By Lisa Larson-Bunnell
Here are some of the things I plan to do when I get back to my hospital:
1) Revisit our Compliance risk assessment.
2) Use a heat map to highlight areas of compliance risk to our board.
3) Implement a board member compliance attestation that states they: a) have received general compliance training, b) have received general training on the role of the board in compliance oversight and the impact of the Yates memo, c) that they commit to appropriate response to compliance violations.
4) Implement an executive and senior leadership compliance attestation that states they: a) have received general compliance training, b) are committed to reporting potential violations to the Compliance Officer, c) if they have any current concerns, they will report those right away.
5) Review recent corporate integrity agreements for home health services to better inform our home health compliance work plan.
6) Re-evaluate our response plan for ZPIC audits. Kathleen Hessler recommended always alerting outside counsel about ZPIC audits because they are often an indication the government has reason to believe fraudulent activity has occurred ( as a result of qui tam or data analytics, e.g.).
7) Do a better job of documenting department level education that has to do with high-risk compliance topics. For instance, when HIM trains their coders on the appropriate use of the code for Kwashiorkor, make sure the Compliance department has evidence of what the training included and who attended.
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