1. Developing and Implementing an Effective Compliance Program Mary Sacilotto,BA,CHC Chief Compliance Officer Alliance, Inc.

2. Establishing a Commitment to Compliance Board of Directors President/CEO Chief Compliance Officer Essential Compliance Staff Compliance Committees Legal Counsel

3. Hiring a Compliance Officer Experienced in management Trusted and respected Effective communication skills Strong leadership skills Self-confidence Stamina Must have direct and regular contact with the Board of Directors

4. Compliance Guidance Health Care Compliance Association (HCCA) (www.hcca-info.org)www.hcca-info.org U.S. Federal Sentencing Guidelines U.S. Department of Health and Human Services (HHS)  Office of the Inspector General (http://oig.hhs.gov/index.html)http://oig.hhs.gov/index.html Centers for Medicare and Medicaid (http://www.cms.hhs.gov)http://www.cms.hhs.gov

5. Seven Elements of an Effective Compliance Program Written Standards of Conduct Designate a Chief Compliance Officer & other appropriate bodies – Compliance Committees Effective Education & Training Audits and Monitoring Reporting and Investigating Appropriate Disciplinary Mechanisms Response & Prevention

6. Project Management Plan Create standards for compliance (conduct, conflict of interest, fraud & abuse, disclosure) Establish a formal relationship for legal compliance referrals Implement an anonymous hotline as a reporting mechanism Implement compliance complaint logs Develop a compliance program training that outlines organizational culture of corporate ethics Develop educational presentations programs for Board Establish Compliance Committees – Board and Internal Implement an ongoing audit schedule Expedite investigations and remedy alleged misconduct Review current policies & procedures for compliance Measure effectiveness of program ( surveys, focus groups, trend analysis)

7. Compliance Work Plan Develop an annual work plan OIG work plan Semi-annual risks assessments Audits (internal & external) Regulatory requirements Seven elements – education, training

8. Establish Compliance Policies Code of Conduct Conflict of Interest Policy Non-Retaliation Policy Whistleblower Policy Anonymous Reporting Tool False Claims Act

9. Championing Compliance Meet with Program Directors/Managers Facilitate Risk Assessments Conduct Mandatory Compliance Training Attend Staff Meetings Conduct Focus Groups Be visible and keep an open door policy Establish a rapport Be flexible and keep an open mind

10. Sustaining a Compliance Program Considered a work in progress Constantly changes to adapt to the needs of the company Develop an Annual Work Plan and assess regularly (approved by Board of Directors) Remain on the cutting edge by taking advantage of conferences and training opportunities Establish credibility

11. Questions?