Refuah Community Health Collaborative (RCHC) PPS Compliance Partner Training 2017

Welcome! In this training presentation, you will: Be provided an overview of the DSRIP Program and RCHC Learn about RCHC’s Compliance Program and Partner Responsibility under the Compliance Program Know who to contact with DSRIP related compliance questions

RCHC’s Compliance Program Introduction What is DSRIP? Delivery System Reform Incentive Payment program = DSRIP DSRIP´s purpose is to fundamentally restructure the health care delivery system by reinvesting in the Medicaid program, with the goal of reducing avoidable hospital use by 25% over 5 years. DSRIP aims to restructure the health care delivery system through incentivizing and investing in provider collaborations, also known as performing provider systems (PPS). Each PPS is required to commit to work on at least 5, but no more than 11 projects defined under the DSRIP program; each PPS must work with its Partners to identify which Partners will work on which projects.

RCHC’s Compliance Program Introduction RCHC Background RCHC is the only federally qualified health center led PPS Refuah Health Center- lead Serves Rockland and Orange Counties Mission is to provide high quality clinically integrated health services that improve and promote the health and wellbeing of the communities we serve while effectively managing medical costs.

Refuah CHC DSRIP PROJECTS Project 2.a.i.- Create an integrated delivery system focused on evidence based medicine and population health management Project 2.a.ii - Increase Certification of Primary Care Practitioners with PCMH Certification and/or Advanced Primary Care Models Project 2.c.i - Develop a Community-Based Health Navigation Service to Assist Patients to Access Healthcare Services Efficiently Project 3.a.i - Integration of Primary Care and Behavioral Health Services Project 3.a.ii - Behavioral Health Community Crisis Stabilization Services Project 3.a.iii - Implementation of Evidence-Based Medication Adherence Program in Community-Based Sites for Behavioral Health Medication Compliance Project 4.b.i - Promote Tobacco Use Cessation, Especially Among Low SES Populations and those with Poor Mental Health

RCHC’s Compliance Program Introduction What exactly is compliance? Establishes and promotes a culture of integrity and ethical behavior Utilizes tools to prevent and/or detect violations of law or policy Encourages problems to be reported Provides a mechanism for constant monitoring Provides assistance in complying with complex governmental regulations Safeguards public and private funds; helps control fraud, waste, and abuse

RCHC’s Compliance Program Introduction As a Partner, what am I expected to do? Participate in good faith in meeting the applicable metrics of the DSRIP program Implement training and education provided by the PPS Lead Develop or maintain a compliance program where required under NYS law Observe contractual and other compliance requirements as required by the PPS Lead and state law, regulation, and policy

RCHC Compliance Program

RCHC’s Compliance Program Consists of… Compliance Plan Designation of a Chief Compliance Officer Written policies and procedures Anonymous reporting mechanism Training and education responsibilities Oversight from Executive Governing Board And more!

Role of Compliance Committee and Executive Governing Body (“EGB”) The EGB is tasked with overseeing the Compliance Program and must make reasonable efforts to ensure the Compliance Program is effective and potential risk areas are identified and addressed. The Compliance Committee meets as needed and assists the EGB in the oversight of compliance with legal and regulatory requirements of a PPS under DSRIP, including but not limited to, ensuring that RCHC takes all reasonable steps to ensure the Medicaid funds distributed as part of DSRIP are not connected with fraud, waste or abuse Compliance Committee also reviews and approve compliance policies, procedures and plans and ensures the program meetings OMIG Requirements

RCHC Compliance Plan Mission is to instill a culture of prevention, detection, and resolution of all instances of non-compliance with DSRIP Rules and Regulations as well as PPS Protocols. Ensures that PPS Providers and Personnel are familiar with DSRIP conditions of participations, applicable federal and state rules and regulations, and properly implement PPS Project Plans. Compliance Plan can be found online at: http://www.refuahchc.org/compliance/ Any questions about the Compliance Plan or policies and procedures should be directed to Azizza Graziul, Esq. at agraziul@refuahchc.org

RCHC Policies and Procedures: Where can I find them? Can be found on RCHC’s website: http://www.refuahchc.org/compliance/ Includes all PPS approved policies Check often for new policies added and/or revisions to made to existing policies

Designation of Chief Compliance Officer RCHC has designated a Chief Compliance Officer charged with the day to day operations and monitoring of the Compliance Program. RCHC’s Chief Compliance Officer is Azizza Graziul, Esq. She can be reached at 845-354-9300 x 1257 or by email at agraziul@refuahchc.org

Standards of Conduct Sets forth principles of ethical and professional behavior that RCHC Personnel, PPS Providers, and those that perform DSRIP Program-related activities are expected to follow General Standards: Standards place affirmative duty on all personnel to report actual or perceived violations Personnel are expected to be familiar with and abide by RCHC’s Compliance Program and policies and procedures. No employment, engagement, or payment to excluded entities or persons: In order to receive federal funds under DSRIP, a partner must not be an excluded entity. Monthly exclusion checks are performed. Personnel must appropriately and accurately record and report DSRIP-related information, transactions and activities, including records related to patients and their care.

Standards of Conduct Confidentiality- Patient Information: All personnel must abide by HIPAA privacy and security standards regarding protected health information Patient information must be treated with utmost confidentiality Confidentiality- Business Information: Personnel may gain access to confidential information by virtue of his/her participation in or position within their respective organization. Personnel may not communicate confidential information about its organization, partners, or any patients covered by the DSRIP program as it pertains to RCHC, including information of or about another RCHC participating entity or its patients, to anyone and may not be used as a basis for personal or family gain

Who Do I Contact with DSRIP Related Compliance Concerns? Speak with your supervisor or manager Contact RCHC’s Chief Compliance Officer, Azizza Graziul, Esq., directly at 845-354-9300 x 1257 or agraziul@refuahchc.org You may report any potential instances of non- compliance anonymously through the Compliance Hotline: By Phone: (844) 280-0009 By Email: reports@lighthouse-services.com (must mention RCHC in subject line when reporting) Hotline is open 24/7/365

Training and Education Partners are expected to disseminate all trainings and education to their organization from RCHC Partner will attest to the dissemination of all trainings to RCHC “Targeted” trainings provided to individual partners engaged in RCHC projects