Compliance and TeleHealth Julie Bell, MED Compliance Program Manager
Objectives: Introduce you to Intermountain’s Compliance Program • Identify some potential compliance risks for TeleHealth projects • Understand that there is not a one size fits all solution for • TeleHealth projects Identify resources you can use in building and deploying your own • TeleHealth initiatives
Compliance
Purpose/Goal of a Compliance Program It is the overriding responsibility of the Corporate Compliance Department to promote an organizational culture that encourages a commitment to ethical behavior as well as compliance with applicable laws and internal policies.
Compliance and Legal Risks Licensure/Scope of Practice TeleHealth and Prescribing • • Privileging and Credentialing Informed Consent • • Coding/Charging/Billing/Reimburs HIPAA/Privacy/Security • • ement Federal Fraud and Abuse: The • Documentation/The Electronic Anti-Kickback Statute • Health Record Federal Fraud and Abuse: Stark • Medical Malpractice/Liability Law • State Regulations •
Licensure • Scope of • Practice Interstate • Compacts
Privileging and Credentialing Cont. Significant administrative workload • to P&C every provider for TH The Joint Commission issued • standards allowing hospitals to “privilege by proxy”. § 482.22 CFR Condition of • Participation: Medical staff
Coding/Billing/Reimbursement
State TeleHealth Policies
Intermountain • Resources External • Resources
Resources
National Changes H.R. 2550 – Medicare Telehealth Parity Act of 2017 • H.R. 2991 – Helping Expand Access to Rural Telemedicine (HEART) • act of 2017 S. 1016 Creating Opportunities Now for Necessary and Effective • Care Technologies (CONNECT) for Health Act of 2017 S. 787 Telehealth Innovation and Improvement Act of 2017 • H.R. 1148/S. 431 Furthering Access to Stroke Telemedicine Act • (FAST)
Questions?
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