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2010 Region II ConferenceCorporate Compliance Panel
June 3, 2010
Tamy Skaist, Compliance OfficerEzra Medical Center, Brooklyn, NY 11218
My life before I became the Compliance Officer at Ezra Medical Center
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My life after I became the Compliance Officer at Ezra Medical Center
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Overview
Background on Ezra Medical Center Organization of Compliance Program
Compliance Officer Compliance Committee of the Board Board of Directors
Compliance Policy Overview Compliance Training Compliance Reporting System Compliance Auditing Other Relevant Policies and Procedures
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Background on Ezra Medical Center
Located in Brooklyn, NY State-of-the-art facility built in 2008
EZRA MEDICAL CENTER
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Bird’s-Eye View of EMC Facility
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Reception Area
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Dental Exam Room
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Background on Ezra Medical Center
Services offered: Primary care, adults and pediatrics Dentistry, adults and pediatrics, Mobile Dental
Van Optometry and vision therapy Dermatology Podiatry
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Background on Ezra Medical Center
Ezra Medical Center opened its doors in 2001. With minimal resources, the health center created a vital community resource of medical, dental and social service visits for its target population.
During the past 5 years, we’ve seen a growth of over 1,000%.
Currently, we see over 3,000 visits per month.
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Organization of Compliance Program
Compliance Officer Manages Compliance Program
Tracks new developments Ensures compliance reviews are performed Conducts compliance training Responds to reports, complaints and questions
Makes reports to Compliance Committee of the Board
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Organization of Compliance Program
Compliance Committee of the Board Oversees Compliance Program
Receives reports from Compliance Officer Reviews compliance activities
Addresses specific compliance-related concerns
Makes recommendations for changes
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Organization of Compliance Program
Employees Given periodic compliance training Front line in detecting potential compliance
issues
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Compliance Program
Purpose To ensure that Ezra Medical Center operates in full
compliance with all relevant laws, regulations, and guidelines
Particular areas of focus include: Accuracy of coding Claims development and submission Documentation of services rendered Services are reasonable and necessary False Claims Act issues Fraud and abuse (kickbacks/self-referrals)
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Compliance Policy Overview
Privacy and security: Security Officer with responsibility for privacy and security
issues Regular HIPAA training for staff Workstations are physically secure Workstations in public areas are protected with privacy
filters Password protected screen savers when workstations
unattended for 5 minutes or more User accounts disabled immediately upon termination of
user’s employment
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Compliance Training
Bi-annual compliance training for all staff Review compliance program Review of staff responsibilities Discussion of reporting mechanisms
Coding and billing training: Done upon hire, and two times a year
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Compliance Reporting System
Staff are required to report any potential issues to their supervisor, another person in management, or the Compliance Officer
Compliance hotline has been established Toll-free number Available 24 hours per day, 7 days per week Reports are anonymous Reports go to Compliance Officer and/or the
Executive Director
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Compliance Auditing
Current and prospective employees are screened against applicable databases, including: HHS OIG’s List of Excluded Individuals and Entities GSA’s List of Parties Debarred from Federal Programs New York State Medicaid Office of Inspector General List
of Excluded Individuals and Entities Regular self-audits
Done on a quarterly basis Audit of sample charts to ensure that coding and billing
accurate Review by medical records personnel
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Responding to Violations
Investigation by Compliance Officer Ensure that investigation is initiated as soon as reasonably
possible. Identify and review relevant documentation Identify and interview relevant staff members Suspension of staff member from job function to protect integrity
of investigation, if necessary Involvement of legal counsel as required Report to Compliance Committee of the Board
Corrective action Up to and including termination of staff member(s) involved
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Other Relevant Policies and Procedures Whistleblower Protection Policy
Prohibits retaliation or discrimination against any person for making a complaint, assisting in an investigation, or reporting an incident of suspected illegal or unethical conduct
Subjects anyone engaging in retaliation to appropriate disciplinary action, which may include termination
Conflict of Interest Policy Establishes policy for handling potential conflicts of interest Among other things, requires approval of non-conflicted Board members
for any transaction involving a conflicted party Document Retention Policy
Implemented by Compliance Officer Establishes minimum retention periods for records Developed in consultation with legal counsel
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Questions?
