Corporate Responsibility Online Orientation Corporate Responsibility Regulatory Compliance ~Presence Health is committed to compliance with all federal and state laws and regulations ~The goal of Presence Health compliance efforts is to ensure all business is conducted ethically, honestly and in accordance with all rules, regulation and standards

Office of the Inspector General (OIG) The enforcement arm of the Department of Health and Human Services Primary goal is to investigate suspected health care fraud and abuse Specifically Medicare & Medicaid

RISK ~a large portion of the OIG regulations focus on Risk Assessment At Presence health our highest risk areas are Coding Billing Documentation/ charting Chain of command issues Quality of care/ substandard care Patient/ resident privacy (HIPAA)

OIG- Recommendations Due Diligence Recommendations Standards of business conduct education for all employees Senior oversight of compliance programs Background checks on all employees, vendors and volunteers before hire and biannually Create a culture of awareness and establish reporting mechanisms Compliance monitors and audits performed on a regular basis Standards and compliance procedures for all employees

Corporate Responsibility Plan The Presence Health Corporate Responsibility Plan ~ it is the expectation of all Presence Health students that they act with integrity, honesty and the approach all customer interactions ethically and confidentially Presence Health’s Standards of Behavior are based on the Presence Health Values Honesty Oneness People Excellence

Corporate Responsibility Plan The Presence Health Corporate Responsibility Plan South Suburban Regional Oversight Compliance Officer Ahmed Salim 815-741-7387

Corporate Responsibility Plan The Presence Health Corporate Responsibility Plan ~ at Presence health, systems are in place to continuously monitor the accuracy of our coding, billing and documentation. These systems are designed to reasonably detect errors and problems ~any violation of corporate compliance is taken very seriously and appropriate and consistent disciplinary action is taken for all violations regardless of title , position or affiliation

Corporate Responsibility Plan The Presence Health Corporate Responsibility Plan Alert Line 1-800-93-ALERT Confidential and anonymous vehicle to report compliance issues Outsourced Reporting is free of retaliation Our preference is that you initially follow the standard chain of command Supervisor Regional compliance officer Alert line

Corporate Responsibility Plan The Presence Health Corporate Responsibility Plan When errors are detected, reasonable steps are taken to respond appropriately, determine the root cause and prevent similar errors in the future Stop the process, protocol or billing if necessary Determine the cause of the error Develop a protocol to prevent future errors Communicate and implement protocols Continuously monitor the protocols

FALSE CLAIM ACT ~This Act provides a legal tool to counteract fraudulent billing ~Claims under this act are filed by persons with inside knowledge of the false claim…………“whistle blowing” Problem areas No documentation Incomplete or incorrect documentation Documenting on delivery of care that you did not deliver personally or witness being delivered Missing signatures Missing or backdated dates High Risk Areas Billing Supplies or services not delivered Services not medically necessary Billing for non covered service as if covered Billing for outpatient services that should have been included as part of an inpatient stay Up-coding Misrepresenting a diagnosis to justify services Unbundling Duplicate billing

YOUR RESPONSIBILITY ~conflict of interest arises when anyone has 2 duties that conflict Students must not use their positions to profit personally Students must not share confidential Presence Health Information for personal gain Students must disclose interest in business that you or a family member have if that business Buys/sells goods or services to / from Presence Health Competes with Presence Health Is in a position to benefit from patient referrals

Your Responsibility (continued) Gifts, Honoraria, and Gratuities Students cannot accept fits or gratuities form patients, residents, clients or vendors If unsure ask your supervisor or the regional compliance officer Must never accept Money Loans Gift certificates Acceptable candy Fruit Or food that can be shared

Your Responsibility (continued) It is the expectation of Presence health that all students exhibit the standards of Behavior, know what is right, and do what is right If you see something that does not look or feel right contact your supervisor or the corporate Responsibility Liaison or call the alert line

Your resources Presence Health Corporate Compliance and HIPAA policies can be found on PresNet Enter Corporate Compliance Or HIPAA in search bar Select category of inquiry