Karen Voiles, Senior Manager Compliance, QHR. Agenda. Define your organization s highest areas of risk



Similar documents
Fraud and Abuse. Current Trends and Enforcement Activities

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

ZPIC, RAC and MAC Audits Proactive vs. Reactive Approach

Mental Health Resources, Inc. Mental Health Resources, Inc. Corporate Compliance Plan Corporate Compliance Plan

SECTION 18 1 FRAUD, WASTE AND ABUSE

Introductions. Today s Topics 10/12/2015

Regulatory Compliance Tools from Strategic Management Services March 27, 2012

HealthStream Regulatory Script

MSO/IPA Compliance Program

Health Management Annual Compliance Training

Amy K. Fehn. I. Overview of Accountable Care Organizations and the Medicare Shared Savings Program

Health Sciences Compliance Plan

Puerto Rican Family Institute, Inc.

BUDGET & FISCAL AFFAIRS COMMITTEE

Data Analytics and Compliance Effectiveness

ValueOptions Program Integrity

MDaudit Compliance made easy. MDaudit software automates and streamlines the auditing process to improve productivity and reduce compliance risk.

Enterprise Risk Management. Presented by: Lori Koethe, Director of Compliance & Risk Management University Hospitals Elyria Medical Center

OSF HealthCare. Compliance Plan

Compliance in an Outsourced World

Healthcare Management Boot Camp November 3-7, 2014 in Anaheim, California

Tennessee Primary Care Association: 2014 Annual Leadership Conference

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

Prepared by: The Office of Corporate Compliance & HIPAA Administration

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

Compliance Strategies. For Physician Practices Part I

How To Get A Medical Bill Of Health From A Member Of A Health Care Provider

Coding Certificate Program Competencies

Program Integrity Fraud, Waste, and Abuse Training

Inside the Beltway: Compliance Effectiveness Tips

HPC Healthcare, Inc. Administrative/Operational Policy and Procedure Manual

AppleCare General Compliance Training

VCU HEALTH SYSTEM Compliance Program. Updated August 2015

2/21/2014. Therapy Utilization in Long Term Care: Is It Really Over Utilization

SELF AUDITS AND DISCLOSURES IN A RAC WORLD. Kathleen Houston Drummy Partner Davis Wright Tremaine LLP Los Angeles, CA

Touchstone Health Training Guide: Fraud, Waste and Abuse Prevention

2013 Healthcare Compliance Benchmark Study

MEDICARE COMPLIANCE TRAINING EMPLOYEES & FDR S Revised

Fraud and Abuse Compliance Program 101: Do You Have a Plan? Is That Plan Effective?

USC Office of Compliance

Healthcare compliance risk

6/8/2012. Cloning and Other Compliance Risks in Electronic Medical Records

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

Flex Program Member Assessment Satisfaction Member Needs Education

PINE VALLEY HEALTHCARE & REHABILITATION CENTER. Corporate Compliance Plan v5

HEALTH CARE AUDITING & MONITORING TOOLS

Clinical Compliance Plan

The University of Toledo. Corporate Compliance and HIPAA Training

MEDICAL AUDITS: TOP TEN TIPS FOR PHYSICIANS TO ANTICIPATE, RESPOND AND PROTECT THEIR PRACTICES

HFMA s 2011 Certification Program. Contents

Jane Snecinski, FACHE Post Acute Advisors, LLC P.O. Box Atlanta, GA

Recovery Audit Contractors (RACs) and Medicare. The Who, What, When, Where, How and Why?

Seven Component Framework For Compliance Auditing & Monitoring Physician Contracting In Healthcare Organizations

CODE OF RESPONSIBLE CONDUCT

YOUR HEALTHCARE COMPLIANCE PARTNER

Areas of Compliance. Compliance. What Are the Compliance Plan Objectives? Plan Relevance. The Plan Formalizes the Objectives. Compliance Plan Benefits

Medical Transportation Compliance. Mandated Compliance Guidance

EMR Pearls and Perils Presented by Bruce Rappoport, MD, CPC, CHCC

10/18/2015. David C. Marshall, Esquire Latsha Davis & McKenna, P.C. PHCA/CALM Annual Convention November 11, 2015

5/16/2014. Revenue Cycle Impact Documentation risks in an EMR AGENDA. EMR Challenges Related to Billing and Revenue Cycle

THE VALUE OF A COMPLETE CODING QUALITY AUDIT PROGRAM. By Lisa Marks, RHIT, CCS, Coding Audit Director, Precyse

General Office of Compliance and Ethics Program Training JHS Annual Mandatory Education

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

General Policy Statement and Standards on Prohibition on Self-Referrals, Kickbacks and Inducements to Refer. Refer to document abstract on Pulse

Fraud and Abuse: Part 1

Jennifer Leatherbarrow, RN, BSN, RAC-CT Carolyn Lookabill RISKY BUSINESS: A TEAM APPROACH TO CLINICAL AND BILLING COMPLIANCE

OIG Security Audits of EHR Incentive Program Participants

TULANE UNIVERSITY MEDICAL GROUP HEALTH CARE COMPLIANCE POLICY. January 18, Revised

Medicare Fraud, Waste, and Abuse Training for Healthcare Professionals

The Office of Inspector General (OIG) has turned its attention to fraud and abuse training

IT Vendor Due Diligence. Jennifer McGill CIA, CISA, CGEIT IT Audit Director Carolinas HealthCare System December 9, 2014

What Your Organization can do to Avoid the Risks. Jane Snecinski Post Acute Advisors, LLC P.O. Box Atlanta, GA

2014 ACMPE Exam Blueprint

CMS Mandated Training for Providers, First Tier, Downstream and Related Entities

Certification Pathways. Additional Business Office Certifications

THE JOHNS HOPKINS HEALTH SYSTEM CORPORATION CORPORATE COMPLIANCE PLAN

Georgia Physician Medical Record/Recovery Audit Contractors

SUBJECT: FRAUD AND ABUSE POLICY: CP 6018

THE FRAUD PREVENTION SYSTEM IDENTIFIED MILLIONS IN MEDICARE SAVINGS, BUT THE DEPARTMENT COULD STRENGTHEN SAVINGS DATA

Compliance Plan. Table of Contents

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

Presentation Overview

How To Train To Bill At Ucla

Description of a First Tier, Downstream, and Related Entity

Compliance and Program Integrity Melanie Bicigo, CHC, CEBS

Quality and Compliance Training

Chapter 16 Restricted Recipient Program

4/13/2016. Safeguarding Your Medical Identity. Learning Objectives. Dr. Peters Tale of Identity Theft. Presentation

EMR Pearls and Perils

William Rusty Huseman 3733 University Blvd. West, Suite 305-A Jacksonville, FL 32217

Compliance, Code of Conduct & Ethics Program Cantex Continuing Care Network. Contents

Fraud, Waste and Abuse Training for Pharmacies

Compliance Program Code of Conduct

Fraud, Waste and Abuse Training for Medicare and Medicaid Providers

AHLA. E. My Vendor Made Me Do It: New Compliace Risks in EHR

CORPORATE COMPLIANCE PROGRAM

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

Objectives. Fraud and Abuse defined Enforcement agencies Fraud and Abuse regulations Five-step action plan

How To Be A Successful University

MORRISTOWN MEDICAL CENTER INCORRECTLY BILLED MEDICARE INPATIENT CLAIMS WITH KWASHIORKOR

Transcription:

How to Conduct Your Own Risk Assessment and Build an Auditing and Monitoring Plan Karen Voiles, Senior Manager Compliance, QHR Agenda Define your organization s highest areas of risk Key elements of a hospital-wide risk assessment How to measure and prioritize risk Steps to monitor and audit identified risk How to use information obtained from audit and monitoring 2

Which Comes First Risk Assessment or Auditing Plan? NEW AROUND THESE PARTS, STRANGER? AND YET THE QUESTION REMAINED: WHO CAME FIRST? 3 How Do You Define R I S K? R Relative I Intuitive S Significant K Kinetic RISK Something that involves uncertain dangers RISK ASSESSMENT Identifying, measuring, and prioritizing events or risks that may have consequences on an organization s ability to achieve its objectives 4

What Are the Benefits of Risk Assessment? Strategic planning (proactive vs. reactive) Reduce financial loss Improve awareness Improve decision making Improve regulatory compliance Improve risk identification Improve processes Better resource allocation 5 What Are Some Elements to Consider? Operational changes New personnel New information systems Rapid growth New technology New products/service lines Organizational restructuring 6

What Are Some Other Types of Risks? Operational Financial Human Strategic Legal/regulatory Technology 7 What Are Some Hospital Risks to Consider? Billing for services not rendered, duplicate charges, unbundling, billing discharges rather than transfers (RACs) Medical necessity (RACs) Upcoding (RACs) Credit balances Stark and anti-kickback statute False claims HIPAA/HITECH 8

What Other Hospital Risks Should Be Considered? CMS Conditions of Participation (COPs) Conflicts of interest (especially important for 501C3) Wage and Labor Laws EMTALA 72-Hour Rule (3-day window or 1 day if not PPS; does not apply to CAH) Information technology Wireless penetration User access Vendor management Password management 9 What are Some Data Sources? Surveys Interviews OIG Workplan Hotline calls Reports of suspected non-compliance 10

Other Data Sources? Reports: RAC, MIC, and ZPIC PEPPER (www.pepperresources.org) CERT (Community Emergency Response Teams disaster preparedness) OIG OAS (Office of Audit Services) 11 What Should You Look for When Conducting a Hospital Wide Risk Assessment? Tour all hospital departments ED o EMTALA o HIPAA o Signage (NPP, Patient Rights, EMTALA) o P&Ps NPP Financial assistance o Training and education o Billing and coding compliance o Auditing and monitoring 12

What Should You Look for in Registration Areas? Identity theft HIPAA EMTALA Signage (NPP, Patient Rights, Financial Assistance) P&Ps NPP Financial assistance Education and training Auditing and monitoring 13 What Should You Look for in the MedSurg Area? HIPAA P&Ps Education and training Auditing and monitoring Drug diversion 14

What About Other Areas of the Hospital? 15 What Questions Should You Be Asking? 16

Risk Ranking Reputation Financial Legal Likelihood of risk Detectability Controls Score 1-5 (5 highest level of risk) 17 What is Auditing and Monitoring? Reliable systems and controls to review various aspects of operations A system that is practical, workable, and not overly complex auditing functions are performed across many disciplines and departments Data accuracy and consistency Procedures on how the process will work and who is responsible for getting it done Review process regularly to see if it is working/accomplishing the effectiveness standard expected by the OIG Specific, targeted, and prioritized risk areas 18

Why is Auditing and Monitoring Important? 1. Identify risk 2. Implement pe e internal controls os 3. Audit/monitor Process that assesses the quality of the internal controls, which you implement as a result of the risk assessment Risk assessment and auditing and monitoring plan should be completed and approved by your Board annually 19 19 Measuring Risk Must be able to quantify the risk Example: # physician contracts that meet criteria out of total # physician contracts reviewed Establish benchmarks CMS Professional associations o HFMA o TJC 20

Measuring Risk Specific steps for monitoring the particular risk you are auditing Timeframe # of records Record reviewers Patient specific attributes/diagnoses Criteria/checklist/worksheet Location of key components in the record o be reviewed 21 Contracts Medical records What Source of Information Will You Need for the Audit? Explanation of benefits Remittance advice Policies and procedures 22

What Processes are You Going to Use to Review the Risks You are Auditing? Staff interviews Staff observations Medical record reviews What else? 23 How Will You Gather and Report Findings and to Whom Will You Report? 24

How Often Do You Audit? How frequently will you audit the particular risk area identified? Monthly, quarterly, annually Results of audit may dictate frequency of audit or increase in the number of data point reviewed 25 Who is Responsible for What? Who will be responsible for the periodic monitoring of the given risk area? Typically not the compliance officer 26

Auditing & Monitoring Do you know how to build an annual Compliance Auditing and Monitoring Plan? USING THE INFORMATION OBTAINED FROM YOUR AUDITING & MONITORING PROGRAM 27 To Whom Do You Report the Info? Reporting Compliance committee Department level Medical staff committees as appropriate Hospital committees as appropriate 28

What are the Next Steps? Determine the need for further auditing based on error rate and benchmarks Re-file claims Issue overpayments as appropriate Involve counsel as appropriate Update policies, procedures, and training materials 29 30

Thanks for Attending! Intended for internal guidance only, and not as recommendations for specific situations. Readers should consult a qualified attorney for specific legal guidance. 31