1. Corporate Responsibility
Online Orientation
Corporate Responsibility
Regulatory Compliance
~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, regulation and standards

2. 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

3. 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)

4. 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

5. Corporate Responsibility Plan
The Presence Health
Corporate Responsibility Plan
~ it is the expectation of all Presence Health students that they act with integrity, honesty and the approach all customer interactions ethically and confidentially
Presence Health’s Standards of Behavior are based on the Presence Health Values
Honesty
Oneness
People
Excellence

6. Corporate Responsibility Plan
The Presence Health
Corporate Responsibility Plan
South Suburban Regional Oversight
Compliance Officer
Ahmed Salim

7. Corporate Responsibility Plan
The Presence Health
Corporate Responsibility Plan
~ 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
~any violation of corporate compliance is taken very seriously and appropriate and consistent disciplinary action is taken for all violations regardless of title , position or affiliation

8. Corporate Responsibility Plan
The Presence Health
Corporate Responsibility Plan
Alert Line
ALERT
Confidential and anonymous vehicle to report compliance issues
Outsourced
Reporting is free of retaliation
Our preference is that you initially follow the standard chain of command
Supervisor
Regional compliance officer
Alert line

9. Corporate Responsibility Plan
The Presence Health
Corporate Responsibility Plan
When errors are detected, reasonable steps are taken 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 protocols
Continuously monitor the protocols

10. FALSE CLAIM ACT
~This Act provides a legal tool to counteract fraudulent billing
~Claims under this act are filed by persons with inside knowledge of the false claim…………“whistle blowing”
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
High Risk Areas
Billing
Supplies or services not delivered
Services not medically necessary
Billing for non covered service as if covered
Billing for outpatient services that should have been included as part of an inpatient stay
Up-coding
Misrepresenting a diagnosis to justify services
Unbundling
Duplicate billing

11. YOUR RESPONSIBILITY
~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 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

12. Your Responsibility (continued)
Gifts, Honoraria, and Gratuities
Students cannot accept fits or gratuities form patients, residents, clients or vendors
If unsure ask your supervisor or the regional compliance officer
Must never accept
Money
Loans
Gift certificates
Acceptable
candy
Fruit
Or food that can be shared

13. Your Responsibility (continued)
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

14. Your resources
Presence Health Corporate Compliance and HIPAA policies can be found on PresNet
Enter Corporate Compliance Or HIPAA in search bar
Select category of inquiry