Corporate Compliance

Polling Time! Go to: amita.cnf.io A former patient leaves a gift basket to thank their caregivers. No one sees them leave it on the reception desk. It is worth more than $100. What should be done? The answer to this question we are looking for is: “Ask your manager or someone in authority if you don’t know the answer”. The purpose of this slide to communicate the concept of if you don’t know; ask! Our policy is to not accept gifts from residents/patients/participants/clients, however in this case they can’t be returned. If the gifts were cookies, candies, etc that would not be an issue (gifts being nominal in value). However, since the value is so high they would not be accepted if you knew who gave it in this case. Since it can’t be returned there are several options, the gift could be given to the Foundation for use in a silent auction (assuming no perishables are in the basket). Since this basket contains alcohol you could hold a drawing for staff on the unit to give it away.

Objectives You will learn about: Why compliance is important in healthcare Preventing Fraud, Waste and Abuse The AMITA Compliance Program Patient Privacy and Security of Patient Information

Why Is Compliance Important? Total U.S. government health care spend in 2017 - $1.5 Trillion U.S. government estimates that over $80 Billion a year is lost due to fraud, waste and abuse. Ask “What are some examples you can think of?” Billing for services never provided Billing for services not medically necessary Falsifying documents in order to get paid Double billing Over billing –using wrong codes Billing for services not adequately documented Services can only be billed when they are medically necessary, approved to be billed and provided by qualified individuals, documented, coded correctly and not already billed or paid Compliant billing requires complete, accurate, timely and legible documentation by qualified staff, with proper signatures, dates and times in the proper places When these rules are violated, they maybe considered “False Claims”

Primary Healthcare Laws False Claims Act Stark Law Anti-kickback Law HIPAA Significant healthcare regulations Creating a Financial Relationship

AMITA Corporate Compliance Program Chief Compliance Officer Standards of Conduct Policies Compliance training Sanction screening Auditing of coding and billing Processes for reporting concerns Corporate Responsibility Officer to oversee compliance Standards of Conduct Policies that address compliance subjects Compliance training upon hire and annually Sanction screening of employees, medical staff and vendors Auditing of coding and billing Processes for reporting concerns

Privacy and Security of Patient Information Patients trust us with their care Patients trust us with very sensitive information Protecting patient information is part of our job, the law and our Values

Protected Health Information Privacy and Security of Patient Information What is PHI? Protected Health Information Anything that can be used to identify the patient Name, SSN, medical record #, phone number, etc. Anything about the patient’s past, present or future medical conditions or treatment

Privacy of Patient Information *3 Simple Rules* #1 Only access PHI to do your job #2 Only disclose PHI to do your job #3 Only access and disclose the minimum necessary to do your job

Protecting Electronic PHI Security of Patient Information Protecting Electronic PHI Your login is your signature NEVER share Use strong passwords Il2w@AHCO Use encryption when emailing PHI outside of AMITA “-PHI-” in the subject line Ctrl+Alt+Delete or + L - or log out

Privacy and Security of Patient Information Social Media Don’t post ANY info that could ID a patient Don’t post pictures or descriptions of work events that are in conflict with AMITA Health values Remember the Internet is forever, removing posts can be difficult to impossible THINK before you post! It could cost you your job

Electronic Monitoring and Auditing All activity conducted on AMITA information systems is subject to audit, monitoring, and inspection. Including (but not limited to): Log on attempts Web sites visited (or attempted) Medical records accessed, modified or printed Emails sent and received Information stored in personal and shared directories Results of audit and monitoring activities are thoroughly reviewed. Inappropriate activity can result in corrective action from written warnings to termination.

Security of Patient Information Malicious Software, Phishing and Malware Tips Do not download and install software Do not open unsolicited emails from unknown sources Never open an attachment or click on a link from an unknown sender Do not click on internet links that are not work provided/related

Security of Patient Information How Can You Help Protect? Contact the Service Desk Immediately if you… have received/responded to a suspicious email believe your computer may have been infected with malicious software/virus your laptop, computer or AMITA owned phone is lost or stolen

How Do I act “Responsibly” ? Take personal accountability and vigilance for: Knowing compliance requirements of your job Being complete, accurate and timely in your work Ask questions or raise concerns when you have them Check and recheck your work for accuracy ALWAYS tell the truth, even when the truth is hard to hear NEVER Falsify information in medical records, reports, audit or investigations Conceal, destroy or alter records in an investigation

Report concerns: It’s expected and defended 200% Accountability All You Need to Know… Report concerns: It’s expected and defended Don’t ignore potential problems Ask questions to address your concerns No one may retaliate or harass you for reporting a concern You Own It

How to Report a Concern Talk to your manager Talk to your Regional or Service line Compliance Officer/Privacy Analyst Talk to the AMITA Chief Compliance or Privacy Officer Call the AMITA Hotline: 855-477-8861 Complete the online form: www.amitahealth.ethicspoint.com

Details to follow in the L&OD presentation Please Review! Within 7 days, please complete the e-learning module, which is an electronic attestation that you’ve read this booklet and understand AMITA Health’s Standards of Conduct. Details to follow in the L&OD presentation

Is EVERYONE’s responsibility Compliance Is EVERYONE’s responsibility

Break Time. Perfect for… Using the facilities Refilling on beverages Asking questions & evaluating the session on amita.cnf.io Please return by 10:45am