Corporate Compliance Program

1. Corporate ComplianceProgram A Brief Overview of Healthcare Compliance

2. Corporate Compliance ProgramWelcome! • The “what” and “why” of compliance; • Elements of an effective compliance program; • Your role in compliance and preventing fraud and abuse; • How to recognize, resolve, & report compliance issues; • A system designed to promote the prevention, detection and resolution of conduct that does not conform to: • WMC Code of Conduct • Legal & Regulatory Requirements • Ethical Requirements Compliance IS your Responsibility!!

3. Purpose of the Corporate Compliance Program • Promote a healthy environment • Ensure compliance with the law • Cultivate justice • Prevent harassment, disrespect, and a hostile work environment • Identify vulnerabilities and raise concerns

4. Why a Compliance Program? Corporate Good Citizenship Prevent Fraud & Abuse Quality Patient Care Reduces Liability & Penalties

5. Deficit Reduction Act (DRA) • Effective 1/1/07 – Federal & State False Claims Act • Providers who receive five (5) million + Medicaid $ • Mandates Compliance Program • Fraud & Abuse Policy • Educate Staff, Vendors, Contractors • Whistleblower Protections

6. Compliance Program Elements • Compliance Officer and Organizational commitment • Written standards and procedures: WMC Code of Conduct • Annual compliance education and training • Open and effective lines of communication • Monitoring and Audit Programs • Investigation and follow-up of actual or suspected compliance violations • Enforcement through disciplinary guidelines

7. Compliance Risk Areas • HIPAA Privacy and Security • Documentation, Coding and Billing • Theft or misuse of assets • Gifts, Entertainment & Gratuities • Conflicts of Interest • Vendor Relationships

8. HIPAA • HIPAA’s Privacy and Security Rules regulate the use and disclosure of Protected Health Information (PHI); • HIPAA requires that you only use, disclose, & access PHI for job-related purposes; • Patients expect and have a right to privacy of their protected health information (PHI) that is in: • Verbal • Written, or • Electronic form

9. What is PHI? All individually identifiable information that relates to a person’s: • Physical or mental health or condition • Billing and payment for healthcare ……and that identifies, or could be used to identify the person who is the subject of the information.

10. Examples of PHI Patient’s • Name • Address • Phone Number • Account #, Patient ID, Medical Record# • Social Security Number • Date of Birth • Diagnosis or procedure information • AND….any other information that would identify the patient.

11. Privacy Tips • Use shredders or privacy bins; • Keep voices to minimum so others do not overhear; • Do not use personal photography equipment inside the facility, ie: cell phone cameras; • Double check fax numbers before hitting SEND; • Always check proper documentation being handed to a patient, ENSURE IT IS THEIRS! • Know the OPT OUT Policy.

12. Every Employee’s Responsibility • Get educated!! • Know what to do – follow policies and procedures to safeguard PHI • When in doubt…..ASK your Supervisor or the Compliance Officer • Don’t conduct an investigation, you must report HIPAA problems/issues promptly to the Corporate Office. HOW WILL I KNOW WHEN IT IS OKAY TO ACCESS OR SHARE PATIENT INFORMATION? • When it is for treatment, billing or operations and…. • Ask yourself: Do I need this information to carry out the responsibilities of my job?

13. Social Media • Do NOT post PHI to Facebook, Twitter, or any accounts unprotected by WMC firewall; • Do NOT use texting that includes PHI; • i-Cloud is an unprotected site; • Do NOT use g-mail, hotmail, etc. as a place to hold or share information.

14. HIPAA Security • Covers PHI in electronic form only (E-PHI) • Electronic protected health information that our system creates, receives, maintains, and/or transmits electronically • E-PHI is stored on computers, clinical equipment, discs, and software systems • Billing System • Electronic Medical Records

15. HIPAA Security TIPS • Don’t leave your computer unattended • Don’t share your password • Don’t download unauthorized software • Don’t keep PHI in view of visitors or public areas • Don’t misdirect email/faxes

16. Documentation & Reimbursement • Documentation is the written account of a provider’s encounter with a patient • Must be accurate, complete and legible if written • All physician notes MUST be signed and dated, electronically or written • Tens of Billions of Dollars are lost annually to improper payment for: • Services that patients didn’t receive • Up-coding for higher reimbursements • Medically unnecessary services • Separate billing for outpatient/inpatient services for the same period.

17. What is WMC’s Policy on Retaliation? • WMC has a policy of “zero tolerance” for any form of retaliation against those who report Code of Conduct concerns in good faith • WMC encourages honest discussion about these concerns. Zero tolerance retaliation applies to: • Direct as well as indirect retaliation • Retaliatory actions as well as threats of actions • Retaliation from Supervisors as well as from coworkers

18. Conflict of Interest Potential Conflict Situations: • A personal interest that compromises your duty of loyalty to WMC When an individual uses his/her position or the knowledge gained from their position for personal benefit • Even the appearance of a conflict can be a problem • Requirement to disclose conflicts • NYS Joint Commission of Public Ethics • State employee • 2 year moratorium • Are you a designated decision maker? • File an annual disclosure • Earnings of >$91,821(as of 4/2015)

19. Gifts, Gratuities & Business Conduct • The Federal Anti-Kickback Statute prohibits the acceptance of an item of value, cash or any kind, in exchange for referral or business. • Staff may not accept cash, gifts, or other items of value to influence with whom we do business or for the referral of patients. • Gifts, cash, or items of value should never be solicited from patients, vendors or business associates.

20. Gifts, Gratuities & Business Conduct What is Acceptable? • Promotional items that are nominal in value ($10 or less) can be accepted, but are DISCOURAGED • Pens • Notepads • A department or group may accept perishable or consumable gifts • Fruit baskets • Candy, cookies And as long as there is no inference to induce or exchange for referrals.

21. How does this relate to me? • Treat everyone in a courteous and fair manner • Maintain a health and safe environment • Obey all applicable laws and Hospital Policies and Procedures • Keep all patient information and records confidential • Never knowingly make false or misleading statements Got Compliance??? Let’s Get It!!!

22. When to Report a Problem How do you know when to report? • Is there a suspected or actual violation of a law or policy? • Is there a questionable practice or unethical act involved? • Does it feel right?

23. Reporting Where to find help with compliance-related issues? • First resource is often your direct Supervisor/Manager • If he/she does not know the answer or you are not comfortable asking him/her, then please contact: • Terri Alesandro, HealthAlliance Compliance Director • (845) 334-4711 • Westchester Compliance Office(914)-493-2600

24. Helpline Reporting The toll-free Help Line is a confidential, anonymous and non-retaliatory reporting mechanism available 24 hours a day, 7 days a week. • When calling the helpline you will be asked: • Name of your organization • Nature of your concern • Additional questions 1-844-863-1822

25. Questions?