2. Training Objectives What is the Signature Partners MSSP ACO?
What is Compliance?
Why is Compliance important?
What are my personal compliance responsibilities?
When do I report compliance concerns? How do I report them?
Where can I find more information?

3. Signature Partners
Physician-led, clinically integrated provider network comprised of:
Community-based physicians;
Hospital physicians; and
Hospitals
The goals of Signature Partners are to:
Improve quality of care
Enhance the patient care experience
Make medical care more affordable

4. Signature Partners: an ACO in the MSSP
Accountable Care Organization (ACO)
A group of doctors, hospitals, and other health care providers who come together voluntarily to give coordinated, high quality care to their Medicare patients
Medicare Shared Savings Program (MSSP)
A Medicare delivery system reform initiative that aims to improve beneficiary outcomes and increase value of care by providing:
Better care for individuals
Better health for populations
Lowering growth in expenditures

5. 7 Key Elements of an Effective Compliance Program
There are 7 key elements of an effective compliance program identified by the Office of Inspector General (OIG). They, and our methods to satisfy the requirement, are:
Standards and Procedures – Code of Conduct
Oversight – Compliance Officer
Education and Training – Annual Compliance and Ethics Training
Auditing and Monitoring – Compliance Work Plan
Reporting – Compliance and Ethics Hotline
Enforcement and Discipline – Consistent Enforcement of Policies
Response and Prevention – Ongoing Monitoring and Follow-Up

6. Why Is Compliance Important?
It’s your legal and ethical obligation
Increased oversight by Federal and state agencies has resulted in fines, required repayments, and jail time for wrongdoing
An effective compliance program can lead to reduced fines or jail terms, and may help to avoid corporate integrity agreements when the organization has a compliance issue

7. Code of Conduct
The cornerstone of Signature Partners’ compliance program is the Code of Conduct
Requires high clinical, ethical, business, and legal standards
Commitment to evidence-based medicine, patient engagement, cost effective and high quality care, and coordination of care
All personnel must act in compliance and avoid even the appearance of impropriety
Available from the Compliance Department

8. Relevant Laws Some of the relevant laws include:
Health Information Portability and Accountability Act (HIPAA)
Anti-Kickback Statute (AKS)
Physician Self-Referral Law (Stark)
False Claims Act (FCA)
Civil Monetary Penalty (CMP)

9. HIPAA
Includes rules about privacy and security of patient protected health information (PHI)
Examples of PHI can include (but are not limited to)
Name
Address
Birth date
Identification number
Social Security Number
address
Photograph
Other unique identifiers
It is also important to protect other personal information such as financial information and credit card numbers

10. HIPAA (continued)
Use proper safeguards when faxing, mailing, or leaving voic messages including PHI
Unencrypted should not be used to transmit PHI
Dispose of patient information through secure methods such as shredding

11. HIPAA: Acceptable Uses
You may use and disclose patient information without authorization for Treatment, Payment, and Health Care Operations
Treatment: provision, coordination or management of health care and related services
Payment: activities to obtain payment or be reimbursed for services
Health Care Operations: administrative, financial, legal, and quality improvement activities necessary to run the business and support the functions of treatment and payment

12. HIPAA: Minimum Use Standard
Make reasonable efforts to limit the use or disclosure of PHI to the minimum necessary to accomplish the intended purpose
Grant access to PHI on a need to know basis
The minimum use standard does not prevent uses or disclosures for treatment, payment, or healthcare operations

13. Anti-Kickback Statute
Prohibits referral of anything of value in return for:
Referrals that may be billed to a federal health care program
Purchases of goods or services that may be billed to the government
Payments to contractors below fair market value
If even one purpose of an arrangement is to induce inappropriate referrals, it may violate the Anti-Kickback Statute

14. Physician Self-Referral Law (Stark)
Prohibits a physician from making referrals to a healthcare facility in which the physician, or an immediate family member, has a financial interest if those services are billable to federally funded healthcare programs
There are certain exceptions to this rule
A financial relationship can include an ownership or investment interest or a compensation arrangement
Intent is not required to violate Stark

15. False Claims Act
It is a violation of the FCA knowingly to present or cause to be presented, a false or fraudulent claim for payment or approval
Applies to individuals and organizations
Penalties can include:
Repayment of three (3) times the amount wrongly paid by the government
Fines and penalties of $10,781-21,563 per false claim

16. Civil Monetary Penalty: Beneficiary Inducements
The Civil Monetary Penalties Law (CMP), among other prohibitions, prohibits offering or giving remuneration to a Medicare beneficiary likely to influence the beneficiary to select a particular provider if payment may be made by a federal healthcare program
There are several exceptions to this rule
Remuneration is interpreted broadly to include anything of value
Fines up to $50,276 per violation

17. Shared Savings Program Waivers
CMS and the OIG jointly published five (5) fraud and abuse waivers in connection with the Medicare Shared Savings Program
These waivers allow for the flexibility needed for ACOs to achieve the triple aim of improving quality, enhancing patient care, and increasing affordability
Covered arrangements will not be held to violate Stark, the False Claims Act, or the Beneficiary Inducement Civil Monetary Penalty
Each waiver has conditions that must be followed in order for the arrangement to be covered
If you have questions about the application of these waivers, seek legal counsel

18. Government Exclusions and Sanctions
The government punishes individuals and organizations that have committed violations and puts their names on sanction lists, including the List of Excluded Individuals and Entities (LEIE) and System for Award Management (SAM)
Someone can be excluded for:
Failure to repay federally funded student loans
Suspension of a clinical license
Violation of billing rules
Other violations

19. Books and Records
You are responsible for ensuring accuracy and completion in record-keeping
Regulatory agencies or their designees may conduct audits
Keep records for at least ten (10) years

20. Your Responsibility
It is your responsibility to follow all applicable laws, regulations, and ethical standards
Seek guidance from legal counsel if you do not understand those laws and regulations
Conduct yourself with honesty and integrity
Report conduct that you believe violates healthcare rules and regulations
Cooperate with compliance investigations
Complete annual compliance training

21. Reporting Compliance Concerns
You may report compliance concerns to Signature Partners by contacting:
Signature Partners Compliance Officer
(703)
Compliance and Ethics Hotline
Signature Partners prohibits retaliation for a good-faith compliance report
We are here to help! If you have a question about compliance, please feel free to contact us

22. Compliance and Ethics Hotline 888-800-4030
The hotline is a method for confidential reports of potential compliance concerns
Calls are confidential and you may remain anonymous if you wish
All calls will be thoroughly investigated

23. Compliance Resources HHS OIG: http://oig.hhs.gov/
OCR:
CMS:
DOJ:
Fraud and Abuse Waivers:
Your legal counsel

24. Thank You
Thank you for completing the 2017 annual Compliance and Ethics Training
Annual compliance training is a key element of an effective compliance program