Corporate ResponsibilityRegulatory Compliance

“Systems that ensure all students are aware of laws and regulations and act in accordance of those regulations”

Compliance Goal

Presence Health is committed to compliance with all federal and state laws

and regulations.

The goal of Presence Health compliance efforts is to ensure all business is

conducted ethically, honestly and in accordance with all rules, regulations and

standards

Office of the Inspector General• The enforcement arm of the Department of

Health and Human Services.

• Primary goal is to investigate suspected health care fraud and abuse, specifically:

Medicare&

Medicaid

RiskA large portion of the OIG regulations focus on Risk Assessment

At Presence Health our highest risk areas are:• Coding• Billing• Documentation/Charting• Chain of Command issues• Quality of care- Substandard Care• Patient/Resident Privacy (HIPAA)

OIG - RecommendationsDue Diligence Recommendations

• Standards of Business Conduct education for all employees• Senior Oversight of Compliance Programs• Background checks, on all employees, vendors, and

volunteers before hire and biannually• Create a culture of awareness and establish reporting

mechanisms.• Compliance monitors and audits performed on a regular

basis• Standards and Compliance procedures for all employees

The Presence Health Corporate Responsibility Plan

Presence Health’s Standards of Behavior are based on the Presence Health Values:

•Honesty•Oneness•People•Excellence

It is the expectation of all Presence Health students that they act with integrity, honesty, and they approach all

customer interactions ethically and confidentially

The Presence Health Corporate Responsibility PlanSenior Oversight

Arlene Arellano-Brown serves as Presence Health’s Corporate Responsibility and Compliance Officer-773-990-7475

Local Ministry oversightThe Presence St. Mary’s Hospital Corporate

Responsibility Liaison’s are Theresa Barnes 815-937-3500 and Sandy Kambic 815-937-2477

The Presence Health Corporate Responsibility PlanDue Diligence in Hiring

Criminal background checks are performed on all new employees. We additionally check the Excluded Provider list to assure that our employees, medical staff and vendors have not been excluded from participating in any federally funded health care programs.

The Presence Health Corporate Responsibility Plan• At Presence Health, systems are in place

to continuously monitor the accuracy of our coding, billing, and documentation. These systems are designed to reasonably detect errors and problems.

• CHAN (Catholic Health Audit Network) is Presence Health’s internal auditor

The Presence Health Corporate Responsibility Plan

Student Awareness and TrainingAll Presence Health students are required to participate

in annual Corporate Compliance training. All new employees are required to receive Corporate Compliance in New Employee Orientation

The Presence Health Corporate Responsibility Plan

DisciplineAny violations of corporate compliance is taken very

seriously and appropriate and consistent disciplinary action is take for all violations, regardless of title, position, or affiliation.

The Presence Health Corporate Responsibility PlanAlert Line

1-800-93-ALERT•A confidential and anonymous vehicle to report compliance issues.•Outsourced to Global Compliance and reporting is free of retaliation•Our preference is that you initially follow the standard chain of command when faced with a compliance issue

Supervisor>local Compliance Liaison>System Compliance Officer, then to the Alert Line

The Presence Health Corporate Responsibility PlanWhen errors are detected, we must take reasonable steps to respond appropriately, determine the root cause, and prevent similar errors in the future•Stop the process, protocol or billing if necessary•Determine the cause of the error•Develop a protocol to prevent future errors•Communicate and implement protocol•Continuously monitor the protocol

False Claim Act

This Act provides a legal tool to counteract fraudulent billing turned into the Federal Government

Claims under the Act are filed by persons with inside knowledge of the false claim

(“whistle blowing”)

False Claim ActFalse claims can occur with documentation issues that turn a

legitimate claim into a false claim.Problem Areas:• No documentation• Incomplete or incorrect documentation• Documenting on delivery of care that you did

not deliver personally or witness being delivered.• Missing signatures• Missing or backdated dates

False Claim Act

High Risk Areas:

Billing• Supplies or services not delivered• Services not medically necessary• Billing for a non-covered service, as if covered• Outpatient services that should have been

included as part of an inpatient stay

False Claim Act

Risk Areas (cont.)• Up-coding • Misrepresenting a diagnosis to justify services• Unbundling• Duplicate billing

Your ResponsibilityConflict of Interest

Students who are in a position of trust that have competing professional or personal interests. Conflict of Interest arises when

anyone has 2 duties that conflict• Students must not use their positions to profit personally.• Students must not share confidential Presence Health information

for personal gain• Students must disclose in interest in business that you or a family

member have if that business:Buys/sells goods or services to/from Presence HealthCompetes with Presence HealthIs in a position to benefit from patient referrals

Your ResponsibilityGifts, Honoraria and Gratuities

Students cannot accept gifts or gratuities from patients/residents/clients or vendors.

Must never accept• Money• Loans• Gift CertificatesAcceptable• Candy, Fruit, or food that can be shared

If unsure , ask your If unsure , ask your compliance officer compliance officer oror call call

Alert-LineAlert-Line

Your Responsibility

•Know all the laws and regulations that affect your job responsibilities•Bring to your supervisor’s attention

any suspected issues/concerns as a condition of employment.•Avoid and report any suspected

conflicts of interest•Complete your annual education

requirements

Your Responsibility

It is the expectation of Presence Health that all students exhibit the Standards of Behavior,

know what is right, and do what is right.

If you see something that does not look or feel right, contact your supervisor or the Corporate

Responsibility Liaison or call the Alert-Line

Your Resources• Presence Health Corporate Compliance and HIPAA Policies

can be found on Dovenet

http://dovenet.provena.org/

• Local Compliance Liaison• Alert-Line