Create a 10-minute, 2- to 3-slide voice-over presentation using either Microsoft® PowerPoint® or websites such as Google Slides™, Adobe® Slate, or Prezi™ that addresses the board of directors at your organization.
Explain the roles and responsibilities of the following positions as it relates to compliance:
Compliance committee members
Board of directors
Identify who would be responsible for any training the compliance committee receives.
Cite 3 reputable references to support your assignment (e.g., trade or industry publications, government or agency websites, scholarly works, or other sources of similar quality).
Full Answer Section
Purpose:
This Protocol is designed to:
- Encourage self-detection and timely reporting of potential violations.
- Mitigate potential penalties and liabilities associated with non-compliance.
- Promote transparency and accountability within the Organization.
- Enhance the Organization's commitment to ethical and compliant healthcare practices.
Scope:
This Protocol applies to all employees, contractors, and agents of the Organization, including but not limited to:
- Physicians
- Nurses
- Administrators
- Billing and coding personnel
- Compliance officers
Potential Violations Covered:
The Protocol covers potential violations of various federal healthcare laws and regulations, including:
- False Claims Act
- Anti-Kickback Statute
- Stark Law
- Medicare and Medicaid billing requirements
- HIPAA privacy and security regulations
Types of Self-Disclosures:
Under this Protocol, the Organization may self-disclose the following types of potential violations:
- Overpayments:Billing and receiving improper payments from federal healthcare programs.
- Kickbacks:Offering or receiving illegal inducements in exchange for referrals or business.
- Self-referrals:Referring patients for services to entities in which the referring healthcare professional has a financial interest.
- Privacy violations:Improper use or disclosure of protected health information.
- Security breaches:Unauthorized access to or disclosure of protected health information.
Procedure for Self-Disclosure:
- Identification of Potential Violations:Any employee, contractor, or agent who suspects a potential violation must promptly report it to the Organization's Compliance Officer.
- Investigation:The Compliance Officer will investigate the reported potential violation and determine its validity and scope.
- Decision to Self-Disclose:Based on the investigation, the Compliance Officer, in consultation with legal counsel, will determine whether to self-disclose the potential violation to the OIG.
- Disclosure Submission:If a decision to self-disclose is made, the Compliance Officer will prepare and submit a self-disclosure report to the OIG using the OIG's online Self-Disclosure Portal.
- Cooperation and Remediation:The Organization will cooperate fully with the OIG's investigation and implement appropriate corrective actions to address the identified violation and prevent future occurrences.
Compliance with OIG Self-Disclosure Information Requirements:
This Protocol is designed to comply with the OIG's Self-Disclosure Information requirements, including the following:
- Timeliness:Self-disclosure should be made as soon as practicable after the potential violation is identified.
- Completeness:The self-disclosure report should be complete and accurate, including detailed information about the potential violation, financial impact, and corrective actions taken.
- Cooperation:The Organization should cooperate fully with the OIG's investigation and provide any requested information or documentation.
- Remediation:The Organization should implement appropriate corrective actions to address the identified violation and prevent future occurrences.
Confidentiality:
The Organization will maintain the confidentiality of all information related to potential violations to the extent permitted by law.
Reporting and Monitoring:
The Compliance Officer will monitor the implementation of this Protocol and report periodically to the Organization's leadership on its effectiveness.
Training and Education:
The Organization will provide regular training and education to all employees, contractors, and agents on the importance of compliance and the self-disclosure process.
Review and Update:
This Protocol will be reviewed and updated periodically to reflect changes in applicable laws and regulations, as well as best practices in self-disclosure.
Additional Resources:
Conclusion:
This Self-Disclosure Protocol demonstrates the Organization's commitment to compliance and ethical conduct. By promoting timely and accurate self-disclosure of potential violations, the Organization can mitigate potential penalties and liabilities, build trust with the government and the public, and ensure the delivery of high-quality healthcare services.