compliance within the School.

14 Employee/Vendor Screening & Education The School s Compliance Program is structured on ten elements. The 5 th and 6 th elements are: 5. Employee and Vendor Screening The School shall not contract with, employ or extend privileges to any individual or entity that is excluded from participation or is otherwise ineligible to participate in federal health care programs. 6. Education The School provides ongoing, effective education and training programs for all faculty, staff and students on Organizational Professionalism and the Compliance Program.

15 Auditing/Monitoring & Risk Assessment The School s Compliance Program is structured on ten elements. The 7 th and 8 th elements are: 7. Auditing and Monitoring The School establishes procedures for monitoring the effectiveness of the Compliance Program. 8. Risk Assessment The School conducts ongoing risk assessments and takes appropriate steps to reduce the risk of law violation identified through the assessment process.

16 Enforcement/Prevention & Response The School s Compliance Program is structured on ten elements. The 9 th and 10 th elements are: 9. Enforcement and Prevention Individuals violating the standards of this Compliance Program will be subject to progressive discipline, up to and including termination. Sanctions will be applied in accordance with relevant staff personnel policies, School policies/procedures and/or faculty code as appropriate. 10. Organizational Response The School responds to potential violations of the Compliance Program and/or applicable federal and state laws/regulations reported by staff, students, faculty members or others that have questions or concerns regarding School activity.

17 Compliance Program Policies The 10 policies included in the School s Compliance Program ensure we follow federal and state regulations and adhere to the principles and elements described in the previous slides. The School s Compliance Program document can be found at: ce-program/

18 Compliance Policies The School has many other detailed policies in addition to the 10 general policies included in the Compliance Program document. All compliance policies, procedures and guidelines, including HIPAA policies, can be found on the website at:

19 Compliance Director The Compliance Director is responsible for the development, implementation and management of the School s Compliance Program. The Dean of Dentistry and Executive Leadership ensure the Compliance Director is provided with the appropriate resources to effectively manage and meet the elements of the Program.

20 Compliance and Training Committee Members The School s Compliance and Training Committee is made up of the following members: Committee Chair Compliance Director Executive Director and Privacy Official, Health Sciences Administration Associate Dean, Finance and Resources (ex-officio) Associate Dean, Clinical Affairs (ex-officio) Associate Dean, Information Management and Quality Improvement (ex-officio) Assistant Attorney General (advisor/ex-officio) Assistant Dean, Clinical Services (ex-officio) Information Technology Director Department Educational and Information Technology Director Faculty representative for ethics and professionalism knowledge Faculty representative for research expertise Faculty representative for clinical expertise Pre-doctoral student Graduate student/resident

21 Compliance and Training Committee Role The Compliance and Training Committee meets monthly. Some of the Committee s responsibilities are: Advise and assist the Compliance Director with implementation of the Compliance Program Serve as compliance leaders for staff, faculty and students by supporting compliance efforts Reinforce compliance laws, regulations and School policies Recommend School risk posture to the Dean Review concerns brought forward by the Compliance Director Provide feedback on proposed policies and requirements Monitor overall status of School compliance

22 Federal False Claims Act (FCA) The Federal False Claims Act The False Claims Act is the single most important tool U.S. taxpayers have to recover billions of dollars stolen through fraud every year. Those who knowingly submit false claims are liable for civil penalties of $5,500 to $11,000 per false claim plus three times the government s damages. Citizens with evidence of fraud (whistleblowers) can sue on behalf of the government and may be awarded a portion of funds recovered (typically 15 25%).

23 False Claims Act & WA State Law The Federal False Claims Act continued Those involved in a False Claims Act violation are often required to enter into a Corporate Integrity Agreement with the government and may face exclusion from federal health care programs like Medicare and Medicaid. Washington State has a law that is very similar to the Federal False Claims Act (RCW 74.09) that works to discourage frauds committed against the state government.

24 False Claim Examples Examples of frauds prosecuted under the False Claims Act: Billing for services not provided Performing inappropriate or unnecessary medical/dental procedures Overpayments not returned within 60 days Double billing Billing in order to increase revenue instead of billing to reflect work performed Recommending a type of treatment or prescribing a medication in order to win kickbacks from labs, pharmaceutical companies or other vendors Billing for services, such as Radiology, without a documented order

25 Anti-Kickback Statute The Anti-Kickback Statute Prohibits any person or entity from offering, providing, requesting, or accepting anything of value with an intent to induce or influence a referral, lease, order or purchase of items or services reimbursable by a federal health care program. Violation of the Statute constitutes a felony and can result in fines, civil money penalties, and imprisonment. Violation can also result in exclusion from federal health care programs such as Medicare and Medicaid.

26 Stark Statute Stark Law - Physician Self-Referral Prohibition The Stark statute is intended to prohibit or limit financial interests that may conflict with the physician s clinical judgment. The Stark statute applies only to physicians who refer Medicare and Medicaid patients for designated health services (E.g., lab, radiology, prosthetics) to entities with which they (or an immediate family member) have a financial relationship. There are nearly 20 exceptions to this statute.

27 HIPAA Privacy & Security Federal Privacy and Security rules help protect the privacy of patient s health information. The School is required to have policies in place to ensure we follow these rules. School of Dentistry adopted UW Medicine HIPAA policies in 2007 and these policies can be accessed at:

28 State Ethics Laws All state employees, including temporary employees and those with minimal pay, are bound by the State Ethics in Public Service Act, RCW This Act, commonly known as the ethics law, addresses conflicts of interest, improper use of state resources, compensation for outside activities, and gifts. The University of Washington has some of its own additional State Ethics policies that address unique University concerns such as faculty consulting. State Ethics information can be found on the Attorney General s Office website at:

29 Communicating Potential Problems Communication is essential to maintain an effective compliance program. All School faculty, staff and students are individually responsible for asking questions and seeking clarification when they encounter potential violations. Faculty, staff and students are encouraged to share compliance-related concerns as soon as possible so appropriate action can be taken.

30 How to Report Potential Problems Compliance-related concerns can be reported through any of the following channels: Your direct supervisor Anyone in a School leadership role The Compliance Director at or The School s Anonymous Compliance Hotline at Answered by a pre-recorded message and no attempt is made to identify caller number or location

31 Workforce Compliance Responsibilities All faculty, staff and students are personally responsible for: Understanding and adhering to relevant policies and procedures Participating in required training Reporting compliance concerns Seeking answers to questions Responding timely to compliance requests (audits, investigations, etc.)

32 Additional Responsibilities for Leadership Workforce members in leadership positions have compliance responsibilities beyond the general workforce. In addition to general workforce responsibilities discussed previously, School leaders/supervisors are responsible for: Communicating compliance expectations Ensuring that appropriate compliance training is taken Implementing and enforcing compliance policies Monitoring compliance

33 Summary of Training Objective #1 Understand why the School has a Compliance Program The School s Compliance Program is necessary to ensure rules and regulations are followed, to prevent, identify and respond to potential violations, and to provide education and assistance in meeting our compliance and ethical standards.

34 Summary of Training Objective #2 Identify the 3 basic principles of the School s Compliance Program 1. Integrity 2. Compliance with legal standards 3. Accurate billing and records Identify the 10 key elements of the School s Compliance Program 1. Participation 2. Responsible Officer 3. Compliance Committee 4. Oversight 5. Employee & Vendor Screening 6. Education 7. Auditing & Monitoring 8. Risk Assessment 9. Enforcement & Prevention 10. Organizational Response

35 Summary of Training Objective #3 Know when and how to report potential compliance concerns Report all potential concerns as soon as possible Report potential compliance concerns to any of the following: Your supervisor Anyone in a School leadership role The School s Compliance Director The anonymous Compliance Hotline

36 Summary of Training Objective #4 Identify some of the Regulations School of Dentistry must follow The Federal False Claims Act Anti-Kickback Statute Stark Statute HIPAA Privacy and Security Laws Washington State Ethics Laws

37 Summary of Training Objective #5 Know your personal compliance responsibilities as a general workforce member Understand and adhere to relevant policies and procedures Participate in required training Report compliance concerns Seek answers to questions Respond timely to compliance requests (audits, investigations, etc.) Know your personal compliance responsibilities as a School leader Understand and adhere to relevant policies and procedures Participate in required training Report compliance concerns Seek answers to questions Respond timely to compliance requests (audits, investigations, etc.) Communicate compliance expectations Ensure that appropriate compliance training is taken Implement and enforce compliance policies Monitor compliance

38 Training Completion & Credit You have completed the Compliance Concepts online training. You are required to take a knowledge assessment in order to receive credit for this module. The link is provided on the next page. Thank you for your participation. Please send any comments and questions to:

39 Knowledge Assessment Please take the following knowledge assessment for Compliance Concepts online training. An electronic record will be sent to the School s Compliance department when you have completed the assessment. This training module and its knowledge assessment are required training material for all School of Dentistry workforce members. It is a good idea to print and save a copy of your knowledge assessment confirmation page for your records.

Fraud, Waste, and Abuse Training. Welcome to the South Florida Community Care Network Fraud, Waste, and Abuse (FWA) & Compliance Training

Fraud, Waste, and Abuse Training. Welcome to the South Florida Community Care Network Fraud, Waste, and Abuse (FWA) & Compliance Training Fraud, Waste, and Abuse Training Welcome to the South Florida Community Care Network Fraud, Waste, and Abuse (FWA) & Compliance Training Training Objectives Meet the regulatory requirement for training

More information

Fraud 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 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 information

Mental 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 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 information

COMPLIANCE AND FRAUD, WASTE AND ABUSE

COMPLIANCE AND FRAUD, WASTE AND ABUSE Neighborhood requires compliance with all laws applicable to the organization s business, including insistence on compliance with all applicable federal and state laws dealing with false claims and false

More information

Health Sciences Compliance Plan

Health Sciences Compliance Plan INDIANA UNIVERSITY Health Sciences Compliance Plan 12.18.2014 approved by University Clinical Affairs Council Table of Contents Health Sciences Compliance Plan I. INTRODUCTION... 2 II. SCOPE... 2 III.

More information

CODE 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. 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 information

North American Partners in Anesthesia. Corporate Compliance Plan

North American Partners in Anesthesia. Corporate Compliance Plan North American Partners in Anesthesia Corporate Compliance Plan VERSION EFFECTIVE: JANUARY 2015 CONTENTS Introduction and Mission 1. Corporate Commitment to Compliance: Code of Conduct 2. Written Compliance

More information

Fraud Waste and Abuse Training First Tier, Downstream and Related Entities

Fraud 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 information

Prepared by: The Office of Corporate Compliance & HIPAA Administration

Prepared 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 information

VCU HEALTH SYSTEM Compliance Program. Updated August 2015

VCU 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 information

Compliance, 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 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 information

USC Office of Compliance

USC 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 information

CODE OF CONDUCT I. POLICY

CODE 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 information

What is a Compliance Program?

What 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 information

Fraud, Waste and Abuse Prevention and Education Policy

Fraud, 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 information

Code of Conduct. 3. SCOPE: All PHI Air Medical Personnel

Code 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 information

False Claims Act CMP212

False 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 information

CORPORATE COMPLIANCE: BILLING & CODING COMPLIANCE

CORPORATE 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 information

Stark, False Claims and Anti- Kickback Laws: Easy Ways to Stay Compliant with the Big Three in Healthcare

Stark, False Claims and Anti- Kickback Laws: Easy Ways to Stay Compliant with the Big Three in Healthcare Stark, False Claims and Anti- Kickback Laws: Easy Ways to Stay Compliant with the Big Three in Healthcare In health care, we are blessed with an abundance of rules, policies, standards and laws. In Health

More information

CORPORATE COMPLIANCE POLICIES AND PROCEDURES DRA NOTICE POLICY (CPL-007) Last Revision Date: September 9, 2014

CORPORATE COMPLIANCE POLICIES AND PROCEDURES DRA NOTICE POLICY (CPL-007) Last Revision Date: September 9, 2014 CORPORATE COMPLIANCE POLICIES AND PROCEDURES DRA NOTICE POLICY (CPL-007) Last Revision Date: September 9, 2014 Original Date: March 5, 2013 OMNICARE DRA NOTICE POLICY CPL-007 (SEPTEMBER 2014) I. PURPOSE

More information

Compliance Program Code of Conduct

Compliance 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 information

Health Management Annual Compliance Training

Health 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 information

2012-2013 MEDICARE COMPLIANCE TRAINING EMPLOYEES & FDR S. 2012 Revised

2012-2013 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 information

FORWARD BY THE COMPLIANCE OFFICER

FORWARD BY THE COMPLIANCE OFFICER YOUTH ADVOCATE PROGRAMS, INC. INTEGRITY COMPLIANCE PLAN Revised: September 2013 FORWARD BY THE COMPLIANCE OFFICER Welcome to the Youth Advocate Programs, Inc., Integrity Compliance Plan (ICP). This Plan

More information

Deficit Reduction Act Information for Employees, Contractors and Agents

Deficit 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 information

13.4 PHI Air Medical Code of Conduct

13.4 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 information

Provider Fraud, Waste & Abuse Training. UPMC Health Plan Fraud, Waste & Abuse Department

Provider Fraud, Waste & Abuse Training. UPMC Health Plan Fraud, Waste & Abuse Department Provider Fraud, Waste & Abuse Training UPMC Health Plan Fraud, Waste & Abuse Department Definitions of Fraud, Waste & Abuse FRAUD: An intentional deception or misrepresentation made by a person or entity,

More information

Corporate Compliance and Ethics Program Effective as adopted on February 21, 2012

Corporate 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 information

Purpose Components Examples of Non-Compliance Applicable Laws & Regulations Responsibilities & Management

Purpose Components Examples of Non-Compliance Applicable Laws & Regulations Responsibilities & Management Purpose Components Examples of Non-Compliance Applicable Laws & Regulations Responsibilities & Management The purpose of a Compliance Program is To reduce the risk or error or fraud Designed to ensure

More information

The University of Toledo. Corporate Compliance and HIPAA Training

The University of Toledo. Corporate Compliance and HIPAA Training Disclaimer This document is not intended to be copied, reproduced, altered, or disseminated for training purposes on the departmental level. It is only intended to be used as a resource. ALL HIPAA training

More information

Fraud, Waste and Abuse (FWA) Training. TP21 - First Transit Medicaid FWA Training

Fraud, Waste and Abuse (FWA) Training. TP21 - First Transit Medicaid FWA Training Fraud, Waste and Abuse (FWA) Training 1 Why Do I Need Training? This training will help you detect, correct, and prevent fraud, waste, and abuse. Federal law requires all companies that bill federal or

More information

PHI Air Medical, L.L.C. Compliance Plan

PHI 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 information

To: All Vendors, Agents and Contractors of Hutchinson Regional Medical Center

To: 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 information

I. Policy Purpose. II. Policy Statement. III. Policy Definitions: RESPONSIBILITY:

I. Policy Purpose. II. Policy Statement. III. Policy Definitions: RESPONSIBILITY: POLICY NAME: POLICY SPONSOR: FRAUD, WASTE AND ABUSE COMPLIANCE OFFICER RESPONSIBILITY: EFFECTIVE DATE: REVIEW/ REVISED DATE: I. Policy Purpose The purpose of this policy is to outline the requirements

More information

Sharp HealthCare s 2016 Compliance Education. Fraud and Abuse: Prevention, Detection and Reporting Module 2

Sharp HealthCare s 2016 Compliance Education. Fraud and Abuse: Prevention, Detection and Reporting Module 2 Sharp HealthCare s 2016 Compliance Education Fraud and Abuse: Prevention, Detection and Reporting Module 2 Learning Objectives: In this module you will learn about the following: The importance of workplace

More information

Medicare Advantage and Part D Fraud, Waste, and Abuse Training. October 2010

Medicare Advantage and Part D Fraud, Waste, and Abuse Training. October 2010 Medicare Advantage and Part D Fraud, Waste, and Abuse Training October 2010 Introduction 2008: United States spent $2.3 trillion on health care. Federal fiscal year 2010: Medicare expected to cover an

More information

Touchstone Health Training Guide: Fraud, Waste and Abuse Prevention

Touchstone Health Training Guide: Fraud, Waste and Abuse Prevention Touchstone Health Training Guide: Fraud, Waste and Abuse Prevention About the Training Guide Touchstone is providing this Fraud, Waste and Abuse Prevention Training Guide as a resource for meeting Centers

More information

Corporate Compliance Program

Corporate Compliance Program Corporate Compliance Program CORPORATE COMPLIANCE OFFICER FOR THE THRO COMPANY AND IMPORTANT PHONE NUMBERS Corporate Compliance Officer... Vice President of Operations Address... 638 South Bend Avenue

More information

Fraud, Waste & Abuse. UPMC Health Plan Quality Audit, Fraud, Waste & Abuse Department

Fraud, Waste & Abuse. UPMC Health Plan Quality Audit, Fraud, Waste & Abuse Department Fraud, Waste & Abuse UPMC Health Plan Quality Audit, Fraud, Waste & Abuse Department Definitions of Fraud, Waste & Abuse FRAUD: An intentional deception or misrepresentation made by a person or entity,

More information

Policies and Procedures SECTION:

Policies and Procedures SECTION: PAGE 1 OF 5 I. PURPOSE The purpose of this Policy is to fulfill the requirements of Section 6032 of the Deficit Reduction Act of 2005 by providing to Creighton University employees and employees of contractors

More information

Medicare Advantage and Medicare Part D Fraud, Waste, and Abuse Training. Introduction

Medicare Advantage and Medicare Part D Fraud, Waste, and Abuse Training. Introduction Medicare Advantage and Medicare Part D Fraud, Waste, and Abuse Training 2009 Introduction The Centers for Medicare & Medicaid Services (CMS) requires Medicare Advantage Organizations (MAO) to have policies

More information

Federal and State Laws Relating to False Claims and False Statements

Federal and State Laws Relating to False Claims and False Statements Federal and State Laws Relating to False Claims and False Statements The federal False Claims Act, the federal Program Fraud Civil Remedies Act, New York State's False Claims Act and certain other New

More information

TM Nightingale. Home Healthcare. Fraud & Abuse: Prevention, Detection, & Reporting

TM Nightingale. Home Healthcare. Fraud & Abuse: Prevention, Detection, & Reporting Fraud & Abuse: Prevention, Detection, & Reporting What Is Fraud? Fraud is defined as making false statements or representations of facts to obtain benefit or payment for which none would otherwise exist.

More information

Frequently Used Health Care Laws

Frequently Used Health Care Laws Frequently Used Health Care Laws In the following section, a select few of the frequently used health care laws will be briefly defined. Of the frequently used health care laws, there are some laws that

More information

MODULE II: MEDICARE & MEDICAID FRAUD, WASTE, AND ABUSE TRAINING

MODULE II: MEDICARE & MEDICAID FRAUD, WASTE, AND ABUSE TRAINING MODULE II: MEDICARE & MEDICAID FRAUD, WASTE, AND ABUSE TRAINING 2 0 1 4 Introduction The Medicare and Medicaid programs are governed by statutes, regulations, and policies PacificSource must have an effective

More information

VisionQuest Code of Conduct

VisionQuest Code of Conduct VisionQuest Code of Conduct Code of Conduct The Code of Conduct guides all employees and contractors by establishing minimum mandatory standards of conduct for individual decision-making while performing

More information

Medicare Parts C & D Fraud, Waste, & Abuse Training

Medicare Parts C & D Fraud, Waste, & Abuse Training Medicare Parts C & D Fraud, Waste, & Abuse Training Requirement The Centers for Medicare and Medicaid Services (CMS) requires that Network Health must provide fraud, waste, and abuse training within 90

More information

HealthStream Regulatory Script. Corporate Compliance: A Proactive Stance. Version: [May 2006]

HealthStream Regulatory Script. Corporate Compliance: A Proactive Stance. Version: [May 2006] HealthStream Regulatory Script Corporate Compliance: A Proactive Stance Version: [May 2006] Lesson 1: Introduction Lesson 2: Importance of Compliance & Compliance Programs Lesson 3: Laws and Regulations

More information

Fraud, Waste and Abuse Training

Fraud, Waste and Abuse Training Fraud, Waste and Abuse Training Providence Health Plans 2013-2014 Why Do I Need Training? Every year, it is estimated between 3% and 10% of healthcare dollars are improperly spent because of fraud and

More information

COMPLIANCE AND OVERSIGHT MONITORING

COMPLIANCE AND OVERSIGHT MONITORING COMPLIANCE AND OVERSIGHT MONITORING The contract between HCA and Molina Healthcare defines a number of performance requirements that must be satisfied by Molina Healthcare subcontracted Providers to provide

More information

Prevention of Fraud, Waste and Abuse

Prevention of Fraud, Waste and Abuse Procedure 1910 Responsible Office: Yale Medical Group Effective Date: 01/01/2007 Responsible Department: Administration Last Revision Date: 09/20/2013 Prevention of Fraud, Waste and Abuse Policy Statement...

More information

ADMINISTRATION POLICY MEMORANDUM

ADMINISTRATION POLICY MEMORANDUM ADMINISTRATION POLICY MEMORANDUM POLICY TITLE: FRAUD AND ABUSE POLICY NUMBER: JCAHO FUNCTION AREA: POLICY APPLICABLE TO: POLICY EFFECTIVE DATE: POLICY REVIEWED: MCH-1083 Leadership All Employees January

More information

A Roadmap for New Physicians. Avoiding Medicare and Medicaid Fraud and Abuse

A Roadmap for New Physicians. Avoiding Medicare and Medicaid Fraud and Abuse A Roadmap for New Physicians Avoiding Medicare and Medicaid Fraud and Abuse Introduction This tutorial is intended to assist new physicians in understanding how to comply with Federal laws that combat

More information

Standards of. Conduct. Important Phone Number for Reporting Violations

Standards 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 information

Fraud, Waste and Abuse: Compliance Program. Section 4: National Provider Network Handbook

Fraud, 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 information

1 st Tier & Downstream Training Focus

1 st Tier & Downstream Training Focus Colorado Access Advantage (HMO) Medicare Advantage Part D Fraud, Waste and Abuse Compliance Training 2010 Introduction 2 The Centers for Medicare & Medicaid Services (CMS) requires annual fraud, waste

More information

Compliance 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 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 information

Compliance Plan. Table of Contents

Compliance 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 information

Corporate Compliance and Ethics

Corporate Compliance and Ethics Corporate Compliance and Ethics Title: Corporate Compliance and Ethics Course Code: EL-CCE-COMP-0 Course Outline Section 1: Introduction A. Course Contributors B. About This Course C. Learning Objectives

More information

Fraud, Waste and Abuse Training for Pharmacies

Fraud, Waste and Abuse Training for Pharmacies Fraud, Waste and Abuse Training for Pharmacies What You ll Learn Definitions of fraud, waste and abuse Examples of each Relevant statutes Your responsibilities Fraud, Waste and Abuse Accounts for billions

More information

Detecting and Preventing Fraud, Waste and Abuse

Detecting and Preventing Fraud, Waste and Abuse Detecting and Preventing Fraud, Waste and Abuse Overview It is the policy of ICS to comply with all applicable federal and state laws regarding fraud, waste and abuse. ICS acknowledges its participation

More information

Fraud, Waste and Abuse Training

Fraud, Waste and Abuse Training Fraud, Waste and Abuse Training 2011 Group Health Incorporated (GHI), HIP Health Plan of New York (HIP), HIP Insurance Company of New York and EmblemHealth Services Company, LLC are EmblemHealth companies.

More information

DIVISION OF CHILD & FAMILY SERVICES Children s Mental Health Services

DIVISION OF CHILD & FAMILY SERVICES Children s Mental Health Services DIVISION OF CHILD & FAMILY SERVICES Children s Mental Health Services SUBJECT: False Claims Act POLICY NUMBER: 11.70 NUMBER OF PAGES: 5 + Compliance Violation Report form EFFECTIVE DATE: March 16, 2009

More information

Medicare Fraud, Waste, and Abuse Training and General Compliance Training. Developed by the Centers for Medicare & Medicaid Services.

Medicare Fraud, Waste, and Abuse Training and General Compliance Training. Developed by the Centers for Medicare & Medicaid Services. Medicare Fraud, Waste, and Abuse Training and General Compliance Training Developed by the Centers for Medicare & Medicaid Services 2016 Training Important Notice This training module consists of two parts:

More information

AppleCare. 2013 General Compliance Training

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 information

The Brody School of Medicine Policy and Procedure Manual

The 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 information

ADMINISTRATIVE MANUAL Subject: CORPORATE RESPONSIBILITY 21.49. Directive #: 21.49 Present Date: January 2011

ADMINISTRATIVE MANUAL Subject: CORPORATE RESPONSIBILITY 21.49. Directive #: 21.49 Present Date: January 2011 Page: 1 of 18 Directive #: 21.49 Present Date: January 2011 Original Date: September 2004 Review Date: January 2013 Applicable To: SVHC & Affiliated Companies SVMC SCLM SLH FCPC POLICY In furtherance of

More information

FRAUD, 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 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 information

Fraud, Waste and Abuse Page 1 of 9

Fraud, 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 information

Corporate Compliance

Corporate Compliance Upstate University Hospital Institutional Compliance Program Physician Orientation 2014 1 Corporate Compliance Upstate University Hospital and the Faculty Practice Plans have active institutional (corporate)

More information

TENET HEALTHCARE CORPORATION S QUALITY, COMPLIANCE AND ETHICS PROGRAM CHARTER. Updated May 7, 2014

TENET HEALTHCARE CORPORATION S QUALITY, COMPLIANCE AND ETHICS PROGRAM CHARTER. Updated May 7, 2014 TENET HEALTHCARE CORPORATION S QUALITY, COMPLIANCE AND ETHICS PROGRAM CHARTER Updated May 7, 2014 PREAMBLE Tenet Healthcare Corporation ( THC ) hereby sets forth this Charter for its Quality, Compliance

More information

FWA Program. Program Description. Issued by: Regulatory Compliance Department

FWA 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 information

NETWORK POLICY & PROCEDURE Page 1 of 7 TITLE: NETWORK RESPONSIBILITY AND COMPLIANCE PROGRAM

NETWORK POLICY & PROCEDURE Page 1 of 7 TITLE: NETWORK RESPONSIBILITY AND COMPLIANCE PROGRAM NETWORK POLICY & PROCEDURE Page 1 of 7 APPROVED FOR: COMMUNITY HEALTH NETWORK FOUNDATION, INC. COMMUNITY HEALTH NETWORK, INC. COMMUNITY HOME HEALTH SERVICES, INC. COMMUNITY HOSPITAL SOUTH, INC. COMMUNITY

More information

This policy applies to UNTHSC employees, volunteers, contractors and agents.

This policy applies to UNTHSC employees, volunteers, contractors and agents. Policies of the University of North Texas Health Science Center 3.102 Detecting and Responding to Fraud, Waste and Abuse Chapter 3 Compliance Policy Statement UNTHSC developed and implemented a Compliance

More information

* SAMPLE * COMPLIANCE PROGRAM GROUP PRACTICE

* 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 information

Fraud, Waste and Abuse Training for Providers

Fraud, Waste and Abuse Training for Providers Fraud, Waste and Abuse Training for Providers What You ll Learn Definitions of fraud, waste and abuse Examples of each Relevant statutes Your responsibilities Fraud, Waste and Abuse Accounts for billions

More information

Medicare (Pioneer) Accountable Care Organization. Annual Compliance Training

Medicare (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 information

Fraud, Waste and Abuse Training

Fraud, 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 information

HealthStream Regulatory Script

HealthStream Regulatory Script HealthStream Regulatory Script Corporate Compliance: A Proactive Stance Release Date: June 2009 HLC Version: 602 Lesson 1: Introduction Lesson 2: Importance of Compliance & Compliance Programs Lesson 3:

More information

Compliance Training for Medicare Programs Version 1.0 2/22/2013

Compliance 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 information

Fraud/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 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 information

LMHS COMPLIANCE ORIENTATION Physicians and Midlevel Providers. Avoiding Medicare and Medicaid Fraud & Abuse

LMHS COMPLIANCE ORIENTATION Physicians and Midlevel Providers. Avoiding Medicare and Medicaid Fraud & Abuse LMHS COMPLIANCE ORIENTATION Physicians and Midlevel Providers Avoiding Medicare and Medicaid Fraud & Abuse Revised 06/03/2014 LMHS COMPLIANCE PROGRAM 6/30/2014 2 Chief Compliance Officer Catherine A. Kahle,

More information

Written: 1/09/07 Federal and State Reviewed: 3/15/12 False Claims Act Revised: 06/13/12 Page: 1 of 5

Written: 1/09/07 Federal and State Reviewed: 3/15/12 False Claims Act Revised: 06/13/12 Page: 1 of 5 Policy and Procedure Manual ADMINISTRATIVE SECTION --- III PATIENT RIGHTS & ORGANIZATIONAL ETHICS COMPLIANCE DEPARTMENT - COMPLIANCE Written: 1/09/07 Federal and State Reviewed: 3/15/12 False Claims Act

More information

FIRST TIER, DOWNSTREAM AND RELATED ENTITIES (FDR) ANNUAL TRAINING

FIRST 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 information

EXECUTIVE SUMMARY Compliance Program and False Claims Recovery

EXECUTIVE SUMMARY Compliance Program and False Claims Recovery EXECUTIVE SUMMARY Compliance Program and False Claims Recovery INTRODUCTION: The Federal Deficit Reduction Act of 2005, also known as the DRA, requires that providers give their employees, medical staff,

More information

The following presentation was based on the

The 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 information

ADMINISTRATIVE POLICY SECTION: CORPORATE COMPLIANCE Revised Date: 2/26/15 TITLE: FALSE CLAIMS ACT & WHISTLEBLOWER PROVISIONS

ADMINISTRATIVE POLICY SECTION: CORPORATE COMPLIANCE Revised Date: 2/26/15 TITLE: FALSE CLAIMS ACT & WHISTLEBLOWER PROVISIONS Corporate Compliance Plan AD-819-0 Reporting of Compliance Concerns & Non-retaliation AD-807-0 Compliance Training Policy CFC ADMINISTRATIVE POLICY AD-819-1 SECTION: CORPORATE COMPLIANCE Revised Date:

More information

Policies and Procedures: WVUPC Policy Pursuant to the Requirements of the Deficit Reduction Act of 2005

Policies and Procedures: WVUPC Policy Pursuant to the Requirements of the Deficit Reduction Act of 2005 POLICY/PROCEDURE NO.: B-17 Effective date: Jan. 1, 2007 Date(s) of review/revision: Nov. 1, 2015 Policies and Procedures: WVUPC Policy Pursuant to the Requirements of the Deficit Reduction Act of 2005

More information

Memo. Professional Accounts, LLC. Corporate Compliance Program

Memo. Professional Accounts, LLC. Corporate Compliance Program Professional Accounts, LLC Memo To: All Employees and Vendors From: Lee Frans, Executive Director Date: April 2, 2012 Re: Corporate Compliance Program Our mission as an organization has been to deliver

More information

Corporate Integrity Department. Volunteer Services Compliance Training

Corporate Integrity Department. Volunteer Services Compliance Training Corporate Integrity Department 2016 Volunteer Services Compliance Training CoxHealth is: An organization rich in traditions, history and integrity An organization whose mission is to improve health of

More information

MSO/IPA Compliance Program

MSO/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 information

MEDICAID AND MEDICARE (PARTS C&D) FRAUD, WASTE AND ABUSE TRAINING

MEDICAID 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 information

CODE OF CONDUCT. Providers, Suppliers and Contractors

CODE 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 information

Administrative Policy & Procedure. Title: Reporting False Claims. Section: Leadership

Administrative Policy & Procedure. Title: Reporting False Claims. Section: Leadership Administrative Policy & Procedure Title: Reporting False Claims Section: Leadership Policy Number: LD-1020 Origination Date: 2/2007 Effective Date: 4/6/2016 Page 1 of 6 Policy Statement Memorial Health,

More information

Approved by the Audit and Compliance Committee of the Providence Health & Services Board of Directors

Approved 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 information

CODE OF CORPORATE COMPLIANCE SUPPLEMENT January 1, 2007

CODE OF CORPORATE COMPLIANCE SUPPLEMENT January 1, 2007 CODE OF CORPORATE COMPLIANCE SUPPLEMENT Purpose As required by the Deficit Reduction Act of 2005, UC Health supplemented its Code of Corporate Compliance, effective, to provide the following detailed information

More information

Medicare Advantage and Part D Fraud, Waste and Abuse Compliance Training

Medicare Advantage and Part D Fraud, Waste and Abuse Compliance Training Medicare Advantage and Part D Fraud, Waste and Abuse Compliance Training Overview This Medicare Advantage and Part D Fraud, Waste and Abuse Compliance Training for first-tier, downstream and related entities

More information

Fraud Waste and Abuse Training Requirement. To Whom It May Concern:

Fraud Waste and Abuse Training Requirement. To Whom It May Concern: RE: Fraud Waste and Abuse Training Requirement To Whom It May Concern: This letter is to inform you about a new requirement being implemented by the CMS program (Centers for Medicare and Medicaid Services)

More information

AVOIDING FRAUD AND ABUSE

AVOIDING FRAUD AND ABUSE AVOIDING FRAUD AND ABUSE Responsibility, Protection, Prevention Presented by: www.thehealthlawfirm.com Main Office: 1101 Douglas Avenue Altamonte Springs, FL 32714 Phone: (407) 331-6620 Fax: (407) 331-3030

More information

Program Integrity (PI) for Network Providers

Program Integrity (PI) for Network Providers Program Integrity (PI) for Network Providers Purpose of Program Integrity Quality providers o Improved outcomes for consumers o Reduced oversight for provider o Confidence in network for LME-MCOs Financial

More information