compliance and code of conduct

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Moore County Hospital District Compliance and Code of Conduct Presentation.

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Moore County Hospital District : 

Moore County Hospital District Ethics and Compliance

Slide 2: 

“Corporate Compliance” refers to MCHD’s pledge to operate within the statues, rules, regulations, and policies set by the government, insurance programs, payers and the organization itself.

The Seven Elements of an Effective Compliance Program: : 

The Seven Elements of an Effective Compliance Program: Compliance Officers and Committees Oversight Responsibility (Screening) Education and Training Auditing and Monitoring Discipline for Compliance Violations Corrective Action and Remediation Code of Conduct

An effective compliance program: : 

An effective compliance program: Creates an environment in which all want to do the right thing Acts as an effective deterrent Creates mechanisms for detecting violations and identifying areas of vulnerability and risk

Participation : 

Participation Who all must participate in MCHD’s compliance program: Board members Employees Physicians Contractors Volunteers

Compliance Officer : 

Compliance Officer MCHD has an Corporate Compliance Officer, who reports to the CEO. The Corporate Compliance Officer is Ashleigh Wiswell. Ashleigh can be reached by phone at 806-934-7804 or Ext. 2000. Her office is located in Room 152. The facility CCO oversees and monitors the execution of the facility’s compliance program.

Compliance Committee : 

Compliance Committee MCHD has a compliance committee having the responsibility to: Identify specific areas of risk that the compliance program needs to address Assess and improve compliance policies and procedures Develop standards of conduct and related policies and procedures Recommend and monitor internal compliance controls and systems Determine compliance program strategy Develop a system to solicit, evaluate, and respond to compliance complaints and problems

Screening : 

Screening MCHD conduct reasonable and prudent background investigations as part of the hiring and retention process. The investigation includes reference and criminal checks and also research into whether an individual has been sanctioned by the government or is ineligible to participate in Medicare or other federally funded healthcare programs.

Training and Education : 

Training and Education General Compliance Training All New Employees and must be completed within 60 days of hire. Annually thereafter Job Specific Training

Detection : 

Detection Reporting: Speak with the Corporate Compliance Officer. Compliance Hotline

Compliance Hotline : 

Compliance Hotline Telephone-based hotline answering system Call 806-934-7848 or Ext. 2002 Operational 24/7 Anonymous Retaliation for reporting is strictly forbidden

Surveys : 

Surveys MCHD regularly conducts satisfaction surveys to measure our progress and gather compliance information. Surveys are conducted: On an on-going basis with Patient Satisfaction and reported weekly/quarterly; Every 12 months with Physicians; and Every 18 months with Employees. Exit Interviews If your employment relationship with MCHD comes to an end, you will be asked to participate in either a live or written Exit Interview.

Joint Commission : 

Joint Commission JCAHO standards require that facilities make the following information available to all staff: The Joint Commission on Accreditation of Healthcare Organizations has a toll-free hotline to provide patients, their families, caregivers, and others with an opportunity to share concerns regarding quality-of-care issues at accredited health care organizations. The toll-free number is 800-994-6610 and is available 24 hours a day, seven days a week; however, staff members are available weekdays between 8:30 a.m. and 5:00 p.m. central standard time to answer calls. In accordance with existing policy, employees who call the JCAHO Hotline in good faith will be protected from retaliation. This information may also be obtained from Human Resources

Auditing and Monitoring : 

Auditing and Monitoring Evaluate processes done in different departments. Random Audits Need identified by report

Discipline/Corrective Action : 

Discipline/Corrective Action Fix the process Disciplinary Action up to and including termination

Code of Conduct : 

Code of Conduct Contains information about the following: Conflict of Interest Antitrust and Fair Dealings Discrimination and Harassment Health and Safety Accounting and Record Keeping Confidentiality EMTALA Billing Stark Laws Protection and Usage of MCHD Assets Political Contributions and Relationships Compliance Violation Reporting

Conflict of Interest : 

Conflict of Interest Outside Activities It is every employees duty to ensure that all outside activities do not constitute a conflict of interest and are not otherwise inconsistent with employment at MCHD. Conflicts of Interest must be reported to Human Resources. Gifts and Entertainment All gifts must be reported to the individuals department manager Only if a problem if the gift is used to influence one’s decision. ASK if you don’t know!

Organizational Opportunities : 

Organizational Opportunities Employees are prohibited (without the consent of the Board of Directors or an appropriate committee) from: taking for themselves opportunities that are discovered through the use of corporate property, information or their positions using MCHD property, information or their position for personal gain and competing with MCHD, directly or indirectly.

Antitrust and Fair Dealing : 

Antitrust and Fair Dealing The philosophy of MCHD is to compete vigorously, aggressively and successfully in today's in the market and to do so at all times in compliance with antitrust and competition and fair dealing laws. Each employee should deal fairly with MCHD's customers, suppliers, competitors and other employees. No employee should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair-dealing practice.

Discrimination and Harassment : 

Discrimination and Harassment MCHD is committed to providing a work environment that values diversity among its employees. MCHD is committed to providing equal employment opportunities to all individuals and will not tolerate any illegal discrimination or harassment of any kind. All levels of supervision are responsible for monitoring and complying with MCHD's policies and procedures for handling employee complaints concerning harassment and other forms of unlawful discrimination.

Health and Safety : 

Health and Safety Each employee has a responsibility to ensure that MCHD operations and products meet applicable government and MCHD standards. All employees are required to be alert to environmental and safety issues and to be familiar with environmental, health and safety laws and MCHD policies applicable to their area of business. Threats or acts of violence and any form of intimidation are not permitted. The use/misuse and influence of illegal drugs or legalized substances in the workplace will not be tolerated.

Accounting Records and Record Keeping : 

Accounting Records and Record Keeping All financial statements and books, records and accounts of MCHD must conform to legal requirements, generally accepted accounting principles, and MCHD's system of internal accounting controls. All records must be retained for the periods set forth by MCHD policy.

Confidentiality : 

Confidentiality All employees must treat what they learn about customers, joint venture partners and suppliers as confidential information. The obligation not to disclose confidential information of MCHD and our customers continues with an employee even after he or she leaves MCHD. Proprietary Information Each employee must protect MCHD intellectual property (trade secrets, trademarks, and copyrights, business, marketing and service plans, databases, records, salary information and unpublished financial data and reports) Confidentiality of Patient Information

EMTALA : 

EMTALA Any patient (regardless of ability to pay) who comes to the Emergency Department at MCHD requesting examination or treatment for a medical condition will be promptly provided an appropriate medical screening examination performed by qualified individuals whether or not an emergency medical condition exists.

Billing : 

Billing MCHD bills patients and/or third-party payers accurately and in compliance with Federal and State laws and regulations. All MCHD employees must exercise care in any written or oral statement made to any government agency or other payer. MCHD will not tolerate false statements by its employees to a government agency or other payer.

Fraudulent and Abusive Billing Practices : 

Fraudulent and Abusive Billing Practices 1. Billing for non covered services or supplies. 2. Altering claim forms to receive increased reimbursement without necessary documentation. 3. Duplicate billing for a single service 4. Misrepresentation of facts on the claim, such as services rendered and dates of services or charges. 5. Failing to return overpayments in a timely manner to the appropriate fiscal intermediary 6. Using default billing codes to justify diagnostic billing codes when proper billing codes would be for non covered services. 7. Unbundled laboratory services from panel to be billed individually at a higher rate. 8. Billing for medically unnecessary services.

False Claims Act: : 

False Claims Act: Imposes civil liability on organizations and individuals that make or cause false or fraudulent claims to the government for payment. Can result in penalties of up to $11,000.00 per false claim, plus three times the amount of damages that the government sustains. The government can also exclude the violators from Medicare, Medicaid and other government programs. As of May 2006 Texas has adopted a state False Claims Act which will coincide with the Federal False Claims Act.

Stark Laws : 

Stark Laws Federal law generally requires that all agreements with physicians for the payment or receipt of money, goods, services, or anything of value be in writing. All payments made to physicians by MCHD must be pursuant to written agreements and must be fair market value for actual services performed. MCHD will not pay for referrals nor will it accept payment for its referrals made to other healthcare entities. MCHD will not consider the value or volume of referrals, or other business generated between it and its physicians, in establishing the compensation under its agreements with its physicians.

Federal Anti-Kickback Statute : 

Federal Anti-Kickback Statute The Social Security Act prohibits the offer , payment, solicitation, or receipt of any form of remuneration in return for the referral of Medicare and Medicaid patients. Considered a felony with fines up to $25,000.00 per violation, plus imprisonment for up to five years. Department of Human and Health Services may impose civil penalties and exclude violators from government health programs

MCHD Assets : 

MCHD Assets All of MCHD's assets should be used only for the MCHD's legitimate business purposes. All employees have an obligation to prevent MCHD's assets from loss, damage, and misuse.

Political Contributions : 

Political Contributions MCHD does not make direct contributions to any candidate for federal, state or local offices. Contributions to political campaigns must not be, and must not appear to be, made with or reimbursed by MCHD funds or resources. MCHD funds and resources include (but are not limited to) MCHD facilities, office supplies, letterhead, telephones and fax machines. MCHD employees who hold or seek to hold political office must do so on their own time, whether through vacation, unpaid leave, after work hours or on weekends. Additionally, all persons must obtain advance approval from MCHD's Chief Compliance Officer prior to running for political office to ensure that there are no conflicts of interest with MCHD business.

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