CORPORATE COMPLIANCECorporate Compliance Training is designed to keep you aware of your role in ensuring that Bridgeway continues to act in accordance with all standards and expectations mandated by law.

Compliance training is mandatory for all employees, upon hire, as needed, and at least annually thereafter

August 4, 2014Prepared by:

Bobby Dillard

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Corporate Compliance

Bridgeway is committed to maintain a culture which encourages employee input, questions, and reports of violations of law, regulation and the code of conduct without any fear of retaliation. Each report or question offers employees an opportunity to contribute positively to the quality of services at Bridgeway. The purpose of this plan is to ensure that all employees understand their responsibility to prevent and detect any fraud, waste or abuse within Bridgeway.

 “Ethics and compliance are the responsibility of all employees of Bridgeway”

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What Is Corporate Compliance?

Corporate means: A group of people acting together – an organization – made up of many individuals. Corporate includes every member – the entire organization. The actions of each person, together, create the actions of the corporate body.

Compliance means: Acting in accordance with a set of standards or expectations mandated by law

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Why Do We Need Corporate Compliance Training?

We are committed to providing effective, quality services to those we serve.

All Bridgeway services must be accessible, cost effective, and meet the needs of our consumers and our communities .

Corporate Compliance is a part of how Bridgeway accomplishes this level of service

Bridgeway is not some distant corporate entity apart from you and your coworkers.

“Bridgeway is YOU…

…AND me, and everyone working within the

organization”

Therefore, Corporate Compliance is required of everyone in the organization to maintain our business of serving our consumers

“Our consumers are the reason we are in business”

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Individual Responsibility

It is YOUR responsibility to do your job in manner that is ethical and complies with the laws and regulations that govern our work

It is YOUR responsibility to seek supervisory assistance if YOU have doubts or are unclear about staying in compliance

It is YOUR responsibility to seek assistance from your program director, HR professional, or corporate compliance officer to stay compliant if you believe your supervisor has provided incorrect guidance

It is YOUR responsibility to detect, prevent and report any incidents of Abuse, Fraud, Harassment, Waste, Discrimination, Corporate Malfeasance, or any other Noncompliance with applicable regulations, policies, or procedures

“All Bridgeway employees must be in compliance with State and Federal laws and organizational Policies and Procedures”

“Corporate Compliance Depends On YOU”

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Regulations Are a Requirement of Funding – It’s a Deal!

Before any money can be paid an agreement/contract must be signed.

We agree to provide services as specified in our agreement in keeping with all applicable laws and regulations.

They agree to pay ONLY if all specifications are met and all laws and regulations are followed.

“Most of the dollars received by Bridgeway to fund services, pay the mortgage, keep the lights on, and make payroll come to us through state and federal government sources”

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We Can Demonstrate Compliance Through Providing Required Documentation

The Consumer Plan

It must be created by appropriate individuals (including the consumer and/or guardian) and qualified staff

It must be signed and dated.

It must meet all time requirements, initially upon admission, and annually thereafter. (Annually is considered to be no more than 365 days)

It must be reviewed and modified periodically as necessary .

The goals should be written in “I” (first person)language, from the consumer’s point of view.

It must be clear that the consumer was involved in the development of the plan.

Progress Notes

All progress notes must be tied to a goal/objective in the consumer plan

All progress notes must be written within 24 hours of service delivery in order to ensure accuracy and quality 

Correct codes must always be used

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What is FRAUD? Fraud is usually considered to be an act that is intentionally designed to be dishonest, deceptive, or misleading. 

But today due to legislation and ever tighter government scrutiny even documentation or billing mistakes are now considered to be FRAUD.

Current legislation highlights the government’s intent to reduce their deficit, particularly Medicaid spending, through denying payment and imposing fines upon those who provide services but fail to live up to the specifications of their agreement.

In order to ensure the uninterrupted payment for services it is our responsibility, each member of Bridgeway, to understand and follow the specifications set forth in our agreements.

“Tighter enforcement means more money returned to the government and fewer dollars for service providers like Bridgeway to deliver those services”

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Mistakes Can Lead To Accusations of FRAUD

State and federal False Claims Acts prohibit billing for services that were never provided, are not eligible for billing, incorrectly coded, or not properly related to the service plan.

We must, therefore, ensure the quality and compliance of every aspect of our services in order to avoid penalties

.

“Any documentation/billing mistake can now be considered to be fraud by the government”

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When Our Request For Payment is Not Accepted

If a claim or a bill submitted for services does not meet all specifications and requirements of the law it can be labeled as:

Unsubstantiated, Unclaimable, Undocumented or Fraudulent

Consequences will then occur

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What Can Result If We Don’t Comply?

Failure by any member of the Bridgeway organization to comply with our contracts and agreements can result in:

Money returned for services already provided.

Fines

Legal action that can include forfeiture of the business and even incarceration

“Any of these consequences could mean an end to those services being provided; an end to the program providing those services, or even an end to the organization, and therefore, could mean an end to our jobs and an end to our ability to help and serve others”

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The Impact Of Noncompliance On the Organization, the Consumer, and YOU

A loss of financial resources

An inability to pay our bills 

A loss of credibility within our communities

A loss of goodwill with our consumers

A loss of our ability to serve those in need.

“The more compliance mistakes we make the more money the government can take back through investigations and audits”

.

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Ensuring Corporate Compliance

Clinical staff must deliver services and document those services following all regulations

Consumer plans/reviews must meet all time frames prescribed by law

All documentation must relate to a specific objective within a current Plan

All progress notes must relate to the Plan

All documented services must have been provided to the consumer

All documentation must be properly signed, authorized by appropriate individuals and dated

All billing must be accurate and supported by appropriate documentation

All records must be complete and maintained in a manner that is accessible to appropriate staff and surveyors

“All staff must be aware of the regulations and standards applicable to their area of service”

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Ensuring Corporate Compliance

Human Resources must ensure the credibility of all staff through the initiation of required criminal background checks, Nurse Aid Registry checks, verification of credentials, and obtaining proof of insurance

Human Resources must also monitor that proper hiring and disciplinary procedures are occurring

Financial staff must ensure that correct codes that specifically reflect the services delivered are used.

Financial staff must follow proper procedures when billing errors are discovered,

Maintenance staff must ensure that all service environments adhere to appropriate building codes, safety codes, and accessibility standards

All staff must maintain their qualifications for their employment as well as continue to update their knowledge and skills through ongoing education and training

All staff must understand their commitment to corporate compliance

“We are committed to recognizing and acting upon any shortfall or error in our service delivery system”

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Some Actions That YOU Can Take To Ensure Compliance

Ask for information and instruction if you do not understand how to be compliant in a particular situation. 

Double check your work to be sure your information is correct. 

Use your creativity to develop more effective ways of work!

Understand YOUR responsibility to report compliance issues immediately. Don’t wait for a crisis to occur!!

Organizations that fail to be aware of ongoing compliance issues or choose to ignore them are destined at some point to have these issues pointed out by surveyors or others resulting in potentially devastating consequences.

It is always best to uncover these issues, though painful they may be, and correct them ourselves voluntarily before the correction is mandated form outside of the organization.

 “It is our intent to

be in compliance at all times”

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Reporting Noncompliance

Bridgeway believes that its employees are its major resource in discovering information about compliance within our organization. The effectiveness of our compliance program depends on the willingness of employees in all parts, and at all levels of the organization to step forward, in good faith, with questions and concerns. We believe strongly that in all of these cases, resolution of problem behaviors or actions will result in better service for our consumers. Bridgeway will ensure that those who have so reported in good faith do not suffer any retaliation from their peers or supervisors.

To report compliance issues, contact:• Your Supervisor• Your Program Director• Human Resources• A Management Officer• The Compliance Officer

You can report:

In person, by phone, mail, e-mail Or Phone@309-836-4153

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Bridgeway encourages employee questions and/or reports

We take each report seriously

It is our intent to make sure that employees who do report: 

Do not suffer any retaliation by their peers or supervisors for their good faith reports or questions;

 

Have more than one way to report questionable behavior or to ask questions about compliance

Have the choice of keeping their names confidential when making a specific report for as long as the organization can reasonably do so.

“We investigate each report to determine the extent of the problem and the corrective action(s) needed”

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We Pledge To deal openly and honestly with consumers and their families, our communities, third party payers, government entities, and auditors

To maintain high standards of business and ethical behavior

To hire, train and support quality staff to provide excellent services to our consumers

To provide services without discrimination based on disability, sex, age, race, color or national origin

To provide services only with staff that are properly qualified, licensed and credentialed

To recognize and act upon any shortfall or error in our service delivery system

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Thank YOU!

WE thank YOU - for YOUR time, YOUR consideration, and all of YOUR efforts in making Bridgeway the preferred provider in our communities.

YOUR dedication to providing care in compliance with regulations and standards ensures the future of Bridgeway and the people we serve.

“YOU are the face and hands, the arms and legs, and, yes, the heart and soul of Bridgeway”