Corporate Compliance Annual Update

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Corporate Compliance Annual Update Mandatory
TrainingAugust 2004
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Corporate Compliance Annual Update
Mandatory Training
August 2004
Charleston/Dorchester Mental Health Center
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DMH and Corporate Compliance

• The Department of Mental Health and the
  Charleston/Dorchester Mental Health Center goals
  for this training include Ensuring employees are
  aware of the Directive
• Providing basic information to remind staff of
  how to be compliant with Corporate Compliance
  Standards
• Identifying how a staff can report violations
• Stating the violations that have occurred and the
  actions taken as a result of the violations.

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General Overview

• Representatives of DMH, including C/DCMHC
  employees, affiliated public officials, and
  volunteers are committed to serving clients with
  dignity and respect while providing quality care
  that is delivered in a sensitive, compassionate
  and prompt manner.
• All persons representing C/DCMHC should promote
  compliance with the complex laws regulating the
  provision of health care which includes full
  compliance and preventing or detecting and
  correcting accidental and intentional
  noncompliance with all applicable legal
  responsibilities.

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Organizational Structure

• The Quality Improvement Director for C/DCMHC is
  also the Director of Corporate Compliance, who is
  located at the Administrative Offices of
  C/DCMHC.
• The operations of C/DCMHC Corporate Compliance
  are developed to be consistent with the Office of
  the Inspector Generals Corporate Compliance
  Program Guidance and the Federal Sentencing
  Guidelines for Organizations.

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An Employees Role

• Any employee made aware of a violation or
  suspecting an activity that violates the
  compliance policies, regulations, or statutes is
  required to immediately make a good faith report
  to
• their Supervisor, the Corporate Compliance
  Officer of C/DCMHC at 843-727-2000, the
  Corporate Compliance Hotline at 803-898-8327 or
  contact the Fraud Hotline at 1-800-521-4493.
• An employee who fails to report a violation is
  not being compliant with the DMH Directive.

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Examples of Violations

• Types of activities that are deemed as Corporate
  Compliance Violations include
• Falsifying the amount of service time provided,
  i.e.
• a clinician was with a client for one hour but
  completes all documentation and bills for two
  hours.
• Falsifying service delivery, i.e. a clinician
  submits documentation as providing an assessment
  but never met with the client.

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Examples of Violations

• Falsifying a signature, i.e. a clinician signs a
  clinical document that requires an additional
  signature, the other person is not available so
  the clinician signs the other persons name.
• Falsifying billing by not having the
  documentation in the medical records which
  substantiates the service billed was provided.
• See next slide for they types of violations
  reported to our Center

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Types of Violations Reported at this Center July
2003 to June 2004
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Primary Ways C/DCMHC Was Made Aware Of Potential
Violations July 2003- June 2004
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C/DCMHC Responses to Potential Corporate
Compliance Violations, July 2003-June 2004
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Review

• Any person suspecting a potential violation
  occurring is required to make a good faith report
  to
• their Supervisor, the Corporate Compliance
  Officer of C/DCMHC at 843-727-2000, the
  Corporate Compliance Hotline at 803-898-8327 or
  contact the Fraud Hotline at 1-800-521-4493.

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Training Sign In

• Now that you have completed the annual training
  and review, please click on this name Sherri
  Dangerfield , and a blank e-mail will be
  generated for you to complete. Be sure the email
  contains your full name, staff ID, and office.
• Please proceed to the last screen after you have
  entered the required information and selected
  send.

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Thank you for your time!
Should you have additional questions please
contact your supervisor.
Please click on the button that reads end
appearing below this text to end this training.
Thank You.
End