Compliance Training 2012 Compliance Training 2012 Training - PDF document

1 Compliance Training 2012 Compliance Training 2012

Training Objectives Training Objectives Training Objectives Training Objectives Understand the purpose of the Understand the purpose of the Understand the purpose of the Understand the purpose of the • Corporate Compliance Program. Corporate Compliance Program. Understand the role of the Corporate Understand the role of the Corporate • Compliance Department. Compliance Department. Understand your role in compliance. Understand your role in compliance. • 2

What is Compliance What is Compliance What is Compliance What is Compliance  Compliance can be described as conducting Compliance can be described as conducting a business and oneself in an ethical, moral, a business and oneself in an ethical, moral, and legal manner. and legal manner.  The SIH Compliance Program has an The SIH Compliance Program has an emphasis on fraud and abuse in the emphasis on fraud and abuse in the emphasis on fraud and abuse in the emphasis on fraud and abuse in the Medicare and Medicaid programs, but also Medicare and Medicaid programs, but also includes other laws and regulations includes other laws and regulations includes other laws, and regulations. includes other laws, and regulations.  It is doing the right thing and the RIGHT It is doing the right thing and the RIGHT g g g g g g thing to do! thing to do! 3

Recovery Audit Contractor Recovery Audit Contractor y (RAC) (RAC)  Hired by the federal government to identify improper Hired by the federal government to identify improper payments and recover overpayments on Medicare payments and recover overpayments on Medicare claims. States also hiring RACs to audit Medicaid. claims. States also hiring RACs to audit Medicaid. claims States also hiring RACs to audit Medicaid claims States also hiring RACs to audit Medicaid  Paid percentage of findings Paid percentage of findings  Request up to 278 medical records every 45 days for Request up to 278 medical records every 45 days for retrospective reviews and 278 every 45 days for retrospective reviews and 278 every 45 days for prepayment reviews of inpatient stays prepayment reviews of inpatient stays t t i i f i f i ti ti t t t t  Reviewing Medicare claims paid as far back as 3 Reviewing Medicare claims paid as far back as 3 g g p p years. Medicaid RACs will look back 5 years. years. Medicaid RACs will look back 5 years. 4

Government Oversight Government Oversight Congress PERM Surveys OIG CMS Medi- Courts ZPIC Attorneys General Attorneys General Medi Medi CERT Health Boards QIO Licensure RAC MIC Local Government Medicaid (Medicare) (Medicaid) DOJ RAC RAC FI MAC OMIG Carrier FDA MFCU QIO DEA VA Healthcare FBI Provider DOT IRS IRS OSHA EPA Treasury DOL SEC HRSA HRSA JCAHO & FTC FTC FCC FCC other accrediting agencies 5

Corporate Compliance Program Corporate Compliance Program Corporate Compliance Program Corporate Compliance Program I t Internally developed Internally developed I t ll d ll d l l d d program that promotes program that promotes ethical and legal business ethical and legal business ethical and legal business ethical and legal business practices. It is designed practices. It is designed to prevent, detect, correct to prevent, detect, correct p and, if necessary, report and, if necessary, report non- non -compliant activity to compliant activity to the appropriate Federal the appropriate Federal the appropriate Federal the appropriate Federal and State authorities. and State authorities. 6

Compliance Compliance Program p Program g  Helps our organization remain on the right Helps our organization remain on the right path, so we can path, so we can path so we can path so we can • live our mission and values live our mission and values • uphold our reputation in the community uphold our reputation in the community h ld h ld t ti t ti i i th th it it • care for patients care for patients  Help SIH maintain a moral and ethical Help SIH maintain a moral and ethical culture. culture culture. culture  Checks Checks - -n n- - Balance System Balance System y 7

Code of Ethics and Conduct Code of Ethics and Conduct Code of Ethics and Conduct Code of Ethics and Conduct Why have a Code of Ethics and Conduct? Why have a Code of Ethics and Conduct? – To uphold our mission values and ethics To uphold our mission values and ethics To uphold our mission, values, and ethics. The core of To uphold our mission, values, and ethics. The core of The core of The core of SIH/SIMS. SIH/SIMS. Who do they apply to? Who do they apply to? Who do they apply to? Who do they apply to? – Everyone! We should incorporate the Code of Ethics in our day Everyone! We should incorporate the Code of Ethics in our day to day operations. to day operations. What does the Code of Ethics cover? What does the Code of Ethics cover? – Things like treatment of patients, documentation, integrity and Things like treatment of patients, documentation, integrity and security of business records, patient and employee safety, security of business records, patient and employee safety, obligation to report compliance violations. obligation to report compliance violations. Where can you find the Code of Ethics? Where can you find the Code of Ethics? – The Intranet, SIH website, and the Compliance Program. The Intranet, SIH website, and the Compliance Program. 8

SIH Compliance Helpline SIH Compliance Helpline p p p p You have questions . . . we’ll get answers! ’ll t ! 1 800 965 4583 1.800.965.4583 or 618 529 2540 618.529.2540 The Helpline is available 24 hours a day, 7 days a week. The Helpline is available 24 hours a day, 7 days a week. All calls are confidential. SIH prohibits retaliation against anyone who in good f i h faith reports an actual or potential violation. l i l i l i 9

The Compliance Department O On the Web th W b For more information about the Compliance For more information about the Compliance Department check out our new Intranet webpage!! To access, click on Departments at the top of the Intranet home page. •Contact us (phone or email) •Meet our staff •Compliance Program •“Eye On” newsletters “E O ” l tt •Report compliance issues (on-line Helpline) 10 10

Compliance Committees Compliance Committees Compliance Committees Compliance Committees Corporate (includes Board members Corporate (includes Board members Corporate (includes Board members Corporate (includes Board members • & senior leaders) & senior leaders) Herrin Hospital Herrin Hospital Herrin Hospital Herrin Hospital • Memorial Hospital of Carbondale Memorial Hospital of Carbondale • St. Joseph Memorial Hospital St Joseph Memorial Hospital St Joseph Memorial Hospital St. Joseph Memorial Hospital • System Offices System Offices • SIMS SIMS SIMS SIMS • • These Committees advise and assist ese Co ttees ad se a d ass st the Compliance Officer. 11 11

Compliance Training Compliance Training Compliance Training Compliance Training  A significant element of the Corporate A significant element of the Corporate Compliance Program is education. Compliance Program is education. g  ALL  ALL ALL SIH workforce members receive ALL SIH workforce members receive SIH workforce members receive SIH workforce members receive Compliance Training. Compliance Training.  Employees receive Employees receive annual refresher training. annual refresher training. g 12 12

Compliance Department Compliance Department Compliance Department Compliance Department • Risk assessment survey Risk assessment survey Risk assessment survey Risk assessment survey • Audit and monitor Audit and monitor • Research rules • Research rules Research rules Research rules • Review outside audit activity Review outside audit activity • Educate • Educate Educate Educate • Participate on multidisciplinary teams Participate on multidisciplinary teams • Interact with government and private/ third party Interact with government and private/ third party Interact with government and private/ third party Interact with government and private/ third party auditors auditors • Help maintain strong compliance program • Help maintain strong compliance program Help maintain strong compliance program Help maintain strong compliance program 13 13