4/22/2013 1 Keeping it all Straight: Compliance Resources at your Fingertips Presented by: Dawnese Kindelt, System Compliance Director Lisa Silveria, System Compliance Director 2 • Learn how to detail your program for internal and external stakeholders • Consider different methods to centralize processes and program documents • Educate your Compliance team to several alternative approaches to managing your program resources –using the Desktop Reference Tool (DTR) as an education resource and teaching tool within your facilities • Take‐away tools to document your compliance program Objectives
Transcript
4/22/2013
1
Keeping it all Straight: Compliance Resources at your Fingertips
Presented by:Dawnese Kindelt, System Compliance Director Lisa Silveria, System Compliance Director
2
• Learn how to detail your program for internal and external stakeholders
• Consider different methods to centralize processes and program documents
• Educate your Compliance team to several alternative approaches to managing your program resources –using the Desktop Reference Tool (DTR) as an education resource and teaching tool within your facilities
• Take‐away tools to document your compliance program
Objectives
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3
• 38 hospital, 100+ clinics, 12 Distinct Part Skilled Nursing, 22 Home Health/Hospice, 7 Behavioral Health Programs, 6 Inpatient Rehab. Facilities
• Joint Ventures (JVs)
• Clinics include:
– Free Standing, Medical Foundation Clinics
– For‐profit Clinics
– Provider Based Clinics
– GME Programs
– Rural Health
– Community Clinics
– Hospitalist Programs
Dignity Health Background
4
• VP Compliance & Internal Audit
• 7 System Compliance Directors
– Hospitals
– Clinics
– Coding/HIM
– Research, Privacy
– Data Security
• Hospital Resource Allocation:
– Facility Compliance Liaisons (FCL)
– Facility Privacy Officials (FPO)
– Research Accountable Executive (AE)
– IT Site Managers
Compliance Structure
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5
Ev‐o‐lu‐tion
n.
1. A gradual process in which something changes into a different and usually more complex or better form. See Synonyms at development.
2.
a. The process of developing.
b. Gradual development
Modern Evolution Theory‐ Dignity Health Compliance
6
Compliance Desk ReferenceLast Updated on: January 11, 2013
This Excel file is an easy paperless way to provide useful information at your fingertips. The reference file is designed like a website with hyperlinks for easy navigation. Listed below are the main pages (worksheet tabs) of the Desktop Reference with hyperlinks to each page. Use the "Home" link at the top of each page to return here.
For changes or corrections to this document please contact: Lisa Paige or Bill Snyder. (See Compliance Department Contacts)
Topic Updated Topic UpdatedHighlighted items have been updated within the last 30 days
Acronyms 04/26/2012 N Guidance Documents 01/07/2013 N
Additional External Resources 10/17/2012 N HIPAA Desktop Reference Monthly N
Audit Tools 03/15/2012 N Hotline / Alertline 02/10/2012 N
Calendar (Meetings and DUE DATES) 01/07/2013 Y Joint Ventures 01/09/2013 Y
Clinic Compliance Desk Reference N NCDs / LCDs 08/27/2012 Y
CMS Program Transmittals 04/10/2012 N New Service Lines / Phys Supervision 12/16/2012 Y
Compliance Department Contacts 12/02/2012 N OCEP 01/11/2013 N
Contacts by Topic 01/07/2013 Y OIG Compliance Program Guidance Documents 04/13/2012 N
Education & Presentations 05/25/2012 N Orientation Materials 04/26/2012 N
DeMinimus 12/16/2012 Y Org Chart Audit and Compliance 11/10/2012 N
EMR 01/11/2013 Y Patient Inducements 05/24/2012 N
Facility Compliance Contacts 01/07/2013 Y Physician Transaction Training 05/24/2012 N
Please review facilities list for accuracy N Policies 04/14/2012 N
FCL Meetings 12/06/2012 N President's Scorecard (Service Area Leader's Scorecard) 11/10/2012 N
Fiscal Year Work Plans 11/10/2012 N Provider Based Clinics 04/14/2012 N
Government Payer Refund Logs 01/11/2013 Y Standards of Conduct
The information contained in this workbook is intended as a resource, but the application to specific facts and circumstancescan easily impact our risk and liability; unless you are sure of the application, please contact your FCL, Compliance or Legal
for additional guidance
4/22/2013
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7
Compliance Desk ReferenceLast Updated on: January 11, 2013
This Excel file is an easy paperless way to provide useful information at your fingertips. The reference file is designed like a website with hyperlinks for easy navigation. Listed below are the main pages (worksheet tabs) of the Desktop Reference with hyperlinks to each page. Use the "Home" link at the top of each page to return here.
For changes or corrections to this document please contact: Lisa Paige or Bill Snyder. (See Compliance Department Contacts)
Topic Updated Topic UpdatedHighlighted items have been updated within the last 30 days
Acronyms 04/26/2012 N Guidance Documents 01/07/2013 N
Additional External Resources 10/17/2012 N HIPAA Desktop Reference Monthly N
Audit Tools 03/15/2012 N Hotline / Alertline 02/10/2012 N
Calendar (Meetings and DUE DATES) 01/07/2013 Y Joint Ventures 01/09/2013 Y
Clinic Compliance Desk Reference N NCDs / LCDs 08/27/2012 Y
CMS Program Transmittals 04/10/2012 N New Service Lines / Phys Supervision 12/16/2012 Y
Compliance Department Contacts 12/02/2012 N OCEP 01/11/2013 N
Contacts by Topic 01/07/2013 Y OIG Compliance Program Guidance Documents 04/13/2012 N
Education & Presentations 05/25/2012 N Orientation Materials 04/26/2012 N
DeMinimus 12/16/2012 Y Org Chart Audit and Compliance 11/10/2012 N
EMR 01/11/2013 Y Patient Inducements 05/24/2012 N
Facility Compliance Contacts 01/07/2013 Y Physician Transaction Training 05/24/2012 N
Please review facilities list for accuracy N Policies 04/14/2012 N
FCL Meetings 12/06/2012 N President's Scorecard (Service Area Leader's Scorecard) 11/10/2012 N
Fiscal Year Work Plans 11/10/2012 N Provider Based Clinics 04/14/2012 N
Government Payer Refund Logs 01/11/2013 Y Standards of Conduct
The information contained in this workbook is intended as a resource, but the application to specific facts and circumstancescan easily impact our risk and liability; unless you are sure of the application, please contact your FCL, Compliance or Legal
for additional guidance
8
Clinic Desk ReferenceLast Updated on: December 21, 2012
This Excel file is an easy paperless way to provide useful information at your fingertips. The reference file is designed like a website with hyperlinks for easy navigation. Listed below are the main pages (worksheet tabs) of the Desktop Reference with hyperlinks to each page. Use the "Home" link at the top of each page to return here.
Topic UpdatedHighlighted items have been updated in the last 30 days
Additional External Resources 04/16/2012 N Provider Education Material 02/10/2012 N
Audit Process Documentation 04/16/2012 N RAC 07/13/2012 N
DHMF Scorecard 04/16/2012 N
Calendar (Meetings and DUE DATES) 12/11/2012 N
Clinic Contacts 12/21/2012 Y
Clinic Coding Staff and EduCode Champions 12/06/2012 N
CMS Program Transmittals 08/27/2012 N
Coding Tip Sheets 12/16/2012 Y
Contact Us 12/02/2012 N
Education Database 12/16/2012 Y
Education on Demand 12/10/2012 N
EduCode 06/13/2012 N
Electronic Medical Records 12/18/2012 Y
Hotline / Alertline 02/10/2012 N
MD Audit 11/12/2012 N
OCEP 07/13/2012 N
Policies 04/17/2012 N Compliance Desk Reference
Provider Based Clinics 02/10/2012 N HIPAA Privacy and Data Security Desk Reference
The information contained in this workbook is intended as a resource. Application to specific facts and circumstances can easily impact our risk and liability; unless you are sure of the application, please
contact your Facility Compliance Liaison, Clinic Director, Dignity Health Compliance or Legal, for additional guidance
4/22/2013
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9
Clinic Desk ReferenceLast Updated on: December 21, 2012
This Excel file is an easy paperless way to provide useful information at your fingertips. The reference file is designed like a website with hyperlinks for easy navigation. Listed below are the main pages (worksheet tabs) of the Desktop Reference with hyperlinks to each page. Use the "Home" link at the top of each page to return here.
Topic UpdatedHighlighted items have been updated in the last 30 days
Additional External Resources 04/16/2012 N Provider Education Material 02/10/2012 N
Audit Process Documentation 04/16/2012 N RAC 07/13/2012 N
DHMF Scorecard 04/16/2012 N
Calendar (Meetings and DUE DATES) 12/11/2012 N
Clinic Contacts 12/21/2012 Y
Clinic Coding Staff and EduCode Champions 12/06/2012 N
CMS Program Transmittals 08/27/2012 N
Coding Tip Sheets 12/16/2012 Y
Contact Us 12/02/2012 N
Education Database 12/16/2012 Y
Education on Demand 12/10/2012 N
EduCode 06/13/2012 N
Electronic Medical Records 12/18/2012 Y
Hotline / Alertline 02/10/2012 N
MD Audit 11/12/2012 N
OCEP 07/13/2012 N
Policies 04/17/2012 N Compliance Desk Reference
Provider Based Clinics 02/10/2012 N HIPAA Privacy and Data Security Desk Reference
The information contained in this workbook is intended as a resource. Application to specific facts and circumstances can easily impact our risk and liability; unless you are sure of the application, please
contact your Facility Compliance Liaison, Clinic Director, Dignity Health Compliance or Legal, for additional guidance
10
Designate a Compliance Officer
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11
Policies
Dignity Health Compliance Policies
Compliance Policy Overview and Distribution Grid
Instructions - Finding Policies on CODI
Compliance Policies
12
Education
Compliance Education Applications and PresentationsFor Additional Educational Materials, see the Guidance section
Note: Click the plus ( + ) sign to the left of the topic you want to view.
A Toolkit for Health Care Boards (February 27, 2012)Listen to the PodcastRead the TranscriptView the VideoHandout: A Toolkit for Heath Care Boards
Compliance Program Basics (January 17, 2012)Exclusion Authorities & Effects of Exclusion (December 5, 2011)False Claims Act (December 19, 2011)Federal Anti-kickback Statute (December 12, 2011)How to Report Fraud to the OIG (February 13, 2012)How to Use the Exclusions Database (February 21, 2012)Importance of Documentation (January 30, 2012)OIG Guidance (January 9, 2012)OIG's Self Disclosure Protocol (February 6, 2012)Physician Self-Referral Law (January 3, 2012)Tips for Implementing an Effective Compliance Program (January 23, 2012)
PresentationsABN PresentationAdmission Challenges - IP, OP and what are Observation Services Assessing the Effectiveness of your Compliance Program - Specialty ServicesConducting Investigations
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Orientation Tools
Last Update: April 26, 2012Orientation Tools
Orientation Manuals
Executive Orientation Manual
FCL Orientation Manual
New Employee Orientation
Presentation
Speakers Notes
Handout
New Manager Handbook
Instructions Compliance Orientation for New Managers
Orientation Checklists
Acute Inpatient Rehab Orientation Checklist
Behavioral Health Orientation Checklist
Emergency Department Orientation Checklist
Home Health / Hospice Orientation Checklist
New Manager Orientation Checklist
SNF Orientation Checklist
14
CMS Program TransmittalsLast Update: April 10, 2012
CMS Program Transmittals
What you need to do if you receive a Program Memorandum / Transmittal:
• Read the PM in full.
• Review the e-mail sent to you by the Subject Matter Lead to see if the PM isInformational Only or if there is Action Required.
• If there is action required, once you have implemented the PM or created an actionplan to implement, fill out the Change Verification Form and send it to theCompliance Analyst, along with a copy to the facility Compliance Department.
• Note: Program Memorandum / Transmittal implementation and action plans may beaudited. Documentary evidence of implementation will be required.
If you have any questions on the PM process, feel free to contact your local FCLor your Subject Matter Lead.
Dignity Health Transmittal Process
CMS Program Transmittals
Change Verification Form
Corrective Action Plan Form
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Coding Tip Sheets
Coding Tip Sheets
Dignity Health Portal --> Departments --> Compliance --> Clinic Compliance --> Coding Tip SheetsNameCoding Tip Sheet: 69210 Coding Tip Sheet: 99211Coding Tip Sheet: 99221Coding Tip Sheet: 99221 - 99223Coding Tip Sheet: Consultation Services Coding Tip Sheet: Critical Care Coding Tip Sheet: Excision of Lesion (2010 Update) Coding Tip Sheet: Injection InfusionCoding Tip Sheet: IPPE - Welcome to MedicareCoding Tip Sheet: Medicare Annual Wellness Visits (AWV) Coding Tip Sheet: Modifier -57 Coding Tip Sheet: OB Ultrasound Documentation Coding Tip Sheet: Observation (Short Version)Coding Tip Sheet: Observation Decision TreeCoding Tip Sheet: On-Line Medical Evaluation Services Coding Tip Sheet: Pap and Pelvic ExamsCoding Tip Sheet: Post-Op Complications Coding Tip Sheet: Revisions to Consultation Services and CodesCoding Tip Sheet: Smoking Cessation (2010 update) Coding Tip Sheet: Subsequent Observation Services Coding Tip Sheet: Telephone Services Coding Tip Sheet: Vaccine Administration Codes Non-Physician Practitioner (NPP) Services - Initial Hospital Care Services Non-Physician Practitioner (NPP) Services - Medicare Billing Rules for Split E/M Services Non-Physician Practitioner (NPP) Services - Three Options to Bill Medicare
16
Education Database
Note: Click the plus ( + ) sign to the left of the topic you want to view.
Coding Tip Sheets
Corporate Compliance Team Education
EduCode
Education Database
The purpose of the Education database is to track the Compliance training that is being provided by the Corporate Clinic Audit team. All training should be entered into the database in order for us to provide reports to Senior Leadership and the Board of Directors showing our efforts.
InstructionsData Entry Form
You can fill out this form and submit to <name> to be input into the database.
Provider EducationThe following documents may be provided to new physicians, non-physician practitioners, and resident depending on specialty and scope of service. These resources should be made available to all providers when provided focused education, as deemed appropriate by the educator.
New Provider Education
NOTE: A provider may use either the 1995 or 1997 Documentation Guidelines, but not a combination of both. When conducting audits/reviews Dignity Health will use either set of criteria, whichever is more appropriate to the encounter.
E&M Services Guide
1995 E&M Documentation Guidelines
1997 E&M Documentation Guidelines
Provider Identification Log (Signature Form)Medicare Fraud and Abuse Resource ReferenceGuidelines for Teaching Physicians, Interns, and Residents
Evaluation and Management (E/M) Documentation Guidelines
General Multi-System Exam (1995)Cardiovascular Exam (1997)Genitourinary Exam (1997)E/M Documentation Instructions for Supervising Physicians at a Teaching Hospital (PATH) and Common ScenariosMusculoskeltal Exam (1997)Neurological Exam (1997)Psychiatric Exam (1997)
Modifiers (Presentation)Global Surgery FAQAdvanced Beneficiary Notice (ABN)Hospital Care Decision Tree (Inpatient vs Observation)Dignity Health Policy 70.4.001 "Incident To" ServicesDignity Health Policy 70.4.003 Code Assignment/Documentation – Physician Practice Specific
Ambulance Services Center NoridianClinical Laboratory Fee Schedule National Correct Coding Initiative (NCCI)Clinical Laboratory Improvement Amendments (CLIA) Office for Civil Rights (OCR) CMS Regulations Office of Inspector General’s websiteCMS Transmittals OIG Exclusion DatabaseCMS Web-based Training Modules OIG Fraud Alerts California Department of Public Health MedLearn Matters ArticlesCalifornia Department of Public Health - All Facility Letters MedLearn Matters Articles Index (2004 - 2011)CMS Website OIG Office of Audit ServicesConditions of Participations for Hospitals OIG Program Guidance
DOJ Health Care Antitrust Statements of Enforcement Policy OIG Reports
Ethics Videos Palmetto GBAFederal Inspectors General Patient Protection and Affordable Care ActFederal Register Quality Improvement OrganizationsFederal Sentencing Guidelines Safe Harbor Regulations Find California Code SNF Prospective Payment System Home Health Agency Center Stark II, Physician Self-Referral Regulations Inpatient Psychiatric Facility PPS Stop Medicare FraudInpatient Rehabilitation Facility PPS The Joint CommissionMedicare Learning Network (MLN) U.S. Department of Health and Human Services Medicare Manuals U.S. Department of Justice MediRegs U.S. Government Printing Office
20
Additional External References
Associations
American Academy of Professional Coders Emergency Nursing Association
American College of Emergency Physicians Ethics and Compliance Officer Association
American Health Information Management Association Healthcare Billing & Management Association
American Hospital Association Healthcare Compliance Association
American Medical Association Healthcare Financial Management Association
Arizona Hospital and Healthcare Association Medical Association of Billers
Association of American Medical Colleges Medical Group Management Association
California Hospital Association Nevada Hospital Association
California Medical Association
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OIG Compliance Program Guidance
Last Updated: April 13, 2012
OIG Compliance Program Guidance Documents
Ambulance
Clinical Laboratories
Home Health
Hospice
Hospital
Hospital - Supplemental
Individual and Small Group Physician Practices
SNF
SNF - Supplemental
Third-Party Medical Billing Companies
22
Department Contacts
Last Update: December 2, 2012
Corporate Compliance Hotline 800-111-1111
Name Title Phone Fax
Name VP, Audit & Compliance 555-111-1111 555-111-1124
Name Coding Compliance Manager 555-111-1112 555-111-1125
NameExecutive Coordinator SupportingMary Ann LeVesque & Dawnese Kindelt
555-111-1113 555-111-1126
Name Compliance Analyst 555-111-1114 555-111-1127
Name Chief Privacy Administrator 555-111-1115 555-111-1128
Name System Compliance Director, Clinics 555-111-1116 555-111-1129
Name Corporate Compliance Manager - Clinics 555-111-1117 555-111-1130
Name Executive Coordinator to Raja Sekaran 555-111-1118 555-111-1131
NameAdministrative AssistantSupporting Jerome Ingrande & Matt Rydman
555-111-1119 555-111-1132
Name Director Coding Compliance 555-111-1120 555-111-1133
Name Coding Compliance Manager 555-111-1121 555-111-1134
Name Coding Compliance Manager 555-111-1122 555-111-1135
Name Chief Data Security Administrator 555-111-1123 555-111-1136
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Contacts by Topic
Last Updated: January 7, 2013
Contacts by Topic
For questions about: Contact: Title Phone
Admitting / Patient Access Name System Compliance Director 555-111-1111
Ambulance Services Name System Compliance Director 555-111-1112
Behavioral Health Name System Compliance Director 555-111-1113
Cardiovascular Name System Compliance Director 555-111-1114
Care Management Name System Compliance Director 555-111-1115
Clinics Name System Compliance Director, Clinics 555-111-1116
Coding - Clinics Name System Compliance Director, Clinics 555-111-1111
Coding - Hospitals Name Director Coding Compliance 555-111-1112
EduCode - Clinics Name Corporate Compliance Manager, Clinics 555-111-1113
EduCode - Hospitals Name Director Coding Compliance 555-111-1114
Emergency Department / EMTALA Name System Compliance Director 555-111-1115
Government Payer Refund Logs Name Compliance Analyst 555-111-1116
Home Health / Hospice Name System Compliance Director 555-111-1117
Imaging Name System Compliance Director 555-111-1118
Inpatient Rehabilitation Name System Compliance Director 555-111-1119
Lab Name System Compliance Director 555-111-1120
Materials Management / Supply Chain Name System Compliance Director 555-111-1121
Name (Reports only) Compliance Analyst 555-111-1123
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Facility Contacts
Last updated: January 7, 2013
DIGNITY HEALTH FACILITIES AND CONTACTSClick on + box on left gray margin to display all associated facilities. Click on - to close
Affiliated With Facility
System Compliance
Director FCLOCEP
Champion Attorney
Government Payer
Refunds
Coding Compliance
Manager
Research Accountable
ExecutiveArroyo Grande Community Hospital
Arroyo Grande Community HospitalAddress & Phone
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Arroyo Grande Care CenterAddress & Phone
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Coastal Cancer Care and Diagnostic CenterAddress & Phone
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Coastal Surgical InstituteAddress & Phone
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Bakersfield Memorial Hospital
Bakersfield Memorial HospitalAddress & Phone
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
California Hospital Medical Center
California Hospital Medical CenterAddress & Phone
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Chandler Regional Medical Center
Chandler Regional Medical CenterAddress & Phone
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
Contact Name and Number
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Compliance Hotline
Dignity Health Compliance Hotline: (800) 938-0031
Dignity Health has established the Dignity Health Hotline at (800) 938-0031 for use by employees to ask questions or report potential or suspected violations of the Standards of Conduct, HIPAA, Dignity Health Policy, or other Healthcare Regulations.
The Hotline is accessible 24 hours per day, seven days a week. All reports will be taken seriously, reviewed and investigatedpromptly, result in appropriate corrective action and, to the extent possible, be treated in a confidential manner. An employee does have the option to remain anonymous.
Retaliation against any employee who, in good faith, reports potential or suspected violations is unlawful and will not be tolerated.
Dignity Health has contracted with “Global Compliance Services” to manage our hotline calls. • All calls will be answered by a Global Compliance Services communications specialist.• The specialist will contact the appropriate Dignity Health representative.• The Dignity Health representative will log the call, then forward to the appropriatepersonnel for investigation.
• Upon completion of the investigation, the investigator will prepare a report describingthe conclusions and any recommendations.
• Regardless of the subject matter, all responses should be sent to Global ComplianceServices within 30-days of the original call.
As a manager, you may be called upon to assist the FCL, FPO or other authorized personnel with investigations.
Complete details can be found in Dignity Health Policy 070.1.006 Response Procedure – Dignity Health Hotline Calls.
Hotline Response Form
26
FCL (Facility Compliance Liaison) Meetings
Last Updated: December 6, 2012
FCL Meetings
The FCLs meeting quarterly on the 3rd Wednesday of the 2nd month of the quarter (2:00 pm California time). Dial-in and WebEx information will be e-mailed to all FCLs prior to the meeting.
Meeting Minutes FY12 Approval
July 25, 2011 11/16/2011
November 16, 2011 05/16/2012
May 16, 2012 07/18/2012
Meeting Minutes FY13 Approval
July 18, 2012 11/14/2012
November 14, 2012 Pending
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Calendar / Due Dates
Last Updated: January 7, 2013FY13 FY14
Q3 Q4 Q1 Q2Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
1New Year's
Day
2
3
4CMS
Inspection
HCCA Compliance
Institute
5CMS
Inspection
HCCA Compliance
Institute
6HCCA
Compliance Institute
7
8
Monthly Compliance Committee
Meeting
Monthly Compliance Committee
Meeting
Monthly Compliance Committee
Meeting
Monthly Compliance Committee
Meeting
Monthly Compliance Committee
Meeting
Monthly Compliance Committee
Meeting
Monthly Compliance Committee
Meeting
Monthly Compliance Committee
Meeting
Monthly Compliance Committee
Meeting
Monthly Compliance Committee
Meeting
Monthly Compliance Committee
Meeting
Monthly Compliance Committee
Meeting
9
Compliance Oversight Meeting, 10:00 am
10
11Annual Policy reviews are
due
12
28
Audit Tools
Home
Last Updated: March 15, 2012
Audit Tools
Behavioral Health Self Audit Tool
Inpatient
Outpatient
Corrective Action Plan
Home Health Self Audit Tool
Home Health Billing Audit Tool - Legend and Instructions
Home Health Billing Audit Tool
Hospice Self Audit Tool
Hospice Billing Audit Tool - Legend and Instructions
Hospice Billing Audit Tool
Inpatient Rehabilitation Facility Self Assessment
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Audit Process Documentation
Last Update: November 12, 2012
Clinic Audit Schedule FY13
Clinic Compliance Routine Audit Process
Clinic Compliance Routine Focused Audit Process
Corrective Action Findings/Actions Codes List
Clinic Refund/Rebill Log
FY13 Dignity Health Medical Foundation Scorecard
MD Audit
Important Note: Data prior to July 1, 2011 (FY12) is incomplete and inaccurate and cannot be used for trending.
MD Audit Scoring Methodology
For help with MD Audit please contact:Name - NumberName - Number
NOTE: A provider may use either the 1995 or 1997 Documentation Guidelines, but not a combination of both. When conducting audits/reviews Dignity Health will use either set of criteria, whichever is more appropriate to the encounter.
Beginning January 2011 the Office of the Inspector General (OIG) and Centers for Medicare and Medicaid (CMS), and other governing bodies have published concerns related to the increased documentation and billing related to the use of the Electronic Health and Medical Records. These concerns have included the improper use of ‘copy paste’ functions and other concerns.
The Compliance Department has collaborated with physicians and EMR implementation staff to create the attached EMR guide which was developed to describe potential risk that may arise when implementing an EMR, and to provide recommendations to mitigate those risks.
This document includes best practices as outlined by professional associates and CMS and the health care community.
This guide is not meant to detail all risk areas or solutions, but to serve as a resource in addition to external publications.
Implementing and Maintaining Electronic Medical Records (EMR Guidebook)
Progress Notes and Forms
Update for Amendments, Corrections and Delayed Entries
Medicare Physician Fee ScheduleThis document outlines the Physician Supervision Requirements for a variety of services
Joint Ventures
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Joint Ventures
Last Updated: January 9, 2013
Joint Ventures
Joint Venture Compliance Assessment Memo
JV Assessment Questionnaire
JV Inventory 2011
Policy 3.700 Guidelines and Requirements for JV Arrangements
Policy 140.1.001 Joint Ventures
36
Provider Based Clinics
Last Updated: April 14, 2012
Provider-Based Clinics
Requirements for a determination that a facility or an organization has provider-based status. (42 CFR 413.65)http://edocket.access.gpo.gov/cfr_2007/octqtr/pdf/42cfr413.65.pdf
Program Transmittal A-03-030
Memo - Provider-Based Requirements
Checklist - Provider-Based Requirements
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Government Payer Refunds
Last Updated: January 11, 2013
Government Payer Refunds
Policy 70.1.008 Voluntary Government Refunds, Rebills and Voluntary Disclosures
Overview of the Government Payer Refund log
Blank Refund LogThis is a sample refund log. A log has been created for each facility. If you need a log created for your facility, please contact your Compliance Analyst at 555-555-1212 or via e-mail at [email protected]
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DeMinimus Tracking
Last Updated: December 16, 2012
DeMinimus Tracking
Presentation: Tracking DeMinimus Gifts and Gratuities
DeMinimus Tracking Form
Physician Expense Tracking Form
Sample: Physician Transaction Report
Memo: Tracking Physician Meal Expendures
Medical Director Monthly Time Sheet
Deminimus Log
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Guidance Documents
Last Updated: January 9, 2013
Guidance Documents
Admission Challenges - Inpatient, Outpatient & what are Observation Svcs Operation of Physician Referral Services and DirectoriesAmerican’s with Disabilities Act Compliance PACT RuleCompliance, Privacy and Data Security Conference Materials Patient Inducements
Casts / Sprints / Strappings Physician Extenders (under development)Charging for ED Triage Only Physician Owned DistributorsCharging for Intraosseous Infusion Medication Administration Physician Transaction Primer and GridCharging Medicaid Patient for Non-Covered Cosmetic Procedure Practical Guide for Compliance Program OversightConflict of Interest of Non-Management Employees Presbyopia Correcting IOL Guidance
Memo Reporting Observation Services in Labor and Delivery
Form Reporting of IV Injection Infusion HydrationCPT Code 29581 - Venous wound compression system below knee Sleep Study Lab Staffing (CPDH Memo)Customer Advisory Panels Social Media Guidelines (Dignity Health)Discounts for Physicians injured performing services at Dignity Health Stark Law Clarifications and EnforcementDocumentation and Reporting Requirements of Discarded Drugs Stark Medical Staff Incidental Benefit Exception GuidanceFree or Reduced Price Equipment and Service Transactions* Tracking Physician Meal ExpendituresGifts Guidance - Hospital Trauma ChargingGifts Guidance - Vendor Type A/B Emergency Room Bed DesignationHoliday GiftsInfusion Start and Stop Time DocumentationJoint Venture
*Available to FCLs Only
40
Patient Inducement Guidance
Last Update: May 24, 2012
Patient Inducement Guidance
Car Seat Guidance
Free Goods and Services to Patients
Gifts and Inducements (OIG Special Advisory Bulletin)
Compliance Issues with Free Services and Promotions
OIG Advisory Opinions
Opinion NumberYear
Published Summary
11-092011 (concerning the use of a "preferred hospital" network as part of Medicare Supplemental
Health Insurance ("Medigap") policies.)
11-02 2011 (concerning a complimentary local transportation arrangement whereby a hospital would transport patients from physician offices located on, or contiguous to, the hospital's campus to the hospital if the patients require further treatment and cannot transport themselves.)
09-11 2009 (concerning the provision of free blood pressure screenings to walk-in visitors at a hospital)
09-07 2009 (concerning a proposal to expand an existing program that provides free oral nutritional supplements to malnourished end-stage renal disease patients who are on dialysis)
09-01 2009 (concerning a complimentary local transportation program for friends and family of residents of a skilled nursing facility)
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• Non‐Retaliation Policy
• Disciplinary Policies and Procedures
• Job Descriptions
• Presidents’ Scorecard
Enforcing Disciplinary Standards Through Well Published Guidelines
