CAMcare Health Corporation
Corporate Compliance
Program
Corporate Compliance
 Purpose:
– To establish a system of internal controls
designed to ensure that we regularly evaluate
and monitor our own adherence to applicable
statues, regulations and program requirements
High Risk Areas for Health
Centers
 Billing and Coding
 Grants Management
 Internal Controls
 Information Management
 Tax Issues
 Cost Reporting and Regulatory Filings
Elements of Effective CCP
 Designate Corporate Compliance Officer and
Committee
 Develop and Implementation of Compliance &
Practice Standards
 Conduct Training & Education
 Establish open lines of communication
 Conduct Internal Monitoring and Auditing
 Establish Process for Responding to Potential
Offenses
 Establish Disciplinary Standards
Corporate Compliance Committee
 Corporate Compliance Officer
 Medical Director
 Nursing Director
 Billing Director
 Finance Director
 MIS Director
Implementation of Compliance &
Practice Standards
 Establishment of policy to promote
compliance
– Develop written policies and procedures that
establish guiding principles or courses of action
for staff
– Policies and procedures must be consistent with
the requirements and standards established by
health center’s BOT and all regulatory and
accrediting organizations
Training and Education
 Develop and provide ongoing education and
training for BOT and Staff regarding the
Compliance Program
– All BOT and Staff will receive a General
Compliance training
– Specialized training for staff (ie. Staff with
direct responsibility for coding and billing)
– Focused training for areas identified in an audit
to be potentially problematic
Open Lines of Communication
 Establish a toll free hotline for reporting
issues and concerns relating to compliance
 Ensure that the telephone number is
publicized in a common staff work area (ie.
Break room, lunchroom)
Internal Auditing and Monitoring
 Conduct periodic self audits to assure
– Written standards and policies are in
compliance with the law
– Operating in compliance with written policies
and procedures
– Coding and billing are accurate with services
provided
– Documentation is accurate and complete
– Furnished services are reasonable and
necessary
Response to Detected Offenses
 Upon receiving a report of suspected non-
compliance, the Compliance Officer will initiate
steps to investigate the conduct in question
– Interviews of persons with knowledge of the matter
– Review of relevant documents and applicable laws
– Engage legal counsel, external auditors, or health care
experts to assist in the investigation if necessary
Establish Disciplinary Standards
 Establish and publish procedures for enforcing and
disciplining individuals who violate the law
 Disciplinary guidelines should be well publicized
–
–
–
–
–
Trainings
Policy and Procedure
Employee job descriptions
Employee handbook
Standards of Conduct
Why Corporate Compliance?
 Mandatory
 Establishes a program to identify and
respond to organizational risks
 Identifies and addresses gaps in existing
practices,policies and procedures
 Program will deter potential fraudulent
activity