1. CORPORATE COMPLIANCE PROGRAM The Office of Corporate Integrity
Welcome….!!!
CORPORATE COMPLIANCE PROGRAM
Presented by
The Office of Corporate Integrity

2. Purpose of a Compliance Program
As defined in the Office of Inspector General (OIG) Compliance Guidance for Hospitals
“Fundamentally, compliance efforts are designed to establish a culture within a hospital that promotes prevention, detection and resolution of instances of conduct that do not conform to Federal and State law, and Federal and State and private payer health care programs, as well as the hospital’s ethical and business policies.”

3. Components of GHS Compliance Program
Structural Elements
Open Communication – Hotline
Compliance Officer
Compliance and Practice Standards
Education and Training
Internal Monitoring and Auditing
Enforcement of Rules and Standards of Conduct
Response, Remedies and Resource Planning
Risk Assessment
Substantive Elements
Laws and Regulations pertaining to Health Care operations
Fraud & Abuse Laws: STARK, Anti-Kickback, CMP (Inducements)
False Claims: Qui – Tam / Whistle-blower
Exclusionary list, HIPAA, Medical Identity Theft, OIG Guidance, COI

4. Corporate Integrity Office Structure

5. Corporate Compliance Program Structure

6. Corporate Compliance is Everyone’s Responsibility
Board : Duty of Care / Duty of Loyalty
Executive Staff: Highest Moral Character and Integrity
Leadership: Exhibit Professionalism and Right Relationships
All Employees:
Perform duties in a professional and responsible manner
Adhere to all GHS policies
Report any violation of policies or suspected unethical behavior
Read, understand and follow the Code of Excellence

7. What is a “Compliance Issue”?
A compliance issue is a concern that there is a violation of a law, rule, regulation or policy that governs our industry.
►Fraud and Abuse Issue
False Claims: Medical Necessity Reasonableness, Quality Coding
Improper Inducements
►HIPAA Violation
Privacy Breach
Security Lapse
►Violation of our Code of Excellence and/or related GHS Policies

8. GHS Policies and Initiatives
Harassment
Gifts and Gratuities
Social Media
Photography
Proper Use of Property (Information Systems)
Equal Opportunity
Drug-Free Workplace
Conflicts of Interest
Finance and Billing (Coding and Documentation)
Reporting Concerns and Non-Retaliation
Business Ethics and Conduct
Patient Safety and Quality
University Medical Group

9. Compliance Reviews Documentation of tests/procedures/charges/coding
Charge capture reconciliations
Medical necessity verification
Investigation of employee/patient complaints
Actions of independent contractors (agents)
Privacy/Confidentiality
Auditing and Monitoring (IT, Policies, Payments, Risk Areas)
Conflict of Interest
University Medical Group

10. Your Concerns are Important!
Reporting Mechanisms
Your Concerns are Important!
Contact your:
Immediate Supervisor
Department Director
Department Compliance Manager / Liaisons
Human Resources
Other Management
Compliance Office or
Hotline (you can report anonymously)

11. Office of Corporate Integrity Compliance Office
Skip Morris - Executive Director of Corporate Integrity
J. Scott Pietras - Corporate Compliance Officer
Tracy Morris – Privacy Officer
Jan Latham, Compliance Analyst / UMG Compliance Liaison
Linda Robinson, Compliance Administrative Assistant

12. Code of Excellence
Are new employees and existing employees (including physicians and contracted employees) required to read and acknowledge the Code of Excellence?
A few examples of a violation to the Code of Excellence include, however not limited to: Fraud & Abuse, Misconduct-harassment and disruptive behavior, asking for and accepting gifts, cash/checks or gift certificates from patients or their family members, business vendors, device manufacturers and pharmacy industry.
Yes-All GHS employed staff and employed contractors are required to read and sign the COE Acknowledgement form
Fraud and Abuse (false documentation in records, improper billing of a known false claim
Misconduct and unethical behavior to GHS policies and procedures-harassment and disruptive behavior
Solicitation or Accepting gifts, cash or gift certificates is a prohibited practice from both patients, patient family members, business, device manufacturers and pharma vendors
HIPAA Privacy and Security Violations (accessing patient records and/or disclosing patient information without a work related reason both inside and outside the workplace)
Yes-All GHS employed staff and employed contractors are required to report compliance concerns

13. Code of Excellence You may call anonymously
The Hotline Reporting Options:
You may call anonymously
You are protected from retaliation or retribution
All Hotline reports come to the GHS Corporate Integrity Office for
investigation and resolution of reported concerns
The GHS Corporate Integrity Office may forward the concern to the appropriate department manager, depending on the issue (e.g., Human Resources Department) OR depending on the severity of the reported issue, it may require further reporting to authorities for investigation and lawful purposes-
(Examples: Fraud and Abuse, Identify Theft)
GHS does not tolerate employees, contractors or other persons who retaliate against a person who makes a good faith report under this policy. We make every effort to handle reports confidentially.

14. Hotline Numbers 1-888-243-3611 1-800-297-8592 (en español)
Code of Excellence
Hotline Numbers
(en español)
Go to GHSNet main page under Employee Reference, Employee Hotline & HIPAA Privacy Line

15. HIPAA
Health Insurance Portability and Accountability Act of 1996 Department of Health and Human Services (HHS) established national standards for electronic health care transactions. HIPAA also established the rules for the security and privacy of health data. The Office of Civil Rights is the enforcement agency for HIPAA.

16. If it identifies a patient, it is likely considered to be PHI!
HIPAA Privacy Rule
Protected health care information (PHI) may not be disclosed without the authorization of the patient unless permitted by one the several exceptions.
Major exception is for “TPO”
TPO = treatment, payment or operations
PHI includes (but is not limited to):
Patient demographics
Clinical or health information
Images or photographs
Financial information
If it identifies a patient, it is likely considered to be PHI!

17. HIPAA Security Rule
Covered Entities must use specific administrative, technical, and physical security procedures to assure the confidentiality of electronic protected health information.
Important components include:
Encryption
Protection of electronic devices
Access rules

18. HITECH
Health Information Technology for Economic and Clinical Health Act
The American Recovery and Reinvestment Act of 2009 (Recovery Act), among other things, expanded HIPAA Privacy and Security protections.
Important components include:
Electronic access to records
New fines for violations
Breach reporting
Business Associate requirements

19. When in doubt, don’t give out contact the Compliance Office.
Applying the Rules
Reasonableness- Don’t Delay Treatment
Minimum Necessary & Need-to-Know
Audits
Duty to Protect & Report
Maintain Reasonable Safeguards
Protect Your User ID & Password – No Sharing!
Attention to Detail
Social Media
Privacy Violations = Civil Rights or Criminal Violations
Accessing Your Own Medical Records
When in doubt, don’t give out contact the Compliance Office.

20. Corporate Compliance is Everyone’s Responsibility Thank you!
Remember……
Corporate Compliance is Everyone’s Responsibility Thank you!