Johns Hopkins Health System
Corporate Compliance Orientation
Ethics, Integrity and Values
7/12/2016
1
Entities Under JHHS Corporate
Compliance Oversight
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
The Johns Hopkins Health System Corporation, Inc.
The Johns Hopkins Hospital, Inc.
Johns Hopkins Bayview Medical Center, Inc.
The Office of Johns Hopkins Physicians
Howard County General Hospital, Inc.
Johns Hopkins Medical Management Corporation
Johns Hopkins HealthCare, LLC
The Johns Hopkins Home Care Group, Inc.
The Johns Hopkins Home Health Services, Inc.
Johns Hopkins Pediatrics at Home, Inc.
Johns Hopkins Pharmaquip, Inc.
Suburban Hospital, Inc. and Suburban Hospital Healthcare System, Inc.
Sibley Memorial Hospital
All Children's Hospital, Inc. & All Children's Health System, Inc.
Potomac Home Health Care
2
JHHS Corporate Compliance:
Who, What, Why, How, When, & Where
•
•
•
•
•
Who oversees Compliance?
What is Corporate Compliance?
Why have a program?
How does it affect me?
When do I need to think about
Compliance?
• Where do I turn if I have questions?
7/12/2016
3
Who Oversees Compliance?
The Department of Corporate Compliance. This
Department was established to educate and train
employees, preserve continued ethical and legal
conduct and protect organizational and employee
reputations.
Contact:
-Laura Mezan, RN, JD, Chief Compliance Officer
-Compliance Department, 410-614-6693 (local) or
Hotline at 1-877-WE COMPLY (1-877-932-6675)
-If intranet is available, visit our website at:
http://www.insidehopkinsmedicine.org/JHHScompliance
7/12/2016
4
What is Corporate Compliance?
Compliance means we adhere to the rules and
regulations required by Federal, State & Local laws.
• JHHS is committed to following all applicable laws and
regulations and in particular, those laws and regulations that
address health care fraud, waste, and abuse and the proper
billing of Medicare, Medicaid, and other government funded
health care programs. This includes the Federal False Claims
Act and State law or related enforcement policies.
• JHHS recognizes its employees rights under these laws and is
committed to abiding by them. We rely heavily on our
employees, to help us comply with all of the legal and regulatory
requirements applicable to us by identifying potential problems,
reporting them and asking questions.
7/12/2016
5
What is Corporate Compliance?
Cont’d
The Compliance team provides:
• Education and training.
• Auditing of high risk billing at each of
the entities.
• Investigations of documentation and
billing irregularities.
7/12/2016
6
What is the Compliance
Program?
• A program comprised of various policies and
procedures to detect and prevent fraud, waste,
and abuse, and to protect those who report
suspected instances of fraud, waste, and
abuse. They are:
– JHHS Corporate Compliance Plan
– JHHS Non Retaliation Policy
– JHHS Organizational Ethics Statement
– Conflict of Interest Policy
– Other Applicable Policies and Procedures
Specific to Your Entity
7/12/2016
7
Why have a Program?
• To ensure that we:
–protect our organization, employees, and
customers;
–preserve the level of integrity that JHHS is
known for;
–promote the continued effort to do the right
thing;
–maintain effective internal controls that
promote adherence to legal and ethical
standards;
–promote detection, prevention, and
resolution of illegal or unethical conduct.
7/12/2016
8
The Regulatory Environment Is
Complex
Examples of Federal and State Enforcement
Fraud and Abuse Laws:
– Federal False Claims Act (and Qui Tam/
Whistleblower)
– State False Claims Acts (e.g., Maryland, Florida)
– Stark I and II Self-referral laws
– Federal Anti-Kickback Statute
– State specific Self-referral and/or kickback laws
– Health Insurance Portability and Accountability Act
(HIPAA)
7/12/2016
9
Federal False Claims Act (FCA)
• Basis for healthcare FCA prosecutions:
- actual knowledge;
- acts in deliberate ignorance;
- acts in reckless disregard to the truth;
- knew or should have known.
• Civil penalties increased up to $11,000 per
false claim and up to 3 times the amount of
each claim as damages.
- Penalties include acts that the provider knew or
should have known were not accurate.
7/12/2016
10
Recent Health Care Settlements
(For-profit Institutions)
Significant fines, penalties, and restitution
paid in the health care industry for fraud,
waste and abuse:
–
–
–
–
–
Columbia/HCA
Tenet Healthcare
Smith Kline Beecham
Caremark, Inc.
Lab Corp of America
7/12/2016
$1.7 billion
$900 million
$325 million
$250 million
$182 million
11
Recent Health Care Settlements
(Not For Profit Institutions)
Imposed Regardless of Non-Profit or Teaching Institution Status:
• St. Barnabas Hospital
• Stanford Medical Center
$265 million
$ 40 million
Local Settlements and Voluntary Overpayments:
• St Joseph Hospital (Stents)
• JHBMC (Coding)
• JHHS (Medicare One Day Stays)
– JHH
– JHBMC
7/12/2016
$22 million
$2.75 million
$1.6 million
$373 thousand
12
Compliance with Billing
& Coding Rules
• Bill only for items and services that have been
rendered and fully documented.
• Bill only for the items and services that are
“medically necessary” and were ordered by a
physician or other appropriately licensed individual.
• Accurately represent the type or level of
service provided.
Failure to follow billing and coding rules may put
yourself, patients, co-workers, institutions at risk!
7/12/2016
13
Special Compliance Issues
• Interaction with others.
• Conflict of interest.
• Workplace conduct and responsibility.
7/12/2016
14
Interactions with Others
Gifts: With the exception of biomedical, pharmaceutical,
and medical device vendors, nominal “gifts” may be
accepted if the item offered is edible or usable in the
workplace. Any other gifts should be discussed with the
Compliance or Legal Department.
Supplier, Vendor of Consultant: JHHS and its staff may
not accept gifts or contributions to influence with whom
we do our daily business.
Physician and Provider Agreements: Contracts and
other formal relationships should always be reviewed by
our Legal Counsel.
7/12/2016
15
JHHS Policy on Gifts from Biomedical,
Pharmaceutical, & Medical Device Vendors
• To comply with legislation, as of July 1, 2009,
JHHS policy prohibits the acceptance of gift items
from Biomedical, Pharmaceutical, and Medical
Device vendors.
• Items such as ink pens, clipboards, note pads,
calculators, etc. may no longer be accepted from
these vendors by JHHS staff.
• Also, effective July 1, 2011, medication samples
will be banned.
7/12/2016
16
Conflict of Interest
An Officer, Trustee or other Disqualified Person
connected to JHHS Corporation is deemed to
have a “conflict of interest” if the person has a
financial interest, directly or indirectly, through
business, investment or family.
Examples include:
• An ownership or investment interest in any entity
with which the Corporation has a transaction or
arrangement; or
7/12/2016
17
Conflict of Interest Examples
Cont’d
-
• Any compensation arrangement with the
Corporation or with any entity or individual with
which the Corporation has a transaction or
arrangement; or
• A potential ownership or investment interest in, or
compensation arrangement with, any entity or
individual with which the Corporation is negotiating
a transaction or arrangement; or
• Compensation which includes direct and indirect
remuneration as well as gifts or favors that are
substantial in nature.
7/12/2016
18
Workplace Conduct &
Responsibility
• Obey applicable laws, rules and policies.
• Behave honestly, use good judgment with high
ethical standards.
• Strive for mutual respect and trust.
• Avoid personal conflicts of interest.
• Report actual or suspected violations to
management or Compliance staff.
Failure to follow the Code may put yourself, patients,
co-workers, institutions and/or the System at risk!
7/12/2016
19
Who do I ask if I have questions?
There are several options you have for
answering questions about Compliance:
1. Talk to your supervisor.
2. Review written materials.
3. Contact the Compliance Department at
(410) 614-6693.
4. Utilize the Compliance Hotline.
7/12/2016
20
Remember the
Compliance Hotline!
Hotline Number:
1-877-WE COMPLY (1-877-932-6675)
• 24/7 availability
• Non retaliation
• Anonymous, confidential
7/12/2016
21
DO THE RIGHT THING!
7/12/2016
22