Hospitals Face Substantial Compliance Burdens. We Can Help Your Facility Come Into Compliance and Maintain Compliance on an Ongoing Basis.
Hospital Consulting Team Lead – Timothy E. Allen | Former Special Agent (U.S. Secret Service & DOJ-OIG)
Compliance is a key issue for hospitals of all sizes and in all regions of the United States. Compliance obligations exist at the local, state, and federal levels, and even minor miscues can potentially have serious consequences. As a result, hospital CEOs need to make compliance a daily priority, and compliance officers must have unwavering confidence that their efforts are sufficient to ward off scrutiny from the regulatory authorities.
Understanding Hospitals’ Compliance Duties in Today’s Constantly-Evolving Regulatory Environment
What does it mean for a hospital to be compliant? While this question seems simple enough, the answer is extraordinarily complicated. There are numerous aspects to compliance, and hospitals must have the requisite policies, procedures, and protocols in place to ensure comprehensive compliance on an ongoing basis.
Put our highly experienced team on your side
Roger Bach
Former Special Agent (OIG)
Timothy E. Allen
Former Senior Special Agent U.S. Secret Service
Chris J. Quick
Former Special Agent (FBI & IRS-CI)
Maura Kelley
Former Special Agent (FBI)
Ray Yuen
Former Supervisory Special Agent (FBI)
Michael S. Koslow
Former Supervisory Special Agent (DOD-OIG)
Marquis D. Pickett
Special Agent U.S. Secret Service (ret.)
At Corporate Investigation Consulting, our former U.S. Department of Health and Human Services (DHHS), Drug Enforcement Administration (DEA), and Office of Inspector General (OIG) agents assist hospital CEOs and compliance officers with establishing full compliance. Our expertise extends to all aspects of hospital compliance—including (but not limited to):
HIPAA Compliance
These days, you will be hard-pressed to find a hospital CEO or compliance officer who is not familiar with at least the basic requirements of the Health Insurance Portability and Accountability Act (HIPAA). However, complying with HIPAA means different things for different hospitals, and HIPAA compliance programs must be custom-tailored to each individual facility’s specific needs.
Billing Compliance
Billing compliance is perhaps the most-complex area of compliance for hospitals. We rely on extensive experience in both the public and private sectors to help hospitals establish and maintain compliance with respect to Medicare, Medicaid, Tricare, Department of Labor (DOL), and private health insurance billing rules and regulations.
Anti-Kickback Statute and Eliminating Kickbacks in Recovery Act Compliance
The Anti-Kickback Statute and its lesser-known sibling, the Eliminating Kickbacks in Recovery Act, pose significant risks for hospitals. Hospital CEOs and compliance officers must ensure that all financial relationships with third-parties either fall outside of the scope of these statutes or fall within one of the specific statutory safe harbors or exceptions.
Prescription Drug Compliance
With former DEA agents on our nationwide team of compliance consultants, we are able to efficiently assist hospitals with prescription drug compliance. We can help your hospital adopt policies and procedures to fully comply with the Controlled Substances Act (CSA), Drug Supply Chain Security Act (DSCSA), and other pertinent statutes, and we can assist with the DEA registration process and DEA inspections as well.
Telemedicine Compliance
Telemedicine is a high-risk area that is also becoming increasingly high in demand. There are many unique aspects to telemedicine compliance, and hospitals must ensure that their patient care and billing practices fully align with all pertinent legal and regulatory requirements.
Cybersecurity Compliance
Cybersecurity is another of compliance that is becoming increasingly important for hospitals. While cybersecurity is essential within the telemedicine context, hospitals need to take appropriate steps to ensure that all patient and employee credit, health, and personal information is adequately protected from malicious attacks.
FAQs: Establishing, Maintaining, and Proving Hospital Compliance
Q: How can I comprehensively identify my hospital’s compliance obligations?
Comprehensively assessing a hospital’s compliance obligations begins with getting a grasp of the scope and nature of the hospital’s operations. What payors does the hospital bill? How does it structure its relationships with doctors? Does it offer telemedicine services? In order to answer these types of questions, the first step is to conduct a thorough internal audit. Once this is complete, then a compliance strategy can be developed with the information gathered during the audit process.
Q: What are the steps involved in implementing an effective hospital compliance program?
Implementing an effective hospital compliance program starts with developing policies and procedures that are custom-tailored to the hospital’s operations, risks, and needs. Then, once these policies and procedures are in place, dissemination and training are the next major steps. After all hospital personnel have received training, the final step is to assess the effectiveness of the implementation and determine whether any follow-up measures are necessary.
Q: How can I be sure that my hospital’s compliance program is effective?
Assessing the effectiveness of a hospital’s compliance program involves conducting an internal audit. The audit should examine all areas of compliance, and it is absolutely imperative for the audit to be conducted in an unbiased manner. The intent should not be to “confirm” compliance, but rather to identify any compliance failures so that they can be remedied as necessary.
Q: What should I do if I am aware of compliance deficiencies within my hospital’s operations?
If you are aware of compliance deficiencies within your hospital’s operations, you need to make it a priority to fix the issue as soon as possible. Known compliance deficiencies can present major risks during government compliance audits and investigations. On the same token, however, demonstrating proactive efforts to identify and remedy any compliance failures can serve to mitigate any potential exposure during a government inquiry.
Q: What is required in order to maintain compliance on an ongoing basis?
Maintaining compliance on an ongoing basis requires three main things: (i) auditing to assess compliance, (ii) remaining up-to-date on hospitals’ statutory and regulatory obligations, and (ii) knowing when additional compliance measures are necessary. At Corporate Investigation Consulting, we assist hospital CEOs and compliance officers with all three of these aspects of maintaining compliance, and we proactively provide recommendations so that our clients can update their compliance programs as necessary.
Speak with a Hospital Compliance Consultant at Corporate Investigation Consulting
If you have questions or concerns about hospital compliance, we encourage you to contact us for more information. We will arrange for you to speak with one of our senior compliance consultants in confidence as soon as possible. To discuss your hospital’s compliance needs with a former DHHS, DEA, or OIG agent, call 866-352-9324 or tell us how we can reach you online today.