Donald Sinko, CPA

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HIPAA, Documentation, and Billing Compliance, Oh
My!

• Donald Sinko, CPA
• Cleveland Clinic
• Chief Integrity Officer

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Promoting a Culture of Integrityand Ethical
Behavior

• Commitment to a Strong Corporate Compliance
  Program
• Strong senior management support
• Awarded 2009/2010 Worlds 100 Most Ethical
  Companies
• Comply with federal, state and local laws and
  regulations
• Policies and standards of conduct

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Chief Integrity Officer Reporting Lines
Audit Committee of the Board of Directors
Chief of Staff
Corporate Compliance Committee
Chief Integrity Officer
CEO
Office of Internal Audit
Office of Corporate Compliance
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Promoting a Culture of Integrityand Ethical
Behavior

• Integrity of Our Process
• Compliance program procedures to prevent, detect
  and correct non-compliance
• Compliance with contracts is audited
• Cleveland Clinic has adopted the PhRMA Code and
  the AdvaMed Code of Ethics
• Nationally recognized conflicts of interest policy

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Increased Scrutiny and Regulations

• Mandating compliance (CMS, OIG Congress)
• HIPAA privacy and security
• Electronic medical record documentation
• RAC and insurance company billing audits
• FDA research audits
• Physician contracts
• Quality and safety
• Form 990 tax compliance
• Conflicts of interest

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Patient Data Privacy and Security

• American Recovery and Reinvestment Act
• Establishing standards
• Importance of encrypting data
• Laptops, thumb drives, Blackberrys
• Increased penalties
• Properly dispose of PHI
• De-Identify patient information
• Breach reporting standards
• HIPAA security risk analysis

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Other Compliance Issues

• HIPAA
• Unauthorized access
• Unauthorized disclosures
• Patient access to mental health records
• Protecting drug and alcohol treatment records
• HIPAA 5010
• Documentation shortcuts (e.g., copy paste)
• Coding/billing practices
• Governmental improper payment initiatives
• RAC, MIC, MAC, ZPIC

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Research Compliance Issues

• Billing research charges vs. std. of care
• Compliance with IRB approved protocols
• HIPAA related to outside researchers
• Ownership of research data
• Consenting process
• Conflicts of interest

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