REFLECTIONS FROM GROUND ZERO: DISASTER PLANNING FOR COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FAL...
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REFLECTIONS FROM GROUND ZERO: DISASTER PLANNING FOR COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN). LINDA V. TIANO SENIOR VICE PRESIDENT AND GENERAL COUNSEL, EMPIRE BLUE CROSS BLUE SHIELD. Empire Blue Cross Blue Shield. Not for Profit Health Insurer 28 Counties in New York

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REFLECTIONS FROM GROUND ZERO: DISASTER PLANNING FOR COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN)

LINDA V. TIANO

SENIOR VICE PRESIDENT AND GENERAL COUNSEL, EMPIRE BLUE CROSS BLUE SHIELD


Empire blue cross blue shield l.jpg
Empire Blue Cross Blue Shield COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN)

  • Not for Profit Health Insurer

  • 28 Counties in New York

  • Medicare Part A & B Administrator

  • Over 6000 Employees

  • Commenced operations in late 1930s


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Multiple Locations COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN)

  • Melville, LI

  • Bohemia, LI

  • Middletown, NY

  • Albany, NY

  • Yorktown, NY

  • Syracuse, NY (Medicare)

  • Harrisburg, PA

  • World Trade Center - over 1900 employees


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Move to WTC COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN)

  • Three years ago

  • Substantial upgrade to systems

  • Standardized workstations

  • Eliminated rogue systems and servers

  • Disaster planning


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Disaster Plan COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN)

  • Operational Focus

  • Recovery team

  • Key functions - e.g. recovery cost center

  • Systems back up plans

  • Responsibilities need to be flexible

  • Multiple sites key


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9/11 COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN)

  • WTC headquarters was destroyed

  • Plan worked well

  • Computer center unaffected

  • Claims and customer service switched to other sites instantaneously


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9/11 CONTINUED COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN)

  • Focus on finding employees and returning to work

  • Finding telephone numbers was an issue, especially cell phones


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The Aftermath - Systems COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN)

  • All system servers backed up 8/31.

  • Claims + customer mail is imaged upon receipt. All imaged documents available.


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The Aftermath - Legal Department COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN)

  • Paper based

  • CLMS System

  • Imaging

  • Offsite storage

  • Word Processing - issues with confidentiality


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The Aftermath - Office Space COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN)

  • 1900 Employees displaced

  • Analyzed demographics

  • Placed people in existing space where possible

  • 7 leases in 6 weeks


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Document Inventory COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN)

What was missing and where could we find it

  • Other offices

  • Board members

  • Regulators

  • Outside Counsel

  • e-mail or network documents


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Compliance Issues COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN)

  • Disaster Plan did not cover

  • Companies have compliance plans & disaster plans, but not compliance plans for disasters

  • Primary issue was documents


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Documents COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN)

  • Provider credentialling files

  • Minutes

  • Historical documents

  • Insurance Policies

  • Provider contracts

  • Vendor Contracts

  • Rate filings

  • Financial records

  • Employment documents

  • Documents sent by others


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Audit Issues COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN)

  • DOH was supposed to come in October

  • DOI was onsite


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Key Factors in Recovery COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN)

  • Multiple locations

  • Employees

  • Recent move and systems consolidation

  • Efforts on Restructuring

  • Vastness and sympathy


Recommendations l.jpg
Recommendations COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN)

  • Disaster Plan for Compliance

  • Schedule documents required, with how to retrieve, e.g. where else are they, how far back you need them, who is responsible and prioritize. Keep it up-to-date.


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Recommendations (cont’d) COMPLIANCE (OR WHAT TO DO WHEN YOUR BUILDING FALLS DOWN)

  • Keep copies of key documents in multiple locations

  • Scan and back up

  • Know what your regulators keep

  • Telephone Numbers

  • Creativity