Welcome to The Wonderful World

Theodore J. Leibowitz

of Corporate Compliance

Why Corporate Compliance?• We’re required because we bill Medicaid

• 20 years ago, people were billing Medicaid for dead people

• Corporate Compliance is here to ensure ethical practices

• NYS has the largest Medicaid system in the country– Now that the state is in fiscal distress, – Compliance is a target – HIV and AIDS is on OMIG’s “to-do-list”

Here’s the Good News…

We are already doing the majority of the work:

• I-Pro Audits have great performance feedback • Client Services have excellent supervisory procedures • Already have Internal Audit procedure in place• Already have External Audit procedure in place• Excellent monitoring reports from AIDS Institute

Good News cont.…

We are concerned OMIG is going to fine the organization in their reach to recover excessive amounts of money

Much of what we need to do is already being done• We need to start using their Jargon• We need to start documenting our actions • We need to write the policies that OMIG wants to see in place

STAP’s Corporate Compliance Plan

• Details and provides the guidelines for our program

• Identifies: – Position responsibilities– Auditing and Monitoring– Training and Education– Oversight & Governance

• Used as a living, breathing document

Corporate Compliance Work Plan Outline

• Documentation of what must be completed by frequency (monthly, quarterly, annually)

• Keeps track of tasks • Assists in maintaining structure to the program• Keeps Committee on task• Demonstrates how we meet regulations

Implementation List

Consists of:

– Policies and Procedures that must be written

– Monthly Meetings

– Change our language into the Jargon used by OMIG

Corporate Compliance Library Contains:

– All provider Procedure Manuals related to billing and Medicaid [7]– Provider Procedure Manual for Ryan White Grants [7]– The Agency’s Fiscal Policies and Procedures Manual [7]– Policy Procedure Manuals of each program operated by the agency

[7]– Guidance Manual and Regulations for AIDS Institute funded programs

[7]– OSHA materials [9] – STAP’s Exposure Control Plan– Regulations governing Medical Assistance Payments for programs [7]– Medicaid Providers Manual [7]– Reporting Documentation – Exclusion Documentation (will be discussed) – Pertinent Medicaid Updates

Reporting Policy and ProcedureReporting is confidential and can be anonymous Multiple methods:

– 800 number – Mail-in– Form Drop Box– Email

Contents:– Forms that allow us to document any concern that is reported

If OMIG questions something, we need a tighter way of documenting

(Binder found in Corporate Compliance Library)

Medicaid Exclusion

Providers are not allowed to employ ineligible persons An ineligible person is one who:

– An individual currently excluded, debarred, suspended, terminated, or otherwise prohibited to participate in Federal healthcare programs.

– An individual pleaded guilty, been found guilty, been convicted or indicted of a criminal violation for fraud against Medicaid but has not yet been excluded.

Must be printed and documented in Library from 4 different National Databases for New Hires and Annually for everyone(Binder found in Corporate Compliance Library)

Responsibilities

STAP prides itself on our culture in which everyone is responsible for upholding ethical practice in all areas

• Responsibilities– *See Handout*

• Corporate Compliance created for Hospitals

• We are trying to scale it down

Training

Consequential– New Hires or identified risk issue– As a result of updated regulations

Annually – Comprehensive training on STAP’s Corporate

Compliance practices, policies and procedures for all staff, volunteers, Board Members, and any other individuals providing oversight, management, billing, or client services that Medicaid is billed

Meetings and Reviews

• All meetings must be documented – Attendance Sign-in Sheets– Agendas– Presentations

… All must be documented in the Library

• Monthly Meeting– Department Updates– Address any current issues

• Annual Meeting– Review Plan, audits, and policies

Client Services

More Good News…

Client Services currently has 7 different Levels of checking records and reviewing what gets billed to Medicaid

• Client Services Monthly Department Meeting• CFP Meetings• Self Case Reviews• Supervisory Case Reviews• Content Case Reviews• Peer File Reviews• Weekly Activity Log Reviews• Monthly Log and Productivity Reviews

Conclusion

• We’re doing more than Medicaid requires in most areas

• Everything must be Documented (If it is not documented, then it did not happen)

• Use OMIG’s Jargon

• Maintain Exclusion database checks

• Ensure regular Training (New Hires and Annual)

Questions?