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Healthcare Compliance Training OSI has an active Compliance Program to ensure:Healthcare Compliance Program: A Compliance Committee Compliance Policies and Procedures Periodic medical record and billing audits A Compliance Hotline Staff training and education Healthcare Compliance Program The OSI Compliance program consists of:Staff Education and Training: OSI Code of Conduct Compliance Hotline HIPAA Red Flags Rule Staff Education and Training This training session will cover the following key issues:Code of Conduct: We are committed to quality care and patient safety. We shall obey the law. We shall communicate openly and effectively with our patients and co-workers. We shall always seek to build trust, show respect, and perform our jobs with integrity. Code of Conduct The underpinnings of ethical business practices at OSI are the following:Code of Conduct Policy: Quality care Ethical business practices Adherence to HIPAA and Red Flags requirements Adherence to federal and state laws and guidelines regarding documentation and billing practices An employee’s right to confidentially disclose a compliance violation Protection of workplace safety and an environment free of harassment. Code of Conduct Policy The Orthopedic Surgery, Inc. Compliance Code of Conduct incorporates commitment to the following: Each OSI employee is required to read and sign an acknowledgement of the Code of Conduct .COMPLIANCE HOTLINE: OSI is committed to providing compassionate care with the highest ethical standards. If you witness any activity which may be a violation of a federal or state law particularly in the areas of fraud, abuse or waste you may report the violation on the Compliance Hotline: 1 (800) 511 - 4396 You may remain anonymous if you wish. COMPLIANCE HOTLINEQuestion: A) A Code of Conduct B) A Compliance Committee C) A Compliance Hotline D) Every employee E) All of the Above Question The Compliance Program at OSI includes :Question: A) A Code of Conduct B) A Compliance Committee C) A Compliance Hotline D) Every employee E) All of the Above Question The Compliance Program at OSI includes :HIPAA: Health Insurance Portability and Accountability Act of 1996 (HIPAA) HIPAAHealth Insurance Portability and Accountability Act of 1996 (HIPAA), : The HIPAA Privacy Rule provides federal protections for personal health information (PHI) and gives patients an array of rights with respect to that information. At the same time, the Privacy Rule permits the disclosure of personal health information needed for patient care and other important purposes. The HIPAA Security Rule specifies a series of administrative, physical, and technical safeguards for healthcare practices to use to assure the confidentiality, integrity, and availability of electronic protected health information. Health Insurance Portability and Accountability Act of 1996 (HIPAA),HIPAA: Orthopedic Surgery, Inc. expects that as per HIPAA requirements, staff will not use, disclose or discuss patient health information with others unless it is necessary to perform his or her job or is required by law. Patient health information will be released only to persons authorized by law or by the patient's written authorization. Only the minimum , necessary PHI will be released when authorized. HIPAAHIPAA: Protected Health Information (PHI): Protected Health Information is any individually identifiable information contained in the patient’s medical record or files. This includes the patient’s name, address, diagnosis, chart notes, lab or x-ray results, treatment plan, insurance or financial information. HIPAA: Protected Health Information (PHI)Disclosure of PHI: Orthopedic Surgery, Inc. is permitted to use and disclose protected health information, without an individual’s authorization, for the following purposes or situations: 1) To the individual or persons that he or she designates in writing 2) Treatment, Payment, and Health Care Operations 3) Judicial request, law enforcement, public health activities and national security 4) Disclosures about abuse, neglect or violence. Disclosure of PHINotice of Privacy Practices: Orthopedic Surgery, Inc. is required by law to: To provide patients with a notice in plain language of its privacy practices, including the uses or disclosures Orthopedic Surgery, Inc. may make of the individual’s information and the individual’s rights with respect to that information. To make its notice available to any person who asks for it. To provide the notice to the individual no later than the date of first service. To prominently post and make available its notice on any web site it maintains that provides information about its customer services or benefits. Notice of Privacy PracticesAccessing the Notice of Privacy Practices : Copies of the Notice of Privacy Practices (NPP) are available at the front desk and also on the OSI website. Accessing the Notice of Privacy PracticesADVANCE BENEFICIARY NOTICE OF NONCOVERAGE (ABN): If the practice believes a service offered to a Medicare patient may not be covered by Medicare, we must inform the patient and then the patient must sign an Advance Beneficiary Notice (ABN). The ABN allows the Medicare beneficiary to make an informed decision about whether to receive services that he/she may be financially responsible for paying. ADVANCE BENEFICIARY NOTICE OF NONCOVERAGE (ABN)HIPAA Security Rule: The HIPAA Security Rule specifies a series of administrative, physical, and technical safeguards for healthcare practices to use to assure the confidentiality, integrity, and availability of electronic protected health information Orthopedic Surgery, Inc. must, by law, take reasonable measures to secure all protected health records created, stored, accessed, and transmitted electronically. HIPAA Security RuleHIPAA Security Rule Three Components:: Administrative Policies and Procedures, management of passwords and access rights, conducting risk analysis, and developing business continuity plan. Technical The technology that makes safeguards possible (access controls, antivirus protection, encryption, firewall, etc.). Physical Protection of the physical things (computers and facilities where records are stored). Together they cover the processes and systems you need to protect PHI. HIPAA Security Rule Three Components:HIPAA Security Rule: Why talk about security? Breaches in electronic security typically result in unauthorized access or release of protected health information. Most breaches in security occur from inside the building. HIPAA Security RuleSecurity Walkthrough: Always protect the security, safety and privacy of electronic patient information. Don’t give anyone your password. Log off , lock your computer screen or click “show desktop” before walking away from your desk. Don’t open an email attachment unless you know who sent it. Don’t download or install software without approval from the Operations Manager. Don’t leave laptops or PDAs in an unattended vehicle. Security WalkthroughPatient Complaints re: HIPAA: If there has been a violation of the HIPAA privacy policies then a formal report may be made to: The Compliance Officer of OSI - Ron Chorzewski 781-279-7040 ext. 491 The Compliance Hotline 800-511-4396 or to the Secretary of the U.S. Department of Health and Human Services (617-565-2664). Patient Complaints re: HIPAAQuestion: Which of the following statements is false: HIPAA is a federal law mandating the protection of patient health information. HIPAA includes both a Privacy rule and a Security rule. HIPAA was enacted by legislators to add more paperwork for medical offices. PHI includes any patient identifier linked with that patient’s health information. QuestionQuestion: Which of the following statements is false: HIPAA is a federal law mandating the protection of patient health information. HIPAA includes both a Privacy rule and a Security rule. HIPAA was enacted by legislators to add more paperwork for medical offices. PHI includes any patient identifier linked with that patient’s health information. QuestionIdentity Theft Prevention and Detection and Red Flags Rule : The Federal Trade Commission defines identity theft as “ a fraud committed or attempted using the identifying information of another person without authority .” Identifying information is “any name or number that may be used to identify a specific person.” Medical identity theft occurs when a person seeks healthcare using another person’s name or insurance information. Identity Theft Prevention and Detection and Red Flags RuleIdentity Theft Prevention and Red Flags Rule: Orthopedic Surgery, Inc. follows all federal and state laws and reporting requirements regarding identity theft. This presentation outlines how Orthopedic Surgery, Inc. employees will (1) identify , (2) detect and (3) respond to “red flags.” A “red flag” includes a pattern, practice or specific account or record of activity that indicates possible identity theft. Identity Theft Prevention and Red Flags RuleIdentify Red Flags: A complaint or question from a patient based on the patient’s receipt of a bill for another individual; a bill for a product or service that the patient denies receiving; a bill from a provider that the patient never patronized; or a notice of insurance benefits for health care services never received.. A patient or health insurer report that coverage for medical services has been denied because insurance benefits have been depleted or a lifetime cap has been reached. A patient who provides an insurance number but never produces an insurance card or other physical documentation of insurance. A breach of data from outside sources, for example; theft of a patient’s chart either paper or electronic. Identify Red Flags OSI employees may encounter inconsistent or suspicious patient information or activity that may signal identity theft. OSI identifies the following as potential red flags:Detect Red Flags : Driver’s license or other photo ID; Current health insurance card; and If the photo ID does not show the patient’s current address the patient must present a utility bill or other correspondence showing current residence. If the patient is a minor, the patient’s parent or guardian must bring the information listed above. Detect Red Flags OSI staff will be alert for discrepancies in patient information that suggest risk of identity theft or fraud. OSI staff will verify patient identity , address and insurance coverage at the time of patient registration/check-in . When a patient calls to request an appointment, the patient will be asked to bring the following at the time of the appointment:Detect Red Flags Continued : The photograph on a driver’s license or other photo ID submitted by the patient does not resemble the patient. The patient submits a driver’s license, insurance card, or other identifying information that appears to be altered or forged. Information on one type of patient identification is inconsistent with information on another form of identification or with information already in the practice’s records. An address or telephone number is discovered to be incorrect, non-existent or fictitious. The patient fails to provide identifying information or documents. The patient’s signature does not match a signature in the practice’s records. Detect Red Flags Continued Staff should be alert for the possibility of identity theft in the following situations:Respond to Red Flags: The employee should gather all documentation and report the incident to his or her immediate supervisor or Ron Chorzewski, the OSI Compliance Officer. If the activity is determined to be fraudulent then Orthopedic Surgery, Inc. will take immediate action. Actions may include: Notify the affected patient; Notify affected physician(s); Notify appropriate law enforcement. Respond to Red Flags If a red flag is detected by an employee of OSI:Respond to Red Flags: If a patient claims to be a victim of identity theft: Orthopedic Surgery, Inc. will compare the patient’s ID Theft documentation with personal information in the practice’s records. The patient should be encouraged to file a police report for identity theft. The patient should be encouraged to complete the ID Theft Affidavit developed by the FTC which can be obtained at www.ftc.gov or call 1.877.ID.THEFT. Respond to Red FlagsRed Flags Rule Disclaimer: TO OUR PATIENTS: In accordance with the rules and guidelines established by the federal government under the Fair and Accurate Credit Transactions Act of 2003, Orthopedic Surgery, Inc., PC (Orthopedic Surgery, Inc.) has developed and implemented an Identity Theft Prevention Program. As part of that program, all patients are therefore required to provide Orthopedic Surgery, Inc. a copy of their driver’s license (or other governmental issued photo ID) along with their health insurance card. Parents must provide a copy of their driver’s license and insurance card for any of their children should the child become a patient of this office. If you decline to provide the photo identification you will be required to sign this form indicating that you are declining to provide the required identification and will hold Orthopedic Surgery, Inc. harmless for any breach of their identity that could have been prevented if the required identification had been provided in the form that was required. Should you have any questions, please ask one of our staff to put you in contact with our Compliance officer. I decline to provide the required photo identification and to have my picture entered into the EMR: ___________________________________ ______________ Signature Date Red Flags Rule DisclaimerQuestion: Why is it important for medical professionals to be concerned about identity theft? QuestionAnswer: We care about our patients and appreciate the sensitivity of the information they entrust to us. We have a legal obligation to protect patient information. Identity Theft could potentially jeopardize patient care. We are committed to uphold the law and to never participate in fraudulent activity. AnswerOrthopedic Surgery Inc.: Orthopedic Surgery Inc. Thank you for completing this Compliance Staff Training You do not have the permission to view this presentation. In order to view it, please contact the author of the presentation.