National Policy Library Document

Size: px
Start display at page:

Download "National Policy Library Document"

Transcription

1 Page 1 of 5 National Policy Library Document Policy Name: Medicare Compliance: Compliance Officer and Compliance Committee Policy No.: HR Policy Author: Author Title: Author Department: Sheryl D Pessah Mgr Compliance & Reporting 4002-Medicare Compliance and C Phone: Cost Center: 818/ Functional Owner: Nancy A Starts Executive Owner: Gay Ann Williams Blank This Policy is applicable to the following: Department(s): Business Unit(s): Regions: Products/LOB's: All Departments HN Life, HNAZ, HNCA, HNI, HNNE, HNOR, HNPS N/A Medicare Advantage, Medicare Part D Date Created: Effective Date: Version: 03/28/ /01/ Blank Policy Statement: Health Net follows the Centers for Medicare & Medicaid Services (CMS) requirements contained in the Medicare Managed Care Manual Chapters, the Prescription Drug Benefit Manual Chapter 9 Part D Program to Control Fraud, Waste and Abuse Guidance as well as Parts 422 and 423 of Title 42 of the Code of Federal Regulations (CFR). CMS requires Medicare Advantage (MA) organizations and Part D Sponsors have a compliance officer and compliance committee in place as described in 42 CFR (b)(4)(vi), Chapter 11 Section 20.1 of the Medicare Managed Care Manual as well as in the CMS Prescription Drug Benefit Manual Chapter 9 Part D Program to Control Fraud, Waste and Abuse (Sections through ). A. Medicare Compliance Officer The Medicare Compliance Officer is responsible for ensuring compliance with the MA and Part D program requirements. As some duties of the Medicare Compliance Officer are delegated, the Medicare Compliance Officer maintains appropriate oversight of those delegated duties. Responsibilities of the Medicare Compliance Officer include, but are not limited to: a) Developing and monitoring the implementation of and compliance with MA and Part D related policies and procedures through the creation and implementation of a monitoring and auditing program. b) Participating with the Medicare Oversight Committee, which functions as the Medicare compliance committee.

2 Page 2 of 5 c) Reporting, at least on a quarterly basis, or more frequently as necessary, to Health Net s Chief Compliance Officer and compliance committee, on the status of Health Net s compliance program, the identification and resolution of potential or actual instances of noncompliance, and Health Net s oversight and audit activities. d) Ensuring consistent and timely reporting of relevant Medicare Compliance issues to management, to the Chief Executive Officer and President of Health Net, Inc., and to the Audit Committee of the Health Net Board of e) Creating and coordinating, or appropriately delegating, educational training programs to ensure that Health Net s officers, directors, managers, associates and first-tier, downstream and related entities working on the MA and Part D programs are knowledgeable of Health Net s compliance program; its written standards of conduct, policies, and procedures; and the applicable statutory, regulatory, and other requirements. f) Ensuring that first tier, downstream, and related entities, particularly those involved in sales and marketing activities, are aware of and follow the requirements for MA and Part D sales and marketing activities. g) Briefing the compliance committees and governing body on the status of compliance training. h) Developing, implementing and maintaining a system for Health Net s officers, directors, managers, associates and first-tier, downstream and related entities to ask compliance questions, and report suspected instances of non-compliance or potential instances of fraud, waste or abuse confidentially or anonymously without fear of retaliation. i) Maintaining the compliance reporting mechanism and closely coordinating with the Special Investigations Unit (SIU), where applicable. j) Responding to reports of potential instances of MA and Part D fraud, waste or abuse, including the coordination of internal investigations and the development of appropriate corrective or disciplinary actions, if necessary. To that end, the Medicare Compliance Officer has the flexibility to design and coordinate internal investigations (e.g., responding to reports of problems or suspected violations) and execute any resulting corrective action (e.g., making necessary improvements to policies and practices and taking appropriate disciplinary action). k) Coordinating personnel issues with Health Net s Organization Effectiveness (OE) Department to ensure that the DHHS OIG and GSA exclusion lists have been checked to ensure no officers, directors, managers, associates or first-tier, downstream and related entities are included on such lists. l) Reporting any potential fraud or misconduct related to the MA or Part D program to CMS, its designee and/or law enforcement. m) Ensuring documentation is maintained for each report of potential fraud, waste or abuse received through any of the reporting methods (i.e., hotline, mail, in-person), which describes the initial report of non-compliance, the investigation, the results of the investigation, and all corrective and/or disciplinary action(s) taken as a result of the investigation as well as the respective dates when each of these events and/or actions occurred and the names and contact information for the person(s) who took and documented these actions. n) Overseeing the development, implementation and monitoring of corrective action plans. o) Ensuring potential fraud investigations are referred to the MEDIC (Part D), as appropriate, and facilitating any documentation or procedural requests that the MEDIC make of the Part D plan. Similarly, the Medicare Compliance Officer will collaborate with other other applicable organizations when a fraud, waste or abuse issue is discovered to involve multiple parties. p) The Medicare Compliance: Officer has the authority to: Report directly to the Chief Compliance Officer, who has the authority to report directly to the Board of Interview or delegate the responsibility to interview Health Net s employees and other relevant individuals. Review and retain company contracts and other documents pertinent to the MA and Part D programs. Review or delegate the responsibility to review the submission of data to CMS to ensure that it is accurate and in compliance with CMS reporting requirements. Seek advice from legal counsel. Report misconduct to CMS, its designee and/or law enforcement. Conduct and direct internal audits and investigations of any first tier, downstream, or related entities. Health Net Medicare Compliance Department The Health Net Medicare Compliance Department reports to the Medicare Compliance Officer and assists in promoting ethical conduct, instilling a company-wide commitment to Medicare Compliance, and exercising diligence in detecting and preventing misconduct. Responsibilities of the Medicare Compliance Department include, but are not limited to: Maintaining the Health Net Medicare Compliance Plan. Interpreting Federal policy and providing guidance to the Health Net business units responsible for administering the MA and Part D program.

3 Page 3 of 5 Analyzing CMS memos and new or revised guidance and distributing such memos to the Health Net business units responsible for administering the MA and Part D program. Tracking to ensure appropriate actions are taken by the applicable business unit(s) in response to CMS memos and new or revised guidance. Conducting routine audits and focused reviews of high-risk areas. Maintaining the Medicare Compliance intranet site on Health Net Connect as a source of education and information to all associates. Developing training products to educate associates about the Compliance Program and associates responsibility for administering the MA and Part D plans in a compliant and ethical manner. Reporting significant and material compliance issues to the Medicare Compliance Officer. Developing, implementing and maintaining Medicare Compliance policies and procedures. B. Compliance Committee The Health Net Medicare Oversight Committee is responsible for setting the Medicare Program s direction; resolving compliance actions and other critical issues requiring executive decisions such as resources, budgets, interdependencies, resource deployment; monitoring the status and progress of critical projects; and addressing organizational obstacles for the subcommittees. The Medicare Oversight Committee is functionally the Medicare Compliance committee and is responsible to the Chief Government Programs Officer. Responsibilities of the Medicare Oversight Committee include, but are not limited to: a) Meeting not less than semi-monthly or with greater frequency as business conditions require. b) Developing strategies to promote compliance and the detection of any potential violations. c) Ensuring that training and education are appropriately completed. d) Assisting in the creation of effective corrective action plans and ensuring that they are implemented and monitored. e) Ensuring the business units that administer the Health Net MA and Part D products have appropriate, up-todate compliance policies and procedures. f) Reviewing and addressing reports of monitoring and auditing of areas in which Health Net is at risk of fraud, waste or abuse and ensuring that corrective action plans are implemented and monitored. Providing regular and ad hoc reports on the status of compliance with recommendations to Health Net s Board of Policy Purpose: A. To ensure the designation of a Medicare Compliance Officer responsible for developing, operating and monitoring the MA and Part D compliance program. B. To ensure a Medicare compliance committee is in place. Scope/Limitations: This policy and procedure applies to all associates employed, contracted, or otherwise representing Health Net, Inc. and its subsidiaries. Related Policies: Associate Policy: Designation of Chief Compliance Officers and Obligation of Associates to Support the Compliance Mission (MP ) Medicare Compliance: Comprehensive Fraud, Waste and Abuse Plan (HR ) Medicare Compliance: Corrective Action Procedures (EJ ) Medicare Compliance: Effective Lines of Communication ( HR ) Medicare Compliance: Enforcement of Standards ( HR ) Medicare Compliance: Medicare Compliance Plan (HR ) Medicare Compliance: Monitoring and Auditing (HR ) Medicare Compliance: Training and Education ( HR ) Medicare Compliance: Written Policies and Procedures and Standards of Conduct (PS ) References: Title 42 Code of Federal Regulations (CFR) 42 CFR (b)(4)(vi), 42 CFR (b)(4)(vi) 42 CFR (b)(4)(vi)(A-G)

4 Page 4 of 5 42 CFR (b)(4)(i and iii) CMS Medicare Managed Care Manual Chapter 11 - Medicare Advantage Application Procedures and Contract Requirements Section 20.1 Chapter 9 Part D Program to Control Fraud, Waste and Abuse MA-PD Sponsor Part D Audit Guide V 3.0 CP02 - Designation of Compliance Officer and Committee CP09 - Executive Manager and Policy-Making Body PDP Sponsor Part D Audit Guide V 3.0 CP02 - Designation of Compliance Officer and Committee CP09 Executive Manager and Policy Making Body Health Net Medicare Compliance Plan 2010 Definitions: Centers for Medicare and Medicaid Services (CMS) The federal agency within the Department of Health and Human Services that administers the Medicare program. Chief Compliance Officer An associate responsible for the overall compliance program for Health Net, Inc. Compliance Program A program that promotes regulatory compliance and legal conduct to provide guidance to prevent, detect and help resolve non-compliant and illegal conduct, including fraud, waste or abuse. The Department (DHHS) of Health and Human Services The federal department that oversees CMS, and administers many of the "social" programs at the Federal level dealing with the health and welfare of the citizens of the United States. Downstream Entity Any party that enters into a written arrangement, acceptable to CMS, below the level of the arrangement between Health Net and a first tier entity. These written arrangements continue down to the level of ultimate provider of health, pharmacy and/or administrative services to members. First Tier Entity Any party that enters into a written arrangement acceptable to CMS with Health Net to provide administrative services or health care or pharmacy services for a Medicare eligible individual under a MA or Part D Plan. Health Net The term Health Net for the purpose of this Policy and Procedure is applicable for Health Net, Inc and its various subsidiaries. The term will also include delegates, such as providers, Third Party Administrators, or other entities who have been delegated responsibility for activities defined in this policy. Health Net Inc. is the parent company. Health Net Medicare Compliance Plan A written document that defines the specific manner in which the enterprise-wide Compliance Program is implemented across the organization for the Medicare Advantage (MA) and Part D lines of business. Medicare The federal health insurance program for people 65 years of age or older, certain younger people with disabilities, and people with End Stage Renal Disease (ESRD). Medicare Advantage (MA) Also referred to as Medicare Part C, is a program offered to Medicare beneficiaries by private companies which work in conjunction with Medicare and cover the full range of hospital and doctor services covered in Original Medicare. Medicare Advantage (MA) Organization

5 Page 5 of 5 A public or private entity organized and licensed by a state as a risk-bearing entity (with the exception of provider sponsored organization receiving waivers) that is certified by CMS as meeting the Medicare Advantage contract requirements. Medicare Advantage Prescription Drug Plan (MA-PD) An MA plan that provides qualified prescription drug coverage. Medicare Compliance: Officer A Health Net associate responsible, either directly or through delegation, for overseeing the MA and Part D compliance program and operations and for developing, operating, and monitoring the fraud, waste and abuse program Medicare Drug Integrity Contractor (MEDIC) An organization that the CMS has contracted with to perform specific program integrity functions for Part D under the Medicare Integrity Program. The MEDIC is CMS designee to manage CMS audit, oversight, and anti-fraud and abuse efforts in the Part D benefit. Office of the Inspector General (OIG) The OIG conducts and supervises audits and investigations relating to programs and operations of the DHHS. Part D Also referred to as Medicare prescription drug coverage, is a voluntary program offered to Medicare beneficiaries by private companies to subsidize the cost of prescription drugs. Part D Plan Sponsor Refers to an organization offering a PDP, MA or MA-PD plan, a PACE organization offering a PACE plan including qualified prescription drug coverage, and a cost plan offering qualified prescription drug coverage. This includes employer- and union-sponsored plans. Prescription Drug Plan (PDP) Prescription drug coverage that is offered under a policy, contract, or plan that has been approved as specified in 42 C.F.R to offer qualified prescription drug coverage. Related Entities Any entity that is related to Health Net by common ownership or control and performs some of Health Net s management functions under contract or delegation, furnishes services to Medicare enrollees under an oral or written agreement. Subsidiaries Legal entities that report to or are owned by a parent company. Approvers: Functional Owner: Nancy A Starts - Approved on 0 Executive Owner: Gay Ann Williams - Approved on 0 Active Policy Disclaimer Please note: This copy of this policy is current as of the date printed. To be assured that you are viewing the currently active policy, please refer to Health Net's National Policy Library site. Date Printed: 0 09:28:22 AM

National Policy Library Document

National Policy Library Document Page 1 of 11 National Policy Library Document Policy Name: Medicare Compliance: Compliance Officer and Compliance Committee Policy No.: HR328-133757 Policy Author: Author Title: Author Department: Sheryl

More information

Policy Author: Author Title: Author Department: Reporting

Policy Author: Author Title: Author Department: Reporting E-mail a link to this policy.-> Print this page.-> National Policy Library Document Policy Name: Medicare Compliance Corrective Action Procedures Policy No.: EJ44-83932 Policy Author: Author Title: Author

More information

National Policy Library Document

National Policy Library Document Page 1 of 11 National Policy Library Document Policy Name: Medicare Programs: Compliance Element VII Prompt Response to Detected Offenses Policy No.: EJ44-83932 Policy Author: Author Title: Author Department:

More information

National Policy Library Document

National Policy Library Document Page 1 of 8 National Policy Library Document Policy Name: Medicare Programs: Compliance Element III Training and Education Policy No.: HR329-83615 Policy Author: Author Title: Author Department: Jamee

More information

2012 Medicare Compliance Plan

2012 Medicare Compliance Plan 2012 Medicare Compliance Plan Document maintained by: Gay Ann Williams Medicare Compliance Officer 1 Compliance Plan Governance The Medicare Compliance Plan is updated annually and is approved by the Boards

More information

Anti-Fraud Plan Scripps Health Plan Services, Inc.

Anti-Fraud Plan Scripps Health Plan Services, Inc. 2015 Scripps Health Plan Services, Inc. 2015 Scripps Health Plan Services, Inc. Linda Pantovic, LVN Director Compliance & Performance Improvement Scripps Health Plan Services, Inc. 1/1/2015 Table of Contents

More information

Medicare Advantage and Part D Fraud, Waste and Abuse Compliance Training 2015

Medicare Advantage and Part D Fraud, Waste and Abuse Compliance Training 2015 Medicare Advantage and Part D Fraud, Waste and Abuse Compliance Training 2015 Overview This Medicare Advantage and Part D Fraud, Waste and Abuse Compliance Training for first-tier, downstream and related

More information

ISDN. Over the past few years, the Office of the Inspector General. Assisting Network Members Develop and Implement Corporate Compliance Programs

ISDN. Over the past few years, the Office of the Inspector General. Assisting Network Members Develop and Implement Corporate Compliance Programs Information Bulletin #7 ISDN National Association of Community Health Centers, Inc. INTEGRATED SERVICES DELIVERY NETWORKS SERIES For more information contact Jacqueline C. Leifer, Esq. or Marcie H. Zakheim,

More information

FDRs = "First tier", "Downstream" and "Related" entities 3/8/2017. Session 410: Medicare FDRs and Compliance Programs. Presentation Overview

FDRs = First tier, Downstream and Related entities 3/8/2017. Session 410: Medicare FDRs and Compliance Programs. Presentation Overview Session 410: Medicare FDRs and : What the Feds Expect and Tips for Ensuring Your Organization Satisfies the Requirements HCCA 21 th Annual Compliance Institute Catherine M. Boerner, Boerner Consulting

More information

Office of Compliance & Ethics General Compliance Training JHS Annual Mandatory Education

Office of Compliance & Ethics General Compliance Training JHS Annual Mandatory Education Office of Compliance & Ethics General Compliance Training 2017 JHS Annual Mandatory Education Instructions Slide 2 This presentation is an annual update of the Office of Compliance and Ethics (OCE) training,

More information

October Dear Providers:

October Dear Providers: October 2015 Dear Providers: As a contractor with Centers for Medicare & Medicaid Services (CMS) and a QHP through the U.S. Department of Health and Human Services (HHS) through the Patient Protection

More information

September 3, Dear Provider:

September 3, Dear Provider: September 3, 2014 Dear Provider: As a contractor with Centers for Medicare & Medicaid Services (CMS), Arkansas Blue Cross and Blue Shield are required by the regulations to develop and maintain a compliance

More information

Compliance Program Updated August 2017

Compliance Program Updated August 2017 Compliance Program Updated August 2017 Table of Contents Section I. Purpose of the Compliance Program... 3 Section II. Elements of an Effective Compliance Program... 4 A. Written Policies and Procedures...

More information

TABLE OF CONTENTS DELEGATED GROUPS

TABLE OF CONTENTS DELEGATED GROUPS TABLE OF CONTENTS DELEGATED GROUPS DELEGATION AND ADMINISTRATIVE SERVICES OVERSIGHT... 10-1 ADMINISTRATIVE OVERSIGHT PROGRAM AND PROCESS... 10-2 DELEGATION AND ADMINISTRATIVE SERVICES OVERSIGHT Through

More information

Health Partners Plans Medicare FDR Requirements Frequently Asked Questions (FAQs)

Health Partners Plans Medicare FDR Requirements Frequently Asked Questions (FAQs) Health Partners Plans Medicare FDR Requirements Frequently Asked Questions (FAQs) 1. Why do I need to be trained? The Centers for Medicare & Medicaid Services (CMS) requires Medicare Advantage Organizations

More information

Alignment. Alignment Healthcare

Alignment. Alignment Healthcare Alignment CODE OF CONDUCT Alignment Healthcare Our commitment to ethical conduct and compliance depends on all Alignment Healthcare personnel. If you find yourself in an ethical dilemma or suspect inappropriate

More information

Medicare Advantage and Part D Compliance Training. 42 CFR Parts and

Medicare Advantage and Part D Compliance Training. 42 CFR Parts and Medicare Advantage and Part D Compliance Training 42 CFR Parts 422.503 and 423.504 Background > As a Medicare Advantage (MA) and Part D (PDP) Plan Sponsor ( Sponsor ), Blue Cross and Blue Shield Northern

More information

Inland Empire Health Plan Quality Management Program Description Date: April, 2017

Inland Empire Health Plan Quality Management Program Description Date: April, 2017 Inland Empire Health Plan Quality Management Program Description Date: April, 2017 Page 1 of 35 Table of Contents Introduction.....3 Mission and Vision........3 Section 1: QM Program Overview........4

More information

Current Status: Active PolicyStat ID: Origination: 09/2004 Last Approved: 02/2017 Last Revised: 09/2013 Next Review: 02/2019

Current Status: Active PolicyStat ID: Origination: 09/2004 Last Approved: 02/2017 Last Revised: 09/2013 Next Review: 02/2019 Current Status: Active PolicyStat ID: 3092101 Origination: 09/2004 Last Approved: 02/2017 Last Revised: 09/2013 Next Review: 02/2019 Owner: Policy Area: References: Applicability: Bill Mayher: SVP - Reg

More information

Compliance Program. Life Care Centers of America, Inc. and Its Affiliated Companies

Compliance Program. Life Care Centers of America, Inc. and Its Affiliated Companies Compliance Program Life Care Centers of America, Inc. and Its Affiliated Companies Approved by the Board of Directors on 1/11/2017 TABLE OF CONTENTS Page I. Introduction... 1 II. General Compliance Statement...

More information

BOARD OF COOPERATIVE EDUCATIONAL SERVICES SOLE SUPERVISORY DISTRICT FRANKLIN-ESSEX-HAMILTON COUNTIES MEDICAID COMPLIANCE PROGRAM CODE OF CONDUCT

BOARD OF COOPERATIVE EDUCATIONAL SERVICES SOLE SUPERVISORY DISTRICT FRANKLIN-ESSEX-HAMILTON COUNTIES MEDICAID COMPLIANCE PROGRAM CODE OF CONDUCT BOARD OF COOPERATIVE EDUCATIONAL SERVICES SOLE SUPERVISORY DISTRICT FRANKLIN-ESSEX-HAMILTON COUNTIES MEDICAID COMPLIANCE PROGRAM CODE OF CONDUCT Adopted April 22, 2010 BOARD OF COOPERATIVE EDUCATIONAL

More information

When the Auditors Get Audited

When the Auditors Get Audited When the Auditors Get Audited Lisa Jensen, MHBL, FACMPE, CPC April 11, 2016 Disclaimer These educational materials were current at the time they were published and created. They were prepared as tools

More information

Hospice Program Integrity Recommendations

Hospice Program Integrity Recommendations Hospice Program Integrity Recommendations Projected increases in the elderly population and the number of Medicare beneficiaries will likely result in continued growth in utilization of hospice services.

More information

Clinton County Corporate Compliance Plan

Clinton County Corporate Compliance Plan Prepared by: Nursing Home Administrator Director of Mental Health and Addiction Director of Public Health County Administrator Clinton County Corporate Compliance Plan Reviewed and updated: December, 2017

More information

Independent Living Systems. Code of Ethics & Supporting Documentation For Providers and Subcontractors ILS_COE_FDR

Independent Living Systems. Code of Ethics & Supporting Documentation For Providers and Subcontractors ILS_COE_FDR Independent Living Systems Code of Ethics & Supporting Documentation For Providers and Subcontractors Rev. 12/2016 www.ilshealth.com Contents ILS Vision, Mission, and Values... 1 Code of Ethics for First

More information

COMPLIANCE PLAN PRACTICE NAME

COMPLIANCE PLAN PRACTICE NAME COMPLIANCE PLAN PRACTICE NAME Table of Contents Article 1: Introduction A. Commitment to Compliance B. Overall Coordination C. Goal and Scope D. Purpose Article 2: Compliance Activities Overall Coordination

More information

Clinical Compliance Program

Clinical Compliance Program Clinical Compliance Program The University at Buffalo School of Dental Medicine, Daniel Squire Diagnostic and Treatment Center (UBSDM) has always been and remains committed to conducting its business in

More information

Compliance Plan. Table of Contents. Introduction... 3

Compliance Plan. Table of Contents. Introduction... 3 Compliance Plan Compliance Plan Table of Contents Introduction... 3 Administrative Structure... 4 A. CorporateCompliance Officer... 4 B. Compliance Committee... 5 C. Hospital Compliance Officer Communications...

More information

ARNOLD & PORTER UPDATE

ARNOLD & PORTER UPDATE ARNOLD & PORTER UPDATE Guide for Pharmaceutical Industry October 2002 On Monday, September 30, 2002, the Office of Inspector General, U.S. Department of Health and Human Services ( HHS OIG or OIG ) released

More information

STANDARDS OF CONDUCT SCH

STANDARDS OF CONDUCT SCH STANDARDS OF CONDUCT SCH01242018 2018 LETTER FROM THE CEO Welcome, Thank you for choosing St. Croix Hospice. The care you provide impacts our patients, families, caregivers, and countless others every

More information

PHILADELPHIA COLLEGE OF OSTEOPATHIC MEDICINE COMPLIANCE AND ETHICS PROGRAM MANUAL

PHILADELPHIA COLLEGE OF OSTEOPATHIC MEDICINE COMPLIANCE AND ETHICS PROGRAM MANUAL PHILADELPHIA COLLEGE OF OSTEOPATHIC MEDICINE COMPLIANCE AND ETHICS PROGRAM MANUAL I. COMPLIANCE AND ETHICS PROGRAM BACKGROUND Philadelphia College of Osteopathic Medicine (PCOM) is committed to upholding

More information

UNIVERSITY OF ROCHESTER MEDICAL CENTER BILLING COMPLIANCE PLAN

UNIVERSITY OF ROCHESTER MEDICAL CENTER BILLING COMPLIANCE PLAN UNIVERSITY OF ROCHESTER MEDICAL CENTER BILLING COMPLIANCE PLAN Revised December 31, 1998 INTRODUCTION This plan is an integral part of the University s ongoing efforts to achieve compliance with federal

More information

Critical Access Hospitals & Compliance Programs. Gregory N. Etzel, Esq. B. Scott McBride, Esq. Health Industry Group Vinson & Elkins LLP

Critical Access Hospitals & Compliance Programs. Gregory N. Etzel, Esq. B. Scott McBride, Esq. Health Industry Group Vinson & Elkins LLP Critical Access Hospitals & Compliance Programs Gregory N. Etzel, Esq. B. Scott McBride, Esq. Health Industry Group Vinson & Elkins LLP History and Background Critical Access Hospitals ( CAH )were established

More information

JOHNS HOPKINS HEALTHCARE

JOHNS HOPKINS HEALTHCARE Page 1 of 5 ACTION Revised Policy Superseding Policy Number: Repealing Policy Number: POLICY: 1. Johns Hopkins HealthCare LLC (JHHC) ensures that individual/ organizational practitioners continue to meet

More information

Fraud, Abuse, & Waste, Oh My! Developing an Effective Compliance Program

Fraud, Abuse, & Waste, Oh My! Developing an Effective Compliance Program Fraud, Abuse, & Waste, Oh My! Developing an Effective Compliance Program Program speaker The speaker for this program is Arlene Luu, RN, BSN, JD, CPHRM, Senior Patient Safety & Risk Consultant, MedPro

More information

Institutional Handbook of Operating Procedures Policy

Institutional Handbook of Operating Procedures Policy Section: Compliance Policies Subject: Coding and Billing Institutional Handbook of Operating Procedures Policy 06.00.02 Responsible Vice President: VP and Chief Compliance Officer Responsible Entity: Office

More information

Provider Relations Training

Provider Relations Training Cal MediConnect Provider Relations Training Presented by Victor Gonzalez and George Scolari Provider Relations Training Agenda Overview of Cal MediConnect Eligibility & Exclusions Enrollment & Disenrollment

More information

Compliance Program, Code of Conduct, and HIPAA

Compliance Program, Code of Conduct, and HIPAA Compliance Program, Code of Conduct, and HIPAA Agenda Introduction to Compliance The Compliance Program Code of Conduct Reporting Concerns HIPAA Why have a Compliance Program Procedures to follow applicable

More information

How to Overhaul your Internal Structure to be Prepared for the New Home Health CoPs. Program Objectives

How to Overhaul your Internal Structure to be Prepared for the New Home Health CoPs. Program Objectives How to Overhaul your Internal Structure to be Prepared for the New Home Health CoPs 2015 NAHC Annual Meeting 106 October 28, 4:30 5:30 p.m. Nashville, Tennessee Kathleen Spooner, RN, CMC Kathleen A. Hessler,

More information

Recover Health Training. Corporate Compliance Plan Code of Conduct Fraud & Abuse

Recover Health Training. Corporate Compliance Plan Code of Conduct Fraud & Abuse Recover Health Training Corporate Compliance Plan Code of Conduct Fraud & Abuse 1 The Course Objectives When you complete this course you will be able to: Understand Recover Health s reasons for implementing

More information

THE MONTEFIORE ACO CODE OF CONDUCT

THE MONTEFIORE ACO CODE OF CONDUCT THE MONTEFIORE ACO CODE OF CONDUCT 2017 Approved by the Board of Directors on March 10, 2017 Our Commitment to Compliance As a central part of its Compliance Program, the Bronx Accountable Healthcare Network

More information

Ashland Hospital Corporation d/b/a King s Daughters Medical Center Corporate Compliance Handbook

Ashland Hospital Corporation d/b/a King s Daughters Medical Center Corporate Compliance Handbook ( Medical Center ) conducts itself in accord with the highest levels of business ethics and in compliance with applicable laws. This goal can be achieved and maintained only through the integrity and high

More information

Managing employees include: Organizational structures include: Note:

Managing employees include: Organizational structures include: Note: Nursing Home Transparency Provisions in the Patient Protection and Affordable Care Act Compiled by NCCNHR: The National Consumer Voice for Quality Long-Term Care, April 2010 Part I Improving Transparency

More information

Health Choice Compliance Program Subcontractor Reporting Guide

Health Choice Compliance Program Subcontractor Reporting Guide Health Choice Compliance Program Subcontractor Reporting Guide Last Revised: June 2017 1 Reporting Guide Table of Contents 1. Purpose of this Guide (page 3) 2. Reportable Compliance Events (page 4) 3.

More information

COMPLIANCE PROGRAM MANUAL

COMPLIANCE PROGRAM MANUAL COMPLIANCE PROGRAM MANUAL MARCH 2018 STANDARDS OF CONDUCT AND COMPLIANCE HUNTINGTON HOSPITAL COMPLIANCE PROGRAM MANUAL 2 COMPLIANCE PROGRAM MANUAL TABLE OF CONTENTS Section Title Page Preface 4 The Compliance

More information

INLAND EMPIRE HEALTH PLAN CODE OF BUSINESS CONDUCT AND ETHICS. Our shared commitment to honesty, integrity, transparency and accountability

INLAND EMPIRE HEALTH PLAN CODE OF BUSINESS CONDUCT AND ETHICS. Our shared commitment to honesty, integrity, transparency and accountability INLAND EMPIRE HEALTH PLAN CODE OF BUSINESS CONDUCT AND ETHICS Our shared commitment to honesty, integrity, transparency and accountability UPDATED: February 2014 TABLE OF CONTENTS Topic Page A. The IEHP

More information

Highlights of Program Integrity Provisions Managed Care Delivery System Subcommittee June 9, 2011

Highlights of Program Integrity Provisions Managed Care Delivery System Subcommittee June 9, 2011 Patient Protection and Affordable Care Act: Highlights of Program Integrity Provisions Managed Care Delivery System Subcommittee June 9, 2011 1 Provider Screening and Other Enrollment Requirements Provider

More information

Preventing Fraud and Abuse in Health Care

Preventing Fraud and Abuse in Health Care Preventing Fraud and Abuse in Health Care Corporate Compliance what is it? Corporate Compliance is about the effort to fight healthcare fraud and abuse by making it a state and federal criminal offense

More information

Pharmacies Medicare Part D Training Obligations and Medicare Training Resources

Pharmacies Medicare Part D Training Obligations and Medicare Training Resources Pharmacies Medicare Part D raining Obligations and Medicare raining Resources. Your obligation - MS regulations require that all pharmacies contracted with Medicare Part D Plan Sponsors, such as the Medco

More information

Compassionate Care Hospice

Compassionate Care Hospice GOVERNING BODY AUTHORIZATION... 3 Compliance Program Introduction... 4 Compliance Officer Introduction... 5 COMPLIANCE POLICY... 6 COMPLIANCE PLAN... 7 COMPLIANCE PROGRAM... 8 Compliance officer... 8 Compliance

More information

Department of Health and Human Services. Centers for Medicare & Medicaid Services. Medicaid Integrity Program

Department of Health and Human Services. Centers for Medicare & Medicaid Services. Medicaid Integrity Program Department of Health and Human Services Centers for Medicare & Medicaid Services Medicaid Integrity Program California Comprehensive Program Integrity Review Final Report Reviewers: Jeff Coady, Review

More information

What OMIG Looks for in a Compliance Program Review Compliance Program Review Guidance of October 26, 2016

What OMIG Looks for in a Compliance Program Review Compliance Program Review Guidance of October 26, 2016 What OMIG Looks for in a Compliance Program Review Compliance Program Review Guidance of October 26, 2016 March 8, 2017 Latham, NY LeadingAge New York March 8, 2017 2 The Fine Print OMIG acknowledges that

More information

Compliance Program Guidance for General Hospitals

Compliance Program Guidance for General Hospitals NEW YORK STATE DEPARTMENT OF HEALTH Office of the Medicaid Inspector General Compliance Program Guidance for General Hospitals James C. Cox, Medicaid Inspector General Issue Date: May 11, 2012 Compliance

More information

Compliance Program And Code of Conduct. United Regional Health Care System

Compliance Program And Code of Conduct. United Regional Health Care System Compliance Program And Code of Conduct United Regional Health Care System TABLE OF CONTENTS Page MESSAGE FROM OUR PRESIDENT... 1 COMPLIANCE PROGRAM... 2 Program Structure...2 Management s Responsibilities

More information

Managed Care Fraud: Enforcement and Compliance HCCA Compliance Institute March 28, 2017

Managed Care Fraud: Enforcement and Compliance HCCA Compliance Institute March 28, 2017 Managed Care Fraud: Enforcement and Compliance HCCA Compliance Institute March 28, 2017 Pamela Coyle Brecht, Partner Pietragallo Gordon Alfano Bosick & Raspanti, LLP Risk Area: False Data and/or Certifications

More information

Patient Compl p ai l n ai t n s/ s G / r G ie i vanc van es

Patient Compl p ai l n ai t n s/ s G / r G ie i vanc van es Patient Complaints/Grievances What all Employees Need to Know MCMH strongly encourages patients and/or the patient s representative to exercise their right to issue a complaint. Patients and families can

More information

FLORIDA DEPARTMENT OF ENVIROMENTAL PROTECTION

FLORIDA DEPARTMENT OF ENVIROMENTAL PROTECTION FLORIDA DEPARTMENT OF ENVIROMENTAL PROTECTION Office of Inspector General Report No. A-1011EOG-012 Final Report Date: April 2011 Overview The Office of Inspector General (OIG) participated in the State

More information

ALABAMA MEDICAID AGENCY ADMINISTRATIVE CODE CHAPTER 560-X-45 MATERNITY CARE PROGRAM TABLE OF CONTENTS

ALABAMA MEDICAID AGENCY ADMINISTRATIVE CODE CHAPTER 560-X-45 MATERNITY CARE PROGRAM TABLE OF CONTENTS ALABAMA MEDICAID AGENCY ADMINISTRATIVE CODE CHAPTER 560-X-45 MATERNITY CARE PROGRAM TABLE OF CONTENTS 560-X-45-.01 560-X-45-.02 560-X-45-.03 560-X-45-.04 560-X-45-.05 560-X-45-.06 560-X-45-.07 560-X-45-.08

More information

The Purpose of this Code of Conduct

The Purpose of this Code of Conduct The Purpose of this Code of Conduct This Code of Conduct provides a framework to guide us in meeting our obligations as employees and volunteers of HPC Healthcare, Inc., and its current and future affiliates,

More information

Agency Information Collection Activities: Proposed Collection; Comment Request

Agency Information Collection Activities: Proposed Collection; Comment Request This document is scheduled to be published in the Federal Register on 08/27/2018 and available online at https://federalregister.gov/d/2018-18523, and on govinfo.gov DEPARTMENT OF HEALTH AND HUMAN SERVICES

More information

FLORIDA LICENSURE SURVEY PREP

FLORIDA LICENSURE SURVEY PREP FLORIDA LICENSURE SURVEY PREP This information is intended to provide an abbreviated version of the Florida licensure requirements in preparation for an ACHC licensure survey. For a complete listing of

More information

RULES OF DEPARTMENT OF HEALTH DIVISION OF HEALTH CARE FACILITIES CHAPTER STANDARDS FOR QUALITY OF CARE FOR HEALTH MAINTENANCE ORGANIZATIONS

RULES OF DEPARTMENT OF HEALTH DIVISION OF HEALTH CARE FACILITIES CHAPTER STANDARDS FOR QUALITY OF CARE FOR HEALTH MAINTENANCE ORGANIZATIONS RULES OF DEPARTMENT OF HEALTH DIVISION OF HEALTH CARE FACILITIES CHAPTER 1200-8-33 STANDARDS FOR QUALITY OF CARE FOR HEALTH TABLE OF CONTENTS 1200-8-33-.01 Definitions 1200-8-33-.04 Surveys of Health Maintenance

More information

Medicare Fraud & Abuse: Prevention, Detection, and Reporting ICN

Medicare Fraud & Abuse: Prevention, Detection, and Reporting ICN Medicare Fraud & Abuse: Prevention, Detection, and Reporting ICN 908103 1 Disclaimers This presentation was current at the time it was published or uploaded onto the web. Medicare policy changes frequently

More information

1.Cultural & Linguistic Competence. 2.Model of Care for Special Needs Patients. 3.Combating Medicare Fraud, Waste and Abuse. Revised January 2017

1.Cultural & Linguistic Competence. 2.Model of Care for Special Needs Patients. 3.Combating Medicare Fraud, Waste and Abuse. Revised January 2017 Corporate Compliance Training: 1.Cultural & Linguistic Competence 2.Model of Care for Special Needs Patients 3.Combating Medicare Fraud, Waste and Abuse Revised January 2017 1 This training presentation

More information

Government Focus in Home Health

Government Focus in Home Health Government Focus in Home Health November 8, 2011 Cheryl Golden Director Deloitte & Touche LLP Contents Current Regulatory Focus in Home Health Government Programs HHS OIG Work Plan 2012 Auditing and Monitoring

More information

Humana At Home-Star Member Talking Points

Humana At Home-Star Member Talking Points At Home-Star Member Talking Points What are the CMS Medicare Star Ratings? The Center for Medicare & Medicaid Services (CMS) is a federal agency that oversees Medicare & Medicaid, and is part of the Department

More information

Subtitle E New Options for States to Provide Long-Term Services and Supports

Subtitle E New Options for States to Provide Long-Term Services and Supports LONG TERM CARE (SECTION-BY-SECTION ANALYSIS) (Information compiled from the Democratic Policy Committee (DPC) Report on The Patient Protection and Affordable Care Act and the Health Care and Education

More information

Agenda AN EFFECTIVE COMPLIANCE PROGRAM 3/17/2015. Quality Meets Compliance :

Agenda AN EFFECTIVE COMPLIANCE PROGRAM 3/17/2015. Quality Meets Compliance : Quality Meets Compliance : An Integrated Approach to Improving Quality and Reducing Exposure in Health Care Lynn Barrett, J.D., CHC VP & Chief Compliance & Ethics Officer, Jackson Health System Peter Paige,

More information

Compliance Program Code of Conduct

Compliance Program Code of Conduct City and County of San Francisco Department of Public Health Compliance Program Code of Conduct Purpose of our Code of Conduct The Department of Public Health of the City and County of San Francisco is

More information

2018 Northern California HMO Provider Manual Kaiser Foundation Health Plan, Inc.

2018 Northern California HMO Provider Manual Kaiser Foundation Health Plan, Inc. 2018 Northern California HMO Provider Manual Kaiser Foundation Health Plan, Inc. Welcome from Kaiser Permanente It is our pleasure to welcome you as a contracted provider (Provider) participating under

More information

RUTGERS BIOMEDICAL AND HEALTH SCIENCES CODE OF CON DU CT

RUTGERS BIOMEDICAL AND HEALTH SCIENCES CODE OF CON DU CT RUTGERS BIOMEDICAL AND HEALTH SCIENCES CODE OF CONDUCT PREAMBLE On August 22, 2012, Governor Chris Christie signed legislation into law known as the New Jersey Medical and Health Sciences Education Restructuring

More information

Delegation Oversight 2016 Audit Tool Credentialing and Recredentialing

Delegation Oversight 2016 Audit Tool Credentialing and Recredentialing Att CRE - 216 Delegation Oversight 216 Audit Tool Review Date: A B C D E F 1 2 C3 R3 4 5 N/A N/A 6 7 8 9 N/A N/A AUDIT RESULTS CREDENTIALING ASSESSMENT ELEMENT COMPLIANCE SCORE CARD Medi-Cal Elements Medi-Cal

More information

Foundations Health Solutions Nursing Facility Integrity Manual Revised August 2017

Foundations Health Solutions Nursing Facility Integrity Manual Revised August 2017 Foundations Health Solutions Nursing Facility Integrity Manual Revised August 2017 T A B L E O F C O N T E N T S Our Commitment to Integrity... 3 1.0 Code of Ethics... 5 2.0 Reporting & Response (Disclosure

More information

OneWorld Community Health Centers Policy and Procedure

OneWorld Community Health Centers Policy and Procedure TITLE: Corporate Compliance Program and Policy APPLICABLE STANDARDS: RI.01.01.01, HR.01.05.03 EC.02.01.01, EC.02.01.01 OBJECTIVE: To establish guidelines to ensure professional and ethical behavior for

More information

The Impact on Compliance

The Impact on Compliance Highlights of the CMS Final Rule: The Impact on Compliance 21 st Annual Compliance Institute March 27, 2017 Presenters: Kris D Ann Maples and Lyn Bentley Kris D Ann Maples, Esq. 19 years in Healthcare

More information

Rhode Island Department of Health Office of Immunization

Rhode Island Department of Health Office of Immunization Rhode Island Department of Health Office of Immunization Fraud and Abuse Policy and Procedures The Rhode Island Department of Health (RIDOH) Office of Immunization is required by federal grant to investigate

More information

COMPLIANCE PLAN October, 2014

COMPLIANCE PLAN October, 2014 COMPLIANCE PLAN October, 2014 TABLE OF CONTENTS Introduction...3 I. Code of Conduct...3 A. University of Illinois at Chicago Code of Conduct...3 B. COD Standards of Conduct...4 II. Potential Risk Areas...4

More information

Corporate Core Compliance Education

Corporate Core Compliance Education Corporate Core Compliance Education 2017 Annual Refresher Office of Audit and Compliance Services (ACS) Introduction This education session will increase and enhance your knowledge about key regulations

More information

Chapter 13 Section 1

Chapter 13 Section 1 Program Integrity Chapter 13 Section 1 Revision: 1.0 CONTRACTOR'S PROGRAM INTEGRITY (PI) RESPONSIBILITY 1.1 The contractor shall incorporate into its organizational management philosophy a published corporate

More information

HealthStream Regulatory Script. Corporate Compliance: A Proactive Stance. Version: [February 2007]

HealthStream Regulatory Script. Corporate Compliance: A Proactive Stance. Version: [February 2007] HealthStream Regulatory Script Corporate Compliance: A Proactive Stance Version: [February 2007] Lesson 1: Introduction Lesson 2: Importance of Compliance & Compliance Programs Lesson 3: Laws and Regulations

More information

(Signed original copy on file)

(Signed original copy on file) CFOP 75-8 STATE OF FLORIDA DEPARTMENT OF CF OPERATING PROCEDURE CHILDREN AND FAMILIES NO. 75-8 TALLAHASSEE, September 2, 2015 Procurement and Contract Management POLICIES AND PROCEDURES OF CONTRACT OVERSIGHT

More information

Combating Medicare Parts C and D Fraud, Waste, and Abuse Web-Based Training Course. January 2018

Combating Medicare Parts C and D Fraud, Waste, and Abuse Web-Based Training Course. January 2018 Web-Based Training Course January 2018 1 Medicare Learning Network TABLE OF CONTENTS ACRONYMS... 3 TITLE... 4 INTRODUCTION... 5 LESSON 1: WHAT IS FWA?... 13 LESSON 2: YOUR ROLE IN THE FIGHT AGAINST FWA...

More information

Using Internal Audits for Successful Grant Administration

Using Internal Audits for Successful Grant Administration Using Internal Audits for Successful Grant Administration Welcome & Speakers Session Objectives Explain key rules and requirements for complying with CDBG-DR Internal Audit requirements Discuss role of

More information

Current Status: Active PolicyStat ID: COPY CONTRACTOR, MEDICAL STAFF, REFERRAL SOURCE AND EMPLOYEE SCREENING POLICY

Current Status: Active PolicyStat ID: COPY CONTRACTOR, MEDICAL STAFF, REFERRAL SOURCE AND EMPLOYEE SCREENING POLICY Current Status: Active PolicyStat ID: 4305040 Origination: 01/2015 Last Approved: 11/2017 Last Revised: 11/2017 Next Review: 11/2018 Owner: Julie Groves: Compliance Office Policy Area: Compliance References:

More information

DISA INSTRUCTION March 2006 Last Certified: 11 April 2008 ORGANIZATION. Inspector General of the Defense Information Systems Agency

DISA INSTRUCTION March 2006 Last Certified: 11 April 2008 ORGANIZATION. Inspector General of the Defense Information Systems Agency DEFENSE INFORMATION SYSTEMS AGENCY P. O. Box 4502 ARLINGTON, VIRGINIA 22204-4502 DISA INSTRUCTION 100-45-1 17 March 2006 Last Certified: 11 April 2008 ORGANIZATION Inspector General of the Defense Information

More information

A 12-Step Program to Better Compliance: A Practical Approach

A 12-Step Program to Better Compliance: A Practical Approach A 12-Step Program to Better Compliance: A Practical Approach Kim Harvey Looney Anna M. Grizzle 615.850.8722 615.742.7732 kim.looney@wallerlaw.com agrizzle@bassberry.com 11389849 Strict Government Compliance

More information

Provider Relations currently is the public relations arm, for providers, of the Provider Operations

Provider Relations currently is the public relations arm, for providers, of the Provider Operations Provider OPERations 6.1 Provider Relations Provider Relations currently is the public relations arm, for providers, of the Provider Operations Department. Provider Relations consists of a group of Provider

More information

HCCA Annual Institute

HCCA Annual Institute HCCA - 2013 Annual Institute University of Medicine and Dentistry of New Jersey (UMDNJ) Compliance after Deferred Prosecution Bret S. Bissey, FACHE, MBA, CHC, CMPE Senior Vice President, Chief Ethics and

More information

April, 2007 QUESTIONABLE PRACTICES BY HOSPICES AND NURSING HOMES UNDER HEALTH CARE FRAUD AND ABUSE RULES

April, 2007 QUESTIONABLE PRACTICES BY HOSPICES AND NURSING HOMES UNDER HEALTH CARE FRAUD AND ABUSE RULES HOSPICE AND PALLIATIVE CARE PRACTICE GROUP: Mary H. Michal, Chair Linda Dawson Meg S.L. Pekarske Matthew K. McManus LONG TERM CARE AND SENIOR HOUSING PRACTICE GROUP: Robert J. Heath, Chair Burton A. Wagner

More information

San Francisco Department of Public Health

San Francisco Department of Public Health San Francisco Department of Public Health Barbara A. Garcia, MPA Director of Health City and County of San Francisco Edwin M. Lee, Mayor San Francisco Department of Public Health Policy & Procedure Detail*

More information

Administrative services which may be delegated to IPAs, Medical Groups, Vendors, or other organizations include:

Administrative services which may be delegated to IPAs, Medical Groups, Vendors, or other organizations include: Delegation Delegation This section contains information specific to medical groups, Independent Practice Associations (IPA), and Vendors contracted with Molina to provide medical care or services to Members,

More information

UNDERSTANDING OUR CODE OF CONDUCT...4 OUR RELATIONSHIP WITH THOSE WE SERVE...5 OUR RELATIONSHIP WITH PHYSICIANS AND OTHER HEALTH CARE PROVIDERS...

UNDERSTANDING OUR CODE OF CONDUCT...4 OUR RELATIONSHIP WITH THOSE WE SERVE...5 OUR RELATIONSHIP WITH PHYSICIANS AND OTHER HEALTH CARE PROVIDERS... Code of Conduct Code of Ethics Table of Contents UNDERSTANDING OUR CODE OF CONDUCT...4 OUR RELATIONSHIP WITH THOSE WE SERVE...5 OUR RELATIONSHIP WITH PHYSICIANS AND OTHER HEALTH CARE PROVIDERS...7 OUR

More information

AGENCY FOR PERSONS WITH DISABILITIES OFFICE OF INSPECTOR GENERAL ANNUAL REPORT JULY 1, 2013 JUNE 30, 2014

AGENCY FOR PERSONS WITH DISABILITIES OFFICE OF INSPECTOR GENERAL ANNUAL REPORT JULY 1, 2013 JUNE 30, 2014 Barbara Palmer Director Carol Sullivan Inspector General AGENCY FOR PERSONS WITH DISABILITIES OFFICE OF INSPECTOR GENERAL ANNUAL REPORT JULY 1, 2013 JUNE 30, 2014 FLORIDA CAPTIAL, APRIL 2, 2014, AUTISM

More information

NETWORK POLICY & PROCEDURE Page 1 of 6 REPORTING COMPLIANCE AND HIPAA CONCERNS AND PROBLEM RESOLUTION

NETWORK POLICY & PROCEDURE Page 1 of 6 REPORTING COMPLIANCE AND HIPAA CONCERNS AND PROBLEM RESOLUTION NETWORK POLICY & PROCEDURE Page 1 of 6 APPROVED FOR: COMMUNITY HEALTH NETWORK FOUNDATION, INC. COMMUNITY HEALTH NETWORK, INC. COMMUNITY HOME HEALTH SERVICES, INC. COMMUNITY HOSPITAL SOUTH, INC. COMMUNITY

More information

IU ClinicalTrials.gov: Compliance Program Plan

IU ClinicalTrials.gov: Compliance Program Plan Table of Contents Introduction 3 Section I Requirements and Recommendations A. FDAAA 801 Requirements 3 B. ICMJE Publication Requirements 4 C. CMS Billing Requirements 4 D. NIH Recommendations 4 E. IU

More information

As promised in the 2006 statute1 and accompanying

As promised in the 2006 statute1 and accompanying New York Issues Compliance Guidance for Hospitals A Look at How the Guidance Stacks Up to OIG Recommendations Jack Wenik / Matthew McKennan Jack Wenik is a member er of the firm Sills, Cummis mis & Gross

More information

AHCA Continues to Expand Medicaid Program Integrity Efforts; Establishing Performance Criteria Would Be Beneficial

AHCA Continues to Expand Medicaid Program Integrity Efforts; Establishing Performance Criteria Would Be Beneficial January 2018 Report No. 18-03 AHCA Continues to Expand Medicaid Program Integrity Efforts; Establishing Performance Criteria Would Be Beneficial at a glance Since OPPAGA s 2016 review, the Bureau of Medicaid

More information

Federal Update Healthcare Fraud, Waste, and Abuse

Federal Update Healthcare Fraud, Waste, and Abuse Federal Update Healthcare Fraud, Waste, and Abuse Steven Ryan Special Agent In Charge Lori Ahlstrand Regional Inspector General June 2017 1 Overview Understanding the role of the HHS OIG Recent cases and

More information

CMS Technology: Accomplishments and Challenges

CMS Technology: Accomplishments and Challenges CMS Technology: Accomplishments and Challenges Henry Chao, Acting Chief Technology Officer (CTO), Centers for Medicare & Medicaid Services (CMS) Northern Virginia Technology Council (NVTC) February 12,

More information

The New Corporate Integrity Agreements: What Did the Board Know and When Did They Know It?

The New Corporate Integrity Agreements: What Did the Board Know and When Did They Know It? The New Corporate Integrity Agreements: What Did the Board Know and When Did They Know It? Malcolm J. Harkins Center for Health Law Studies St. Louis University School of Law 2015 by Malcolm J. Harkins

More information