Corporate Responsibility

1
Corporate Responsibility

• Regulatory Compliance
• Systems that ensure all students are aware of
  laws and regulations and act in accordance of
  those regulations

2
Corporate Responsibility

• Why is this important to me?

3
Compliance Goal

• Presence Health is committed to compliance with
  all federal and state laws and regulations.
• The goal of Presence Health compliance efforts is
  to ensure all business is conducted ethically,
  honestly and in accordance with all rules,
  regulations and standards

4
Office of the Inspector General

• Office of the Inspector General (OIG)
• The enforcement arm of the Department of Health
  and Human Services.
• Primary goal is to investigate suspected health
  care fraud and abuse, specifically
• Medicare
• Medicaid

5
Risk

• A large portion of the OIG regulations focus on
  Risk Assessment
• At Presence Health our highest risk areas are
• Coding
• Billing
• Documentation/Charting
• Chain of Command issues
• Quality of care- Substandard Care
• Patient/Resident Privacy (HIPAA)

6
OIG - Recommendations

• Due Diligence Recommendations
• Standards of Business Conduct education for all
  employees
• Senior Oversight of Compliance Programs
• Background checks, on all employees, vendors, and
  volunteers before hire and biannually
• Create a culture of awareness and establish
  reporting mechanisms.
• Compliance monitors and audits performed on a
  regular basis
• Standards and Compliance procedures for all
  employees

7
The Presence Health Corporate Responsibility Plan

• Presence Healths Standards of Behavior are based
  on the Presence Health Values
• Compassion
• Accountability
• Respect
• Excellence
• Service
• It is the expectation of all Presence Health
  students that they act with integrity, honesty,
  and they approach all customer interactions
  ethically and confidentially

8
The Presence Health Corporate Responsibility Plan

• Senior Oversight
• Arlene Arellano-Brown serves as Presence
  Healths Corporate Responsibility and Compliance
  Officer-773-990-7475
• The Provena St. Marys Hospital Corporate
  Responsibility Liaisons are Theresa Barnes
  815-937-3500 and Sandy Kambic 815-037-2477

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The Presence Health Corporate Responsibility Plan

• Due Diligence in Hiring
• Criminal background checks are performed on all
  new employees. We additionally check the
  Excluded Provider list to assure that our
  employees, medical staff and vendors have not
  been excluded from participating in any federally
  funded health care programs.

10
The Presence Health Corporate Responsibility Plan

• Student Awareness and Training
• All Presence Health students are required to
  participate in annual Corporate Compliance
  training. All new employees are required to
  receive Corporate Compliance in New Employee
  Orientation

11
The Presence Health Corporate Responsibility Plan

• Monitors and Audits
• At Presence Health, systems are in place to
  continuously monitor the accuracy of our coding,
  billing, and documentation. These systems are
  designed to reasonably detect errors and
  problems.
• CHAN (Catholic Health Audit Network) is Provena
  Healths internal auditor

12
The Presence Health Corporate Responsibility Plan

• Discipline
• Any violations of corporate compliance is taken
  very seriously and appropriate and consistent
  disciplinary action is take for all violations,
  regardless of title, position, or affiliation.

13
The Presence Health Corporate Responsibility Plan

• Alert Line
• 1-800-93-ALERT
• A confidential and anonymous vehicle to report
  compliance issues.
• Outsourced to Global Compliance and reporting is
  free of retaliation
• Our preference is that you initially follow the
  standard chain of command when faced with a
  compliance issue
• Supervisorgtlocal Compliance LiaisongtSystem
  Compliance Officer, then to the Alert Line

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The Presence Health Corporate Responsibility Plan

• When errors are detected, we must take reasonable
  steps to respond appropriately, determine the
  root cause, and prevent similar errors in the
  future
• Stop the process, protocol or billing if
  necessary
• Determine the cause of the error
• Develop a protocol to prevent future errors
• Communicate and implement protocol
• Continuously monitor the protocol

15
False Claim Act

• This Act provides a legal tool to counteract
  fraudulent billing turned into the Federal
  Government
• Claims under the Act are filed by persons with
  inside knowledge of the false claim
• (whistle blowing)

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False Claim Act

• False claims can occur with documentation issues
  that turn a legitimate claim into a false claim.
• Problem Areas
• No documentation
• Incomplete or incorrect documentation
• Documenting on delivery of care that you did not
  deliver personally or witness being delivered.
• Missing signatures
• Missing or backdated dates

17
False Claim Act

• High Risk Areas
• Billing
• Supplies or services not delivered
• Services not medically necessary
• Billing for a non-covered service, as if covered
• Outpatient services that should have been
  included as part of an inpatient stay

18
False Claim Act

• Risk Areas (cont.)
• Up-coding
• Misrepresenting a diagnosis to justify services
• Unbundling
• Duplicate billing

19
Your Responsibility

• Conflict of Interest
• Students who are in a position of trust that have
  competing professional or personal interests.
  Conflict of Interest arises when anyone has 2
  duties that conflict
• Students must not use their positions to profit
  personally.
• Students must not share confidential Presence
  Health information for personal gain
• Students must disclose in interest in business
  that you or a family member have if that
  business
• Buys/sells goods or services to/from Presence
  Health
• Competes with Presence Health
• Is in a position to benefit from patient
  referrals

20
Your Responsibility

• Gifts, Honoraria and Gratuities
• Students cannot accept gifts or gratuities from
  patients/residents/clients or vendors.
• Must never accept
• Money
• Loans
• Gift Certificates
• Acceptable
• Candy, Fruit, or food that can be shared

If unsure , ask your compliance officer or call
Alert-Line
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Your Responsibility

• Know all the laws and regulations that affect
  your job responsibilities
• Bring to your supervisors attention any
  suspected issues/concerns as a condition of
  employment.
• Avoid and report any suspected conflicts of
  interest
• Complete your annual education requirements

22
Your Responsibility

• It is the expectation of Presence Health that all
  students exhibit the Standards of Behavior, know
  what is right, and do what is right.
• If you see something that does not look or feel
  right, contact your supervisor or the Corporate
  Responsibility Liaison or call the Alert-Line

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Your Resources

• Presence Health Corporate Compliance and HIPAA
  Policies can be found on Dovenet
• http//dovenet.provena.org/
• Local Compliance
• Liaison
• Alert-Line