Training Objectives What is the Signature Partners MSSP ACO? What is Compliance? Why is Compliance important? What are my personal compliance responsibilities? When do I report compliance concerns? How do I report them? Where can I find more information?

Signature Partners Physician-led, clinically integrated provider network comprised of: Community-based physicians; Hospital physicians; and Hospitals The goals of Signature Partners are to: Improve quality of care Enhance the patient care experience Make medical care more affordable

Signature Partners: an ACO in the MSSP Accountable Care Organization (ACO) A group of doctors, hospitals, and other health care providers who come together voluntarily to give coordinated, high quality care to their Medicare patients Medicare Shared Savings Program (MSSP) A Medicare delivery system reform initiative that aims to improve beneficiary outcomes and increase value of care by providing: Better care for individuals Better health for populations Lowering growth in expenditures

7 Key Elements of an Effective Compliance Program There are 7 key elements of an effective compliance program identified by the Office of Inspector General (OIG). They, and our methods to satisfy the requirement, are: Standards and Procedures – Code of Conduct Oversight – Compliance Officer Education and Training – Annual Compliance and Ethics Training Auditing and Monitoring – Compliance Work Plan Reporting – Compliance and Ethics Hotline Enforcement and Discipline – Consistent Enforcement of Policies Response and Prevention – Ongoing Monitoring and Follow-Up

Why Is Compliance Important? It’s your legal and ethical obligation Increased oversight by Federal and state agencies has resulted in fines, required repayments, and jail time for wrongdoing An effective compliance program can lead to reduced fines or jail terms, and may help to avoid corporate integrity agreements when the organization has a compliance issue

Code of Conduct The cornerstone of Signature Partners’ compliance program is the Code of Conduct Requires high clinical, ethical, business, and legal standards Commitment to evidence-based medicine, patient engagement, cost effective and high quality care, and coordination of care All personnel must act in compliance and avoid even the appearance of impropriety Available from the Compliance Department

Relevant Laws Some of the relevant laws include: Health Information Portability and Accountability Act (HIPAA) Anti-Kickback Statute (AKS) Physician Self-Referral Law (Stark) False Claims Act (FCA) Civil Monetary Penalty (CMP)

HIPAA Includes rules about privacy and security of patient protected health information (PHI) Examples of PHI can include (but are not limited to) Name Address Birth date Identification number Social Security Number Email address Photograph Other unique identifiers It is also important to protect other personal information such as financial information and credit card numbers

HIPAA (continued) Use proper safeguards when faxing, mailing, or leaving voicemail messages including PHI Unencrypted email should not be used to transmit PHI Dispose of patient information through secure methods such as shredding

HIPAA: Acceptable Uses You may use and disclose patient information without authorization for Treatment, Payment, and Health Care Operations Treatment: provision, coordination or management of health care and related services Payment: activities to obtain payment or be reimbursed for services Health Care Operations: administrative, financial, legal, and quality improvement activities necessary to run the business and support the functions of treatment and payment

HIPAA: Minimum Use Standard Make reasonable efforts to limit the use or disclosure of PHI to the minimum necessary to accomplish the intended purpose Grant access to PHI on a need to know basis The minimum use standard does not prevent uses or disclosures for treatment, payment, or healthcare operations

Anti-Kickback Statute Prohibits referral of anything of value in return for: Referrals that may be billed to a federal health care program Purchases of goods or services that may be billed to the government Payments to contractors below fair market value If even one purpose of an arrangement is to induce inappropriate referrals, it may violate the Anti-Kickback Statute

Physician Self-Referral Law (Stark) Prohibits a physician from making referrals to a healthcare facility in which the physician, or an immediate family member, has a financial interest if those services are billable to federally funded healthcare programs There are certain exceptions to this rule A financial relationship can include an ownership or investment interest or a compensation arrangement Intent is not required to violate Stark

False Claims Act It is a violation of the FCA knowingly to present or cause to be presented, a false or fraudulent claim for payment or approval Applies to individuals and organizations Penalties can include: Repayment of three (3) times the amount wrongly paid by the government Fines and penalties of $10,781-21,563 per false claim

Civil Monetary Penalty: Beneficiary Inducements The Civil Monetary Penalties Law (CMP), among other prohibitions, prohibits offering or giving remuneration to a Medicare beneficiary likely to influence the beneficiary to select a particular provider if payment may be made by a federal healthcare program There are several exceptions to this rule Remuneration is interpreted broadly to include anything of value Fines up to $50,276 per violation

Shared Savings Program Waivers CMS and the OIG jointly published five (5) fraud and abuse waivers in connection with the Medicare Shared Savings Program These waivers allow for the flexibility needed for ACOs to achieve the triple aim of improving quality, enhancing patient care, and increasing affordability Covered arrangements will not be held to violate Stark, the False Claims Act, or the Beneficiary Inducement Civil Monetary Penalty Each waiver has conditions that must be followed in order for the arrangement to be covered If you have questions about the application of these waivers, seek legal counsel

Government Exclusions and Sanctions The government punishes individuals and organizations that have committed violations and puts their names on sanction lists, including the List of Excluded Individuals and Entities (LEIE) and System for Award Management (SAM) Someone can be excluded for: Failure to repay federally funded student loans Suspension of a clinical license Violation of billing rules Other violations

Books and Records You are responsible for ensuring accuracy and completion in record-keeping Regulatory agencies or their designees may conduct audits Keep records for at least ten (10) years

Your Responsibility It is your responsibility to follow all applicable laws, regulations, and ethical standards Seek guidance from legal counsel if you do not understand those laws and regulations Conduct yourself with honesty and integrity Report conduct that you believe violates healthcare rules and regulations Cooperate with compliance investigations Complete annual compliance training

Reporting Compliance Concerns You may report compliance concerns to Signature Partners by contacting: Signature Partners Compliance Officer (703) 286-3970 Compliance and Ethics Hotline 888-800-4030 Signature Partners prohibits retaliation for a good-faith compliance report We are here to help! If you have a question about compliance, please feel free to contact us

Compliance and Ethics Hotline 888-800-4030 The hotline is a method for confidential reports of potential compliance concerns Calls are confidential and you may remain anonymous if you wish All calls will be thoroughly investigated

Compliance Resources HHS OIG: http://oig.hhs.gov/ OCR: http://www.hhs.gov/ocr/privacy/index.html CMS: http://www.cms.gov/Regulations-and-Guidance/Regulations-and-Guidance.html DOJ: http://www.justice.gov/ Fraud and Abuse Waivers: https://www.cms.gov/Medicare/Fraud-and-Abuse/PhysicianSelfReferral/Fraud-and-Abuse-Waivers.html Your legal counsel

Thank You Thank you for completing the 2017 annual Compliance and Ethics Training Annual compliance training is a key element of an effective compliance program