General Compliance Consulting
INCompliance advises health care organizations of all types and sizes on a variety of compliance issues. Because our attorney-consultants have in-depth legal knowledge of all applicable health care regulations, we provide informed, relevant and practical advice that is tailored to the specific goals and needs of our clients. We have a deep understanding of what the Office of Inspector General and other government agencies are looking for when they review a compliance program to determine its effectiveness, and we apply that knowledge to every engagement.
risk liability for violating health care fraud and abuse laws. Proper job training to ensure employees understand and appreciate the compliance-related requirements of their positions is essential to having a compliant organization. We help health care organizations develop, modify and deliver compliance training to educate employees, contractors, senior leaders, board members, volunteers and others about the compliance program, their role, and the relevant laws and regulations that affect how business is conducted. Our goal is that each employee, contractor and any other individual who provides services to or on behalf of the organization is fully capable of executing his or her role in compliance with applicable rules, regulations, and standards.
on decades of operative solutions that we have developed on behalf of past clients, allowing our current clients to capitalize on the skill, experience and knowledge we’ve built over time. However, we know that each organization is unique, and no incident in the health care arena is factually the same as previous incidents. Our compliance solutions are, therefore, customized and tailored to meet the need of individual organizations.
The Centers for Medicare & Medicaid Services (CMS) final rule on Medicare Part A and Part B overpayments requires health care providers to report and return overpayments within 60 days of “identifying” the overpayment. To comply with this deadline, our team developed the 60-Day Protocol Decision Making Tool, which was designed with the input of health care compliance and finance professionals to provide a proactive management system for identifying a potential overpayment, describing the problem, determining the cause and returning the payment.
Building a comprehensive compliance program is the first – and most important – step to achieving true compliance, and the first step is preparing comprehensive, up to date policies and procedures, and implementing them. Whether you do not have written policies and procedures in place, or if your current policies and procedures are outdated, we can help you develop and implement an effective program. Utilizing both the regulatory guidance that is applicable to the health care industry as well as industry benchmarks, we work with our clients to develop and implement policies and procedures that are specific to the needs of the organization, meet or exceed OIG expectations, minimize risk and protect the organization.
In order to test the effectiveness of an existing compliance program, we conduct audits of compliance programs, perform a “gap analysis” to identify areas for improvement or modification and make recommendations to fill those gaps. While the scope and duration of the audit varies from client to client, all of our compliance program audits supply the client with a detailed report of our findings, and actionable, realistic recommendations. In fact, many of our health care clients continue to reference our reports for several years after going through the audit process.
When a health care organization is faced with a potential compliance issue, time is of the essence. We assist our clients with internal investigations of compliance concerns, as well as responding to investigations, whether initiated by a government audit, a subpoena, a search warrant or a False Claims Act lawsuit.
INCompliance assisted a large health system, which includes 8 hospitals, 120 outpatient facilities and more than 14,000 employees, in addressing numerous compliance issues and concerns over a period of several years. According to the organization’s compliance director, INCompliance brings professionalism, expertise, availability and an array of useful contacts across the country to each engagement, making our attorney-consultants an easy partnership choice.
We assisted a children’s hospital in conducting an assessment of their overall compliance program for two separate years. The assessments were based on the OIG’s seven elements of an effective compliance program, and encouraged the hospital to refocus their energy and resources to areas of highest risk. In addition to identifying these specific areas in need of improvement, our assessments helped them elevate the profile of compliance organization-wide.
As part of a compliance program audit, we reviewed of the code of conduct and compliance policies and procedures, interviewed key personnel, and provided a written report with gap analysis and recommendations for new/revised policies and procedures for a large health system. We also provided suggestions for strengthening the compliance program and adopting best practices.
This engagement included review and revision of the code of conduct and compliance policies and procedures; recommendations for new policies and procedures needed to meet the OIG guidelines and best practices; and suggestions for changes to the hospital’s existing procedures for exclusion screening and receiving reports of suspected noncompliance to ensure that open lines of communication were established and maintained as part of the hospital’s compliance program.
We reviewed the compliance program of a regional medical center, which addressed a multitude of areas. The review and recommendations were well-received by the staff and provided a definitive roadmap for the future of their overall compliance program.
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