1. KNOCK…..KNOCK “Managing Audits and Compliance” Robert Saenz, President
VIP Medical Consulting

2. Current Epidemic
“Dilly”
“Miss Emma”
“Good Fellas”
“Mary Jane”

3. Robert Saenz
Graduate of both the U.S. Border Patrol Academy & the FBI National Academy.
20 years investigating federal crimes with the Department of Justice.
Prior Field Director for the U.S. Congress working on legislative issues related to Federal & Healthcare law.
Currently, PRESIDENT of VIP Medical Consulting
(210)

4. For Every One Death From Prescription Drug Misuse
9 Treatment admissions for abuse
32 Emergency dept visits
161 People who Misuse/abuse
461 Non-medical users
1 Death
CDC Vital Signs: Overdoses of Prescription Opioid Pain Relievers in the U.S Atlanta, GA: Centers for Disease Control and Prevention, November 2011.

5. Signed Patient Agreement
“DUE DILIGENCE”
Thorough Initial Exam
Signed Patient Agreement
State PDMP Check
Drug Tox Screen
“Specialist”
Consult

6. DEA AUDIT and Chart Review
Overdose of a Patient
Patient/Employee Sells
Pharmacist
Whistleblower
New Patient Eval.
Patient Agreement
State PDMP
Drug Screen

7. Dr. Albert Yeh Dr Yeh wrote over 6000 prescriptions in 1 yr
11 separate DEA undercover visits
Brief History and Physical
Pain in My Toe
What has worked for you before?
X-Ray /MRI but no Drug Screen
NO PDMP
PA follow ups vs MD

8. DEA vs. Dr Yeh
Since Dr. did not Act in Good Faith and in Accordance with Generally Accepted Medical Standards, this leads to arrest and seizure based on :
Racketeering (Dishonest/ Organized Crime)
Money Laundering (Dirty Money)
Billing Fraud (Deception)
Drug Dealing (self explanatory)

9. Medical Board Reviews It is a Battle of “Documentation”
“Were The Prescribing Guidelines followed”
Face to Face physical examination
Prevention of diversion
Assessment of Benefit of opiates or Benzos
Adjustment of treatment according to risk
Periodic Review and Notes delineating progress
Adequate and accurate record keeping

10. HEALTHCARE HISTORY 101 1965 Medicare was created
1970 Kickbacks rampant
1975 HEW (Health, Education, Welfare)
1980 Pres. Reagan “Waste Fraud & Abuse”

11. Deterrence or Terror
OIG Richard Kusserow

12. The Health Insurance Portability and Accountability Act of 1996 (HIPAA) establishes the Health Care Fraud and Abuse Control Program HCFAC or “The Program” TODAY…………… 30 Federal Agencies investigating HealthCare FBI OIG DEA HEAT

13. OIG Strategic Work Plan 2016-2017
With the Affordable Health Care Act known as Obama Care on the rocks and TRUMP Care on the Horizon sputtering as well and the Medicare program in financial jeopardy, the OIG work plan may be more important today. More federal agencies are investigating Medicare fraud and abuse than ever before, with a “zero tolerance expectation” of physicians
Strategic work plan

14. “HEAT” TASK FORCE Created On May 20, 2009
Increased tools and resources,
Sustained focus by senior level leadership
Cabinet level commitment to prevent and prosecute health care fraud
HEAT jointly led by Deputy Attorney General and HHS Deputy Secretary
Comprised of top level agents, prosecutors, attorneys & auditors

15. ANTI KICKBACK Prohibits Outright Bribes Prohibits INDUCEMENT
Items or Services

16. 7 STANDARDS OF SAFE HARBOR
IN WRITING SIGNED BY BOTH PARTIES
COVER SPECIFIC SERVICES BY CONTRACTOR
SET SCHEDULE , LENGTH AND EXACT CHARGE FOR PART TIME
SPAN AT LEAST 1 YEAR
COMPENSATION SET IN ADVANCE (FAIR MARKET VALUE)
NOT INVOLVE SERVICES THAT INVOLVE PROMOTION OF BUSINESS SERVICES
SERVICES DO NOT EXCEED REASONABLY NECESSARY

17. Elements of Compliance
1. Establish compliance standards by developing a code of conduct and writing policies and procedures.
2. Assign compliance monitoring to a designated compliance officer.
3. Conduct comprehensive training and education on practice ethics, policies and procedures.

18. THANK YOU ! VIP MEDICAL CONSULTING www.vipmedicalconsulting.com