May Hospice Fundamentals All Rights Reserved 1. SALES COMPLIANCE AND INTEGRITY How To Grow While Following The Rules

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Dwayne Holmes
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SALES COMPLIANCE AND INTEGRITY How To Grow While Following The Rules Colleen McGreevy Objectives 1. Understand basic steps to successful hospice sales and marketing 2.

1 SALES COMPLIANCE AND INTEGRITY How To Grow While Following The Rules Colleen McGreevy Objectives 1. Understand basic steps to successful hospice sales and marketing 2. Develop a risk awareness in five key areas for your sales program 3. Identify changes your agency can make to prepare for successful, compliant growth Set Yourself Up for Success We believe that every system is perfectly designed to achieve the results it gets Institute for Healthcare Improvement All Rights Reserved 1

2 Why It Matters Healthcare sales and marketing may only be done within very specific parameters Improper practices can lead to charges under anti-kickback statute There has been increased scrutiny in this area in recent years for all providers, including hospices Sales and Marketing Risk Areas 1. Sales Activities 2. Expenditures 3. Access 4. Advertisements and Collaterals 5. HIPAA Compliant Growth: Sales Activities "DOs" Focus on education Give out approved marketing materials with your agency name and contact information and differences Identify the highest opportunity accounts in each territory Hospice-eligible patients Have referred before Large case load Not affiliated with another hospice All Rights Reserved 2

Compliant Growth: Sales Activities "DOs" Call on a mix of accounts: hospital, SNF, ALF, home health Sell deep, not wide Target your efforts - Top 10-20 Set frequencies - weekly for top accounts Call

3 Compliant Growth: Sales Activities "DOs" Call on a mix of accounts: hospital, SNF, ALF, home health Sell deep, not wide Target your efforts - Top Set frequencies - weekly for top accounts Call on decision-makers and influencers every time Sell your outcomes Compliant Growth: Sales Activities "DON'Ts" Perform duties that referring facilities are required to offer Activities such as Bingo Discharge Planning Provide volunteer activities for non patients Give anything in exchange for receiving referrals Be wary of hosting after hours events for referral sources that don t focus on education Drop off meals for referral sources without tie-in to education for the key decision makers and influencers Compliant Growth: Expenditures "DOs" Branded and approved giveaways Pens, pads, cups, hand sanitizer, etc. Special celebration days branded and approved items - Hospice Month, Social Work Month, Administrative Professionals Day, etc. Nominal Value Refreshments for education activities Annual limit per NPI All expenditures documented and expensed All Rights Reserved 3

4 Compliant Growth: Expenditures "DON'Ts" Non-food expenditures (other than branded and approved giveaways) Gift Cards Alcohol Clothing Jewelry Toiletries Other Gifts Personal gifts to referral sources Compliant Growth: Access "DOs" Speed to care is key Consider setting up an admissions department vs anyone can take a referral Eliminate the concept of business hours Develop a back-up admission team for high volume days Train your team to overcome common objections Set up an organized follow-up system for pending and non-admits Compliant Growth: Access "DOs" Start the day with a referral to admission stand-up call for good communication Have a protocol in place for admit nurse in the event that the patient does not appear to be eligible (discuss with clinical manager, Medical Director, referring physician before non-admit) Only Medical Director and attending physician may decide eligibility RN may evaluate and convey findings to physicians Admission staff should share supporting documentation with hospice physicians All Rights Reserved 4

5 Compliant Growth: Access "DON'Ts" Allow sales and marketing staff sign consents if they are financially incentivized Financially incentivize nursing staff Knowingly admit ineligible patients Compliant Growth: Advertisement & Collaterals "DOs" Create brochures, case studies and PowerPoint presentations to educate your community Include the ability to make on-line referrals from your website Engage in social media to communicate with consumers Develop name recognition with billboards and commercials if you have the budget for them Compliant Growth: Advertisement & Collaterals "DOs" Include your phone number for referrals on all collaterals Ensure that any state required language is on all of your materials Use language that reflects your commitment to serving eligible patients Make sure that the photos on your marketing materials reflect the diversity of the community you serve Have an approval process for all materials that includes the compliance department or committee review All Rights Reserved 5

6 Compliant Growth: Advertisement and Collaterals "DON'Ts" Allow your staff to create and distribute materials that are not approved by your Marketing - Communications and Compliance teams Compliant Growth: HIPPA "DOs" All communication should be secure Limit sales and marketing staff participation in IDT Policies regarding transport of PHI Must be privately stored Must be turned in in a timely manner PHI must be shredded after use Compliant Growth: HIPPA "DON'Ts" Discuss PHI in public spaces Review patient charts and other PHI without approval from the patient/family or referral from professional referral source ( covered entity ) Allow sales and marketing staff to text PHI or to send or receive PHI on a non-secure server or device All Rights Reserved 6

7 Wrapping Up: The Successful Hospice To-Do List 1. Focus on education 2. Sell to key decision makers and influencers 3. Share your outcomes 4. Develop referral relationships with a mix of referral types 5. Ensure ease of access any day, any time 6. Advertise your agency through brochures, branded giveaways, social media, billboards, commercials, website 7. Follow HIPAA rules 8. Set up systems for compliance and sales/marketing working together! For Further Questions or Comments Colleen McGreevy CMC Health Partners, LLC (423) colleen@cmchealthpartners.com To Contact Us Susan Balfour Susan@HospiceFundamentals.com Roseanne Berry Roseanne@HospiceFundamentals.com Charlene Ross Charlene@HospiceFundamentals.com The information enclosed was current at the time it was presented. This presentation is intended to serve as a tool to assist providers and is not intended to grant rights or impose obligations. Although every reasonable effort has been made to assure the accuracy of the information within these pages, the ultimate responsibility for the correct conduct, submission of claims and response to any remittance advice lies with the provider of services. All Rights Reserved 7

April Hospice Fundamentals All Rights Reserved 1. The Certification/ Recertification Process: No Room for Error. What You Will Learn Today

April Hospice Fundamentals All Rights Reserved 1. The Certification/ Recertification Process: No Room for Error. What You Will Learn Today The Certification/ Recertification Process: No Room for Error Subscriber Webinar What You Will Learn Today Regulatory requirements Election of the Medicare Hospice Benefit Certification Recertification