Camcare health corporation corporate compliance program
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CAMcare Health Corporation Corporate Compliance Program. Corporate Compliance. Purpose: To establish a system of internal controls designed to ensure that we regularly evaluate and monitor our own adherence to applicable statues, regulations and program requirements.

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CAMcare Health Corporation Corporate Compliance Program

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CAMcare Health CorporationCorporate Compliance Program

Corporate Compliance

  • Purpose:

    • To establish a system of internal controls designed to ensure that we regularly evaluate and monitor our own adherence to applicable statues, regulations and program requirements

High Risk Areas for Health Centers

  • Billing and Coding

  • Grants Management

  • Internal Controls

  • Information Management

  • Tax Issues

  • Cost Reporting and Regulatory Filings

Elements of Effective CCP

  • Designate Corporate Compliance Officer and Committee

  • Develop and Implementation of Compliance & Practice Standards

  • Conduct Training & Education

  • Establish open lines of communication

  • Conduct Internal Monitoring and Auditing

  • Establish Process for Responding to Potential Offenses

  • Establish Disciplinary Standards

Corporate Compliance Committee

  • Corporate Compliance Officer

  • Medical Director

  • Nursing Director

  • Billing Director

  • Finance Director

  • MIS Director

Implementation of Compliance & Practice Standards

  • Establishment of policy to promote compliance

    • Develop written policies and procedures that establish guiding principles or courses of action for staff

    • Policies and procedures must be consistent with the requirements and standards established by health center’s BOT and all regulatory and accrediting organizations

Training and Education

  • Develop and provide ongoing education and training for BOT and Staff regarding the Compliance Program

    • All BOT and Staff will receive a General Compliance training

    • Specialized training for staff (ie. Staff with direct responsibility for coding and billing)

    • Focused training for areas identified in an audit to be potentially problematic

Open Lines of Communication

  • Establish a toll free hotline for reporting issues and concerns relating to compliance

  • Ensure that the telephone number is publicized in a common staff work area (ie. Break room, lunchroom)

Internal Auditing and Monitoring

  • Conduct periodic self audits to assure

    • Written standards and policies are in compliance with the law

    • Operating in compliance with written policies and procedures

    • Coding and billing are accurate with services provided

    • Documentation is accurate and complete

    • Furnished services are reasonable and necessary

Response to Detected Offenses

  • Upon receiving a report of suspected non-compliance, the Compliance Officer will initiate steps to investigate the conduct in question

    • Interviews of persons with knowledge of the matter

    • Review of relevant documents and applicable laws

    • Engage legal counsel, external auditors, or health care experts to assist in the investigation if necessary

Establish Disciplinary Standards

  • Establish and publish procedures for enforcing and disciplining individuals who violate the law

  • Disciplinary guidelines should be well publicized

    • Trainings

    • Policy and Procedure

    • Employee job descriptions

    • Employee handbook

    • Standards of Conduct

Why Corporate Compliance?

  • Mandatory

  • Establishes a program to identify and respond to organizational risks

  • Identifies and addresses gaps in existing practices,policies and procedures

  • Program will deter potential fraudulent activity

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