Compliance Round-Up. March 11, 2014
|
|
- Roderick Copeland
- 5 years ago
- Views:
Transcription
1 Compliance Round-Up March 11, 2014 Medicare Billing Settlement, HIPAA Guidance Mental Health Information, HIPAA Settlement, Two Midnight Rule Legislation, HCFAC Report, Halifax Settlement 1
2 Faculty Brian Annulis, JD, CHC Managing Director, Aegis Compliance & Ethics Center, LLP Ryan D. Meade, JD, CHRC Managing Director, Aegis Compliance & Ethics Center, LLP
3 Continuing Goals The goals of the Compliance Round-Up Webinars: Teaching/knowledge transfer Keep you up to date on compliance rules Practical points Assist organizations to develop in-house methods of managing Please share your thoughts, suggestions (and criticisms) 3 3
4 Compliance Round-Up: Webinar Overview Administrative Matters Monthly on the 2 nd Tuesday of the month No charge! (feel free to spread the word.) Each session will be minutes in duration Each session will begin at 12:00 PM CT If you are unable to participate in the live discussion, each session will be recorded and made available in MP3 format 4 4
5 Today s Topics/Agenda 1. Medicare Billing Settlement 2. HIPAA Guidance Mental Health Information 3. HIPAA Settlement 4. Two Midnight Rule Legislation 5. HCFAC Report 6. Halifax Settlement 5
6 Medicare Billing Settlement On February 18, 2014 US Attorney in Maryland and the OIG announced a FCA settlement with Engage Medical, Inc., its owner Sanjay Puri and three medical practices that were its clients The parties agreed to pay a total of $3,340,979 to resolve claims that Engage Medical overbilled for nuclear stress tests. The allegations resolved in the settlement agreement involve overbilling of nuclear stress tests between July 31, 2007 and March 8,
7 Medicare Billing Settlement Engage Medical contracted with physicians and physician practices, holding itself out as having expertise in medical billing. Engage Medical staff would obtain records from physician clients related to the medical services provided, and transmit that information to staff in India, where medical coders would apply the relevant CPT codes and bill applicable insurance, including Medicare and other federally funded health insurance programs. 7
8 Medicare Billing Settlement Engage Medical marketed the stress tests to general practitioners, persuading them that instead of referring the patients to cardiologists for these tests, Engage could arrange to have the testing service performed in the general practitioner s offices and bill for the tests, all of which would increase the general practitioners incomes. Dr. Muttath and Dr. Gill, two internists, agreed to allow Engage to provide this service. 8
9 Medicare Billing Settlement According to the government s press release, Engage Medical s billing of these tests, however, was false and in direct contradiction to published materials about such medical billing. The government argued that Engage Medical systematically billed for each service twice, using a CPT code modifier intended to be used when the service had been repeated by the same physician or when a distinct service was performed on the same day. The government s position was that none of the tests were repeated and none of the tests was a distinct procedural service. 9
10 Medicare Billing Settlement The government alleged further that Engage Medical also included with its billing a CPT code that was intended to be used for interpreting and reporting images, even though proper CPT coding for a nuclear stress test already compensated the physician for interpreting and reporting the tests results (i.e., unbundling). In its unbundling, the government alleged that Engage Medical ignored the plain language in the applicable CPT coding manuals that specifically told coders not to use the reporting and interpretation CPT codes when billing for nuclear stress tests. 10
11 Medicare Billing Settlement The government also alleged that in 2009, Engage Medical contracted with Advanced Cardiology Center and its three physician owners: Pankaj Lal, M.D., Mubashar Choudry, M.D. and Moshin Ijaz, M.D. Advanced Cardiology hired Engage Medical to re-bill claims for nuclear stress tests that Advanced Cardiology had already performed, billed and been paid for, in some cases years before. 11
12 Medicare Billing Settlement Advanced Cardiology gave Engage Medical access to Advanced Cardiology s billing files and Engage Medical isolated the instances where Advanced Cardiology had performed and been paid for nuclear stress tests. Using its false billing model, Engage Medical resubmitted the nuclear stress tests for payment a second time, using the CPT codes that reflected a distinct or repeat service, and also added the unbundled code for interpretation. 12
13 Medicare Billing Settlement Unlike the internists, however, the government alleged that Advanced Cardiology did not retain Engage Medical to bill claims after February 2010 and thus Advanced Cardiology did not give Engage Medical access to Advanced Cardiology medical records of its patients beyond that time. Rather, Advanced Cardiology employed the Engage Medical model itself, with its own billers applying the false CPT codes to new tests that the cardiologists at Advanced Cardiology performed. 13
14 HIPAA Guidance OCR recently published Guidance concerning when providers may appropriately share the PHI of their mental health patients and provides reminders about HIPAA Privacy Rule issues surrounding mental health records. guidance.html Under 45 C.F.R. Section (b), health care providers may communicate with a patient's family members and friends when the patient does not object and the disclosures are directly relevant to that person's involvement in the patient's care or payment for care. 14
15 HIPAA Guidance Examples A psychiatrist may discuss the drugs a patient needs to take with the patient's sister who is present with the patient at a mental health care appointment; and A therapist may give information to a patient's spouse about warning signs that may signal a developing emergency. 15
16 HIPAA Guidance In the Guidance, OCR also confirms that if a patient is incapacitated, a provider may share information with family and friends when that provider determines, based on professional judgment, that the disclosure is in the patient's best interest. The Guidance emphasizes that providers must abide by the wishes of their adult mental health patients who object to disclosures to friends and family. Nevertheless, OCR reiterates that HIPAA permits providers to warn family members or law enforcement if the provider perceives a serious and imminent threat to the health or safety of the patient or others and the disclosure may reasonably prevent or lessen the risk of harm. 16
17 HIPAA Guidance The Guidance also emphasizes that HIPAA provides extra protection to psychotherapy notes maintained separately since the therapist's personal notes are not required for treatment, payment, or health care operations. Under the Privacy Rule, Providers must obtain a separate authorization to disclose psychotherapy notes with few exceptions. 17
18 HIPAA Settlement On March 7, 2014, OCR announced that Skagit County, Washington agreed to settle potential violations of HIPAA and the Privacy, Security, and Breach Notification Rules. Skagit County agreed to a $215,000 monetary settlement and to work closely with OCR to correct deficiencies in its HIPAA compliance program. This case marks the first settlement with a county government and sends a strong message about the importance of HIPAA compliance to local and county governments, regardless of size, said Susan McAndrew, deputy director of health information privacy at OCR. These agencies need to adopt a meaningful compliance program to ensure the privacy and security of patients information. 18
19 HIPAA Settlement OCR opened an investigation of Skagit County upon receiving a breach report that money receipts with electronic protected health information (ephi) of seven individuals were accessed by unknown parties after the ephi had been inadvertently moved to a publicly accessible server maintained by the County. OCR s investigation revealed a broader exposure of PHI involved in the incident, which included the ephi of 1,581 individuals. Many of the accessible files involved sensitive information, including PHI concerning the testing and treatment of infectious diseases. OCR s investigation further uncovered general and widespread non-compliance by Skagit County with the HIPAA Privacy, Security, and Breach Notification Rules. 19
20 Two Midnight Rule Legislation On March 6, U.S. Senators Robert Menendez (D-NJ) and Deb Fisher (R-NE) introduced the Two-Midnight Rule Coordination and Improvement Act of 2014 (S. 2082), a bipartisan bill to address the ongoing issues surrounding the Two Midnight Rule. The rigid approach currently taken by this rule could lead to instances where a physician is unable to make the proper medical determination for a beneficiary s treatment. Almost immediately after CMS finalized the rule it became clear it was inherently flawed and the rule s enforcement has been delayed on three separate occasions. The current enforcement delay, announced on January 30, 2014, is in effect through September 30,
21 Two Midnight Rule Legislation The Two-Midnight Rule Coordination and Improvement Act seeks to resolve these issue by establishing new guidelines for CMS, in consolation with hospitals, physicians and other experts, to establish criteria and payment methodologies applicable to beneficiaries in need of short inpatient stays. Further, to ensure that hospitals are not subjected to potentially onerous audits while these criteria are being developed, the legislation codifies the enforcement delays CMS has already imposed. 21
22 HCFAC Report The Health Care Fraud and Abuse Control (HCFAC) Program recovered a record-breaking $4.3 billion in taxpayer dollars in fiscal year (FY) 2013, up from $4.2 billion in FY 2012, according to a report released February 26 by DOJ and HHS. According to the HCFAC annual report, in FY 2013, DOJ opened 1,013 new criminal health care fraud investigations involving 1,910 individuals and federal prosecutors had 2,041 health care fraud criminal investigations pending involving 3,535 potential defendants, and filed criminal charges in 480 cases involving 843 defendants. A total of 718 defendants were convicted of health care fraud-related crimes during the year, the report said. 22
23 HCFAC Report DOJ also opened 1,083 new civil health care fraud investigations and had 1,079 civil health care fraud matters pending at the end of the fiscal year, the report said. The report also said for every dollar spent on health care-related fraud and abuse investigations through HCFAC and other programs in the last three years, the government recovered $8.10. This is the highest three-year average return on investment in the 17- year history of the HCFAC Program, the agencies highlighted. 23
24 Halifax Hospital Settlement On March 3, 2014, Halifax Health announced an $85 million settlement with prosecutors that could resolve the first half of a trial over whether the organization's physician compensation deals violate the Stark Law. The settlement still needs finalizing and court approval. Halifax had been preparing for a trial that involved the largest potential damages ever seen in a civil whistleblower case against a single hospital. As much as a billion dollars was on the line. Halifax was about to become one of the few hospitals ever to go trial in such a case, following last year's $237 million judgment against a South Carolina hospital (Toumey) on similar allegations of overpaying doctors. 24
25 Halifax Hospital Settlement Under the settlement, Halifax would resolve the first half of its case out of court, which alleges that the hospital administration illegally compensated a group of nine neurologists and medical oncologists to refer Medicare patients to the hospital. The case was triggered when a former compliance officer who still works at the hospital in a different role, Elin Baklid- Kunz, filed a lawsuit in 2009 accusing Halifax administrators of paying doctors above-market rates and handing out bonuses to the most active doctors using the hospital's share of Medicare funds. If true, both of those arrangements would violate the Stark Law, and if done on purpose or with reckless disregard for the law, the payments would violate the FCA and trigger triple damages 25
26 Halifax Hospital Settlement Even if the settlement is approved, Halifax and Baklid-Kunz are set to litigate a separate but related set of allegations in July that DOJ did not join. Baklid-Kunz said the hospital ignored clear signs that it billed Medicare for inpatient hospital care in cases where the medical need wasn't documented. Hospital officials deny those allegations as well. 26
27 Follow-Up Questions? Next Lecture: Tuesday, April 8,
RECOVERY AUDIT CONTRACTORS
RECOVERY AUDIT CONTRACTORS RAC ROUND-UP SUBSCRIPTION SERVICE Being Proactive Kyphoplasty, CMS Clarifies Effective and Implementation Dates & Changes to Carotid Artery Stenting Coverage January 11, 2011
More informationCOMPLIANCE ROUND-UP. December 13, Aegis Compliance & Ethics Center, LLP 1
COMPLIANCE ROUND-UP December 13, 2011 2011 Aegis Compliance & Ethics Center, LLP 1 Today s Faculty Brian Annulis, JD, CHC Partner, Meade & Roach, LLP 773.907.8343 bannulis@meaderoach.com Ryan Meade, JD,
More informationHIPAA Privacy Rule and Sharing Information Related to Mental Health
HIPAA Privacy Rule and Sharing Information Related to Mental Health Background The Health Insurance Portability and Accountability Act (HIPAA) Privacy Rule provides consumers with important privacy rights
More informationA 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 informationHIPAA Notice of Privacy Practices
HIPAA Notice of Privacy Practices Georgia Mountains Hospice understands that your health information is highly personal and we are committed to safeguarding your privacy. Please read this Notice of Privacy
More informationRECOVERY AUDIT CONTRACTORS
RECOVERY AUDIT CONTRACTORS RAC SUBSCRIPTION SERVICE What are We Learning? May 24, 2011 2011 Aegis Compliance & Ethics Center, LLP 1 Faculty Brian Annulis, JD Partner, Meade & Roach, LLP 773.907.8343 bannulis@meaderoach.com
More informationRecent Developments in Stark and Anti-Kickback Statute Enforcement
Recent Developments in Stark and Anti-Kickback Statute Enforcement Health Care Compliance Association Regional Conference May 18, 2012 Robert Belfort Manatt, Phelps & Phillips, LLP Agenda Overview Lessons
More informationResponding to Today s Health Care Regulatory Environment
Responding to Today s Health Care Regulatory Environment St. Joseph s Health Michael R. Holper SVP, Compliance and Audit Services October 26, 2016 2014 Trinity Health. All Rights Reserved. 1 We operate
More informationThe Department of Justice s Focus on Failure of Care Fraud Cases
The Department of Justice s Focus on Failure of Care Fraud Cases HCCA 17 TH ANNUAL COMPLIANCE INSTITUTE WASHINGTON, DC APRIL 21, 2013 SUSAN C. LYNCH, ESQ. U.S. DEPARTMENT OF JUSTICE SUSAN.LYNCH@USDOJ.GOV
More informationNotice of Privacy Practices for Protected Health Information (PHI)
Notice of Privacy Practices for Protected Health Information (PHI) Dermatology Associates of Colorado, PC THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN
More informationHealthStream 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 informationNotice of Privacy Practices
Notice of Privacy Practices, pg. 1 of 5 Notice of Privacy Practices CATHOLIC CHARITIES OF THE ROMAN CATHOLIC DIOCESE OF SYRACUSE, NY This notice describes the privacy practices of Catholic Charities of
More informationClarifying HIPAA Privacy Rules for Mental Health and Addiction Crises. National Council for Behavioral Health March 19, 2018
Clarifying HIPAA Privacy Rules for Mental Health and Addiction Crises National Council for Behavioral Health March 19, 2018 Webinar Logistics We recommend calling in on your telephone Phone: +1 (562) 247-8422
More informationCAPITAL SURGEONS GROUP, PLLC
CAPITAL SURGEONS GROUP, PLLC NOTICE OF PRIVACY PRACTICES THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW
More informationNOTICE OF PRIVACY PRACTICES
NOTICE OF PRIVACY PRACTICES THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY. WHY ARE YOU GETTING
More informationDiane Meyer, CHC (650) Agenda
The Road Ahead and How to Navigate It Kevin D. Lyles, Esq. kdlyles@jonesday.com (614) 281-3821 Diane Meyer, CHC DMeyer@stanfordmed.org (650) 724-2572 Frank E. Sheeder, Esq. fesheeder@jonesday.com (214)
More informationOREGON HIPAA NOTICE FORM
MARCIA JOHNSTON WOOD, Ph.D. Clinical Psychologist 5441 SW Macadam, #104, Portland, OR 97239 Phone (503) 248-4511/ Fax (503) 248-6385 - Effective Sept.23, 2013 - (This copy for you to keep) OREGON HIPAA
More informationHIPAA-HITECH HELPBOOK NJ Physician Practices
NOTICE OF PRIVACY PRACTICES Montgomery Medical Associates LLC Effective Date: 04/01/13 Version 2 SUMMARY WHAT IS THIS NOTICE FOR? This Notice of Privacy Practices (Notice) describes how Montgomery Medical
More informationCompliance 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 informationHospice House Network Inpatient Conference
Hospice House Network Inpatient t Conference Trends & Recent Developments in Hospice General Inpatient Care Policy and Enforcement June 7, 2013 1 www.morganlewis.com Presented by Howard J. Young, Esq.
More informationHOT TOPICS IN HEALTHCARE FRAUD. Presented by: Jeffrey W. Dickstein and Amy L. Easton Phillips and Cohen LLP
HOT TOPICS IN HEALTHCARE FRAUD Presented by: Jeffrey W. Dickstein and Amy L. Easton Phillips and Cohen LLP Hot Topics in Healthcare Fraud- Agenda FCA 101- the Basics DOJ Recoveries and Statistics Cases
More informationPreparing for the upcoming 2016 HIPAA audits: Lessons and examples from past breaches and fines
Preparing for the upcoming 2016 HIPAA audits: Lessons and examples from past breaches and fines 1 Your Presenters Robert Grant Co-Founder and Chief Strategy Officer of Compliancy Group Over 15 years of
More informationRECOVERY AUDIT CONTRACTORS
RECOVERY AUDIT CONTRACTORS RAC SUBSCRIPTION SERVICE Being Proactive Telemedicine Rule and CMS Updates May 10, 2011 2011 Aegis Compliance & Ethics Center, LLP 1 Faculty Brian Annulis, JD Partner, Meade
More informationCompliance 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 informationJOINT NOTICE OF PRIVACY PRACTICES
JOINT NOTICE OF PRIVACY PRACTICES THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED, AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY. respects
More informationNOTICE OF PRIVACY PRACTICES Mid-Atlantic Women s Care, PLC Effective Date: September 23, 2013 Last Revised: February 15, 2018
NOTICE OF PRIVACY PRACTICES Mid-Atlantic Women s Care, PLC Effective Date: September 23, 2013 Last Revised: February 15, 2018 THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED
More informationA Day in the Life of a Compliance Officer
A Day in the Life of a Compliance Officer (for small physician practices) Mina Sellami, MBA, PMP, JD MedProv, LLC Julia Konovalov Medical Business Partners September 29, 2016 Agenda Government Regulations
More informationNOTICE OF PRIVACY PRACTICES
NOTICE OF PRIVACY PRACTICES THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY. Who Presents this
More informationMedicare Fraud Strike Force Teams Turn Up The HEAT. By Craig A. Conway, J.D., LL.M.
Medicare Fraud Strike Force Teams Turn Up The HEAT By Craig A. Conway, J.D., LL.M. caconway@central.uh.edu Federal agents have been serving warrants, conducting raids, and making arrests across Houston,
More informationCompliance 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 informationIf you have any questions about this notice, please contact the SSHS Privacy Officer at:
Notice of Privacy Practices 0 Effective Date: April 14, 2003 Revision Date: July 15, 2016 South Shore Health System ( SSHS ) is an integrated health care delivery system. For a list of entities which comprise
More informationLegal Issues facing Healthcare Employees. Medical Therapeutics Gibson County High School
Legal Issues facing Healthcare Employees Medical Therapeutics Gibson County High School Learning Objectives for Standard 2 Compare and contrast the specific laws and ethical issues that impact relationships
More informationStark, False Claims and Anti- Kickback Laws: Easy Ways to Stay Compliant with the Big Three in Healthcare
Stark, False Claims and Anti- Kickback Laws: Easy Ways to Stay Compliant with the Big Three in Healthcare In health care, we are blessed with an abundance of rules, policies, standards and laws. In Health
More information2013 AHLA Physicians and Physicians Organization Law Institute. Presented by Judd Harwood & Lori Foley. Agenda
BUYER BEWARE! THE VALUE OF DUE DILIGENCE IN HOSPITAL-PHYSICIAN TRANSACTIONS 2013 AHLA Physicians and Physicians Organization Law Institute Presented by Judd Harwood & Lori Foley Agenda I. Opening Remarks
More informationIf you have any questions about this notice, please contact our privacy officer Dr. Jev Sikes at
Notice of Privacy Practices For Deep Eddy Psychotherapy THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT
More informationENFORCEMENT, COMPLIANCE, & LONG TERM CARE: HOME HEALTH, HOSPICE, & NURSING HOMES
ENFORCEMENT, COMPLIANCE, & LONG TERM CARE: HOME HEALTH, HOSPICE, & NURSING HOMES HEALTHCARE ENFORCEMENT COMPLIANCE INSTITUTE: OCTOBER 29, 2017 NICOLE MARTIN, DIRECTOR OF QUALITY & COMPLIANCE AT SAMARITAN
More informationPatient Privacy Requirements Beyond HIPAA
Patient Privacy Requirements Beyond HIPAA Jane Hyatt Thorpe, J.D. School of Public Health and Health Services George Washington University Carrie Bill, J.D. Feldesman Tucker Leifer Fidell LLP The George
More informationManaged 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 informationCOMPLIANCE GOTCHAS AND EMERGING RISKS
COMPLIANCE GOTCHAS AND EMERGING RISKS BROOKE BENNETT AZIERE & JUSTAN SHINKLE DIRECT SUPERVISION OF HOSPITAL OUTPATIENT THERAPEUTIC SERVICES Hospital outpatient therapeutic services generally require direct
More informationThis notice describes Florida Hospital DeLand s practices and that of: All departments and units of Florida Hospital DeLand.
MRN: FIN: FLORIDA HOSPITAL DELAND HIPAA NOTICE OF PRIVACY PRACTICES Effective Date: September 23, 2013 THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN
More informationHIPAA PRIVACY NOTICE
HIPAA PRIVACY NOTICE PLEASE REVIEW THIS NOTICE CAREFULLY. IT DESCRIBES HOW YOUR MEDICAL INFORMATION MAY BE USED AND DISCLOSED AND HOW YOU MAY GAIN ACCESS TO THAT INFORMATION. POLICY STATEMENT This Practice
More informationAdvanced Oral & Maxillofacial Surgery, Ltd. NOTICE OF PRIVACY PRACTICES
Advanced Oral & Maxillofacial Surgery, Ltd. NOTICE OF PRIVACY PRACTICES This notice describes how health information about you may be used and disclosed and how you can get access to this information.
More informationNOTICE OF PRIVACY PRACTICES
NOTICE OF PRIVACY PRACTICES This notice describes how Pine Creek Medical Center may use and disclose your medical information, and how you may access this information. Please read through and review it
More informationNOTICE OF PRIVACY PRACTICES UNIVERSITY OF CALIFORNIA IRVINE HEALTHSYSTEM
Effective Date: April 14, 2003 NOTICE OF PRIVACY PRACTICES UNIVERSITY OF CALIFORNIA IRVINE HEALTHSYSTEM THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN
More informationPRIVACY POLICY USES AND DISCLOSURES FOR TREATMENT, PAYMENT, AND HEALTH CARE OPERATIONS
PRIVACY POLICY As of April 14, 2003, the Federal regulation on patient information privacy, known as the Health Insurance Portability and Accountability Act (HIPAA), requires that we provide (in writing)
More informationInstructions for using the following Notice of Privacy Practices
Instructions for using the following Notice of Privacy Practices Please keep these issues in mind when adapting the proposed Notice of Privacy Practices (NPP) for your own use: HIPAA has been spelled out
More informationHIPAA Policies and Procedures Manual
UNIVERSITY of NORTH CAROLINA at CHAPEL HILL SCHOOL of NURSING HIPAA Policies and Procedures Manual November 2015 1 Table of Contents I. INTRODUCTION... 3 A. GENERAL POLICY... 3 B. SCOPE... 3 II. DEFINITIONS...
More informationNotice of HIPAA Privacy Practices Updates
Notice of HIPAA Privacy Practices Updates The following is a summary of the updates to the privacy notice for Meridian Hospitals Corporation, Meridian Home Care Services, Inc., Meridian Nursing & Rehabilitation,
More informationWRAPPING YOUR HEAD AROUND HIPAA PRIVACY REQUIREMENTS
WRAPPING YOUR HEAD AROUND HIPAA PRIVACY REQUIREMENTS Jeffrey Staton Attorney at Law Legal Aid Society of Louisville 416 W. Muhammad Ali Blvd., Ste. 300 Louisville, KY 40202 Phone: 502.614.3146 Jstaton@laslou.org
More informationNOTICE OF PRIVACY PRACTICES
NOTICE OF PRIVACY PRACTICES Effective Date: 2013 Wisconsin Dental Association (800) 243-4675 THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS
More informationAVOIDING HEALTHCARE FRAUD AND ABUSE; Responsibility, Protection, Prevention
AVOIDING HEALTHCARE FRAUD AND ABUSE; Responsibility, Protection, Prevention Presented by: www.thehealthlawfirm.com Copyright 2017. George F. Indest III. All rights reserved. George F. Indest III, J.D.,
More informationDate: January 18, 2017 DOJ, OIG & FBI OH MY!!!
Date: January 18, 2017 DOJ, OIG & FBI OH MY!!! CHERYL L. COON For over 20 years, Cheryl L. Coon has advised clients on a broad spectrum of health law, business and environmental issues. In the healthcare
More informationChapter 19 Section 3. Privacy And Security Of Protected Health Information (PHI)
Health Insurance Portability and Accountability Act (HIPAA) of 1996 Chapter 19 Section 3 1.0 BACKGROUND AND APPLICABILITY 1.1 The contractor shall comply with the provisions of the Health Insurance Portability
More informationPEDIATRIC HEALTH ASSOCIATES HIPAA NOTICE OF PRIVACY PRACTICES
Policy effective date: 4-14-2003 Revised January 2014 PEDIATRIC HEALTH ASSOCIATES HIPAA NOTICE OF PRIVACY PRACTICES THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND
More informationWAKE FOREST BAPTIST HEALTH NOTICE OF PRIVACY PRACTICES
WAKE FOREST BAPTIST HEALTH NOTICE OF PRIVACY PRACTICES Effective April 14, 2003 Revised February 17, 2010 Revised September 23, 2013 Revised July 1, 2016 This Notice of Privacy Practices applies to the
More information822% Healthcare Fraud. Office of Medicaid Fraud and Abuse Control
Office of Medicaid Fraud and Abuse Control Michael E. Brooks, Executive Director Office of Medicaid Fraud and Abuse Control Office of the Attorney General mike.brooks@ag.ky.gov Healthcare Fraud The problem
More information2018 HCCA Compliance Institute HIPAA Update: Policy & Enforcement. Policy Update: Marissa Gordon-Nguyen HHS OCR Senior Advisor
2018 HCCA Compliance Institute HIPAA Update: Policy & Enforcement Policy Update: Marissa Gordon-Nguyen HHS OCR Senior Advisor 2 1 OCR Responds to Nation s Opioid Crisis Opioid abuse crisis and national
More informationRECEIPT OF NOTICE OF PRIVACY PRACTICES WRITTEN ACKNOWLEDGEMENT FORM. I,, have received a copy of Dr. Andy Hand s Notice of Privacy Practice.
Central Texas Institute Of Plastic Surgery, PA Dr. Andy Hand, M.D. Plastic and Reconstructive Surgery Cosmetic Plastic Surgery RECEIPT OF NOTICE OF PRIVACY PRACTICES WRITTEN ACKNOWLEDGEMENT FORM I,, have
More informationalways legally required to follow the privacy practices described in this Notice.
The ANXIETY & STRESS MANAGEMENT INSTITUTE 1640 Powers Ferry Rd, Building 9, Suite 10 0, Marietta, Georgia 30067, 770-953-0080 Health Insurance Portability and Accountability Act (HIPAA) NOTICE OF PRIVACY
More informationFEDERAL PROSECUTIONS OF WORKERS COMPENSATION CLINICS
FEDERAL PROSECUTIONS OF WORKERS COMPENSATION CLINICS Dr. NICK OBERHEIDEN Federal Attorney LYNETTE BYRD Former Federal Prosecutor 1-800-810-0259 Available on Weekends page 1 INTRODUCTION The U.S. government
More informationPARAGOULD DOCTORS CLINIC PRIVACY NOTICE
PARAGOULD DOCTORS CLINIC PRIVACY NOTICE Protected Health Information THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE
More informationAlignment. 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 informationMURRAY MEDICAL CENTER HIPAA NOTICE OF PRIVACY PRACTICES
CW CR 618 Exhibit A MURRAY MEDICAL CENTER HIPAA NOTICE OF PRIVACY PRACTICES Effective Date: THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS
More informationR. Gregory Cochran, MD, JD
California Academy of Attorneys for Health Care Professionals October 19-21, 2012 Government Subpoenas (and other Requests) and Health Privacy Considerations R. Gregory Cochran, MD, JD Overview Overview
More informationPATIENT INFORMATION Indiana Plastic Surgery Center, PC
PATIENT INFORMATION DATE: / / PHYSICIAN REFERAL: FAMILY/FRIEND REFERAL: PRIMARY CARE PHYSICIAN: LAST NAME FIRST M.I. HOME ( ) - CELL( ) - WORK( ) - EMAIL MAY WE CONTACT YOU: BY CELL PHONE / TEXTING?: YES
More informationFRAUD IN PERSONAL CARE PROGRAMS
FRAUD IN PERSONAL CARE PROGRAMS JAMES G. SHEEHAN CHIEF INTEGRITY OFFICER NEW YORK CITY HUMAN RESOURCES ADMINISTRATION sheehanj@hra.nyc.gov (212) 274-5600 LEARNING OBJECTIVES Identifying personal care services.
More informationNOTICE OF PRIVACY PRACTICES
THIS NOTICE OF PRIVACY PRACTICES ( NOTICE ) DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED, AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY. Respect for
More information(PLEASE PRINT) Sex M F Age Birthdate Single Married Widowed Separated Divorced. Business Address Business Phone Cell Phone
(PLEASE PRINT) Emma Warner, MSW, LCSW, ACSW Tulsa, OK 74105 (918) 749-6935 Personal Information Name Address Last Name First Name Initial Home Phone Soc. Sec. # City State Zip Sex M F Age Birthdate Single
More informationNotice of. Privacy Practices. Dartmouth-Hitchcock Affiliated Covered Entity
Notice of Privacy Practices Dartmouth-Hitchcock Affiliated Covered Entity This Notice describes how medical information about you may be used and disclosed and how you can get access to this information.
More informationNOTICE OF PRIVACY PRACTICES
535 East 70th Street New York, NY 10021 (212) 606-1000 Specialists in Mobility NOTICE OF PRIVACY PRACTICES Effective Date: April 14, 2003 THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE
More informationRECENT DEVELOPMENTS MEMORANDUM OF UNDERSTANDING
Activities of the Health and Human Services Commission, Office of the Inspector General and the Office of the Attorney General in Detecting and Preventing Fraud, Waste, and Abuse in the State Medicaid
More informationNOTICE OF PRIVACY PRACTICES
NOTICE OF PRIVACY PRACTICES Effective Date: July 12, 2017 THIS NOTICE OF PRIVACY PRACTICES ( NOTICE ) DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED, AND HOW YOU CAN GET ACCESS TO
More informationPhysician Practices Reimbursement, Risk, and Recommendations
Physician Practices Reimbursement, Risk, and Recommendations Alice V. Cudlipp, Senior Consultant.1 M. H. West & Co., Inc In July of 1997, the US Department of Health and Human Services' ("HHS") Office
More informationPrivacy Practices Home Visit Doctor, LLC July 2017
Privacy Practices Home Visit Doctor, LLC July 2017 THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
More informationHH Health System-Shoals, LLC dba Helen Keller Hospital Notice of Privacy Practices
HH Health System-Shoals, LLC dba Helen Keller Hospital Notice of Privacy Practices THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.
More informationBasic Information. Date: Patient s Name: Address:
1 Basic Information : Patient s Name: Address: Home Phone: Work Phone: Cell Phone: Email: Age: Birth : Marital Status: Occupation: Educational History: Name, Address and Phone of Child s School Counselor
More informationA Better You Counseling Services, LLC 1225 Johnson Ferry Road, Ste 170 Marietta GA
A Better You Counseling Services, LLC 1225 Johnson Ferry Road, Ste 170 Marietta GA 30068 404-216-1135 Health Insurance Portability and Accountability Act (HIPAA) NOTICE OF PRIVACY PRACTICES I. COMMITMENT
More informationCHI Mercy Health. Definitions
CHI Mercy Health Definitions If you have any questions about this notice, please contact the CHI Mercy Health s Privacy Office at (701) 845-6540 or 570 Chautauqua Blvd, Valley City ND 58072. Notice of
More informationNOTICE OF PRIVACY PRACTICES
NOTICE OF PRIVACY PRACTICES JANUARY 1, 2018 EFFECTIVE DATE Regenesis Health care Notice of Privacy Practices This notice describes how medical information about you may be used and disclosed and how you
More informationDEPARTM PRACTICES. Effective: Tel: Fax: to protecting. Alice Gleghorn, Page 1
SANTA BARBARA COUNTY DEPARTM MENT BEHAVIORAL WELLNESS NOTICE OF PRIVACY PRACTICES Effective: September 27, 2013 / Revision: January 7, 2015 This notice describes how medical information about you may be
More informationUSES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION: HIPAA PRIVACY POLICY
Page Number 1 of 8 TITLE: PURPOSE: USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION: HIPAA PRIVACY POLICY To assure that individually identifiable health information contained in any University Health
More informationNOTICE OF HOSPICE EL PASO S PRIVACY PRACTICES
NOTICE OF HOSPICE EL PASO S PRIVACY PRACTICES THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
More informationNOTICE OF PRIVACY PRACTICE UNIVERSITY OF CALIFORNIA SAN FRANCISCO DENTAL CENTER
Effective Date: February 1, 2018 NOTICE OF PRIVACY PRACTICE UNIVERSITY OF CALIFORNIA SAN FRANCISCO DENTAL CENTER THIS NOTICE DESCRIBES HOW HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW
More informationNOTICE OF PRIVACY PRACTICES
Page 1 of 10 NOTICE OF PRIVACY PRACTICES EFFECTIVE DATE: The Notice of Privacy Practices became effective on April 14, 2003 and was amended on August 30, 2013. THIS NOTICE DESCRIBES HOW HEALTH INFORMATION
More informationSouthwest Idaho Ear, Nose and Throat, P.A. Notice of Privacy Practices
Southwest Idaho Ear, Nose and Throat, P.A. Notice of Privacy Practices THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.
More informationSlide 1 WHO IS THE CLIENT? WHO CONTROLS THE RECORD? ETHICS AND HIPAA. Slide 2. Slide 3. The Four As of Ethical Practice
Slide 1 WHO CONTROLS THE RECORD? ETHICS AND HIPAA 22 nd Oklahoma Child Abuse & Neglect Conference Norman, Oklahoma, on September 4, 2014 Dr. Arlene B. Schaefer, Ph.D. Forensic and Clinical Psychology Oklahoma
More informationAPPLICATION FOR CONTINUING EDUCATION UNITS
HCCA s 21st Annual Compliance Institute March 26 29, 2017 in National Harbor, MD Please leave this application with staff at the Registration Desk or email: ccb@compliancecertification.org fax: 952-988-0146
More informationSan 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 informationNOTICE OF PRIVACY PRACTICES
BUTTE COUNTY DEPARTMENT OF BEHAVIORAL HEALTH NOTICE OF PRIVACY PRACTICES Effective Date: 4/14/2003 THIS NOTICE DESCRIBES NOW HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS
More informationGRANT FRAUD. What is Fraud? What is Grant Fraud? Who is the Victim? Fraud is Not Good. We Must Prevent or Detect It Early ASSUMPTIONS.
GRANT FRAUD Ken Dieffenbach U.S. Department of Justice OIG What is Fraud? What is Grant Fraud? Who is the Victim? 2 ASSUMPTIONS Fraud is Not Good We Must Prevent or Detect It Early 3 1 FRAUD CONSEQUENCES
More informationSTATEMENT OF THE ACP-ASIM WORKING GROUP EVALUATION AND MANAGEMENT (E/M) DOCUMENTATION GUIDELINES. March 19, 1998
STATEMENT OF THE ACP-ASIM WORKING GROUP ON EVALUATION AND MANAGEMENT (E/M) DOCUMENTATION GUIDELINES March 19, 1998 PURPOSE The purpose of the statement is to: (1) describe the issues surrounding the evaluation
More information10 Government Contracting Trends To Watch This Year
Portfolio Media. Inc. 111 West 19 th Street, 5th Floor New York, NY 10011 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com 10 Government Contracting Trends To Watch
More informationThe Joint Legislative Audit Committee requested that we
DEPARTMENT OF SOCIAL SERVICES Continuing Weaknesses in the Department s Community Care Licensing Programs May Put the Health and Safety of Vulnerable Clients at Risk REPORT NUMBER 2002-114, AUGUST 2003
More informationMAIN STREET RADIOLOGY
MAIN STREET RADIOLOGY PATIENT REGISTRATION FORM **OFFICE USE ONLY** TODAY S DATE: MR#: LAST NAME: FIRST NAME: ADDRESS: APT: CITY: STATE: ZIP CODE: HOME PHONE #: ( ) - CELL PHONE#: ( ) - DATE OF BIRTH:
More informationERIE COUNTY MEDICAL CENTER CORPORATION NOTICE OF PRIVACY PRACTICES. Effective Date : April 14, 2003 Revised: August 22, 2016
ERIE COUNTY MEDICAL CENTER CORPORATION NOTICE OF PRIVACY PRACTICES Effective Date : April 14, 2003 Revised: August 22, 2016 THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED
More informationNotice of Privacy Practices
River Valley Chiropractic LLC Notice of Privacy Practices Effective 9/2014; Revised 9/2014 If you have any questions about this notice, please contact the River Valley Chiropractic Privacy Officer at 308-534-5840.
More informationPATIENT INFORMATION Please Print
PATIENT INFORMATION Please Print DATE Patient s Last Name First Name Middle Name Suffix Gender: q Male q Female Social Security Number of Birth Race Ethnic Group: q Hispanic q Non-Hispanic q Unknown Preferred
More informationDefense Health Agency Program Integrity Office
Defense Health Agency Program Integrity Office Fighting Health Care Fraud and Abuse Around the World Defense Health Agency Program Integrity Office 16401 East Centretech Parkway Aurora, CO 80011 To Report
More informationPRMS Risk Management Educational Offerings
PRMS Risk Management Educational Offerings INTEGRATED PRACTICE Professional Liability Implications of the Affordable Care Act Examine the impact of the increased number of individuals with health insurance
More informationOverlapping Surgery Developments
HCCA 21 st Annual Compliance Institute March 26-29, 2017 Overlapping Surgery Developments Alana B. Sullivan Erlanger Health System Sara Kay Wheeler King & Spalding LLP Agenda Overview of Overlapping Surgeries
More information