Professional Documents
Culture Documents
Compliance
Begins with you
Allison Martin & Kimberly Segal
Barbara Ann Karmanos Cancer Center
February, 2013
Learning Objectives
• What is ethics?
– Ethics simply means doing the right thing. Ethics goes beyond
what is allowed by laws and regulations.
• This program has the commitment of everyone at Karmanos, including the Board of
Trustees, senior management, physicians, employees, vendors and others associated
with KCC
• This program provides education, conducts investigations where there are allegations
of misconduct, takes part in monitoring activities, such as audits, to assess areas of risk
within the organization.
• This program provides a pro-active approach to compliance thereby helping the
organization maintain it’s commitment to the highest level of compliance and ethical
standards.
• Compliance is part of all of our jobs and depends on everyone’s participation for
continued success.
Elements of KCC’s
Compliance Program
KCC’s Compliance Program includes the seven elements of an effective compliance
program as defined by the US Federal Sentencing Guidelines:
1. Written standards of conduct and policies and procedures that promote the
hospital’s commitment to compliance.
3. Compliance education and training for all new hires, with annual training for all staff.
4. Processes to receive anonymous complaints and to allow complaints from staff
without any fear of retaliation (for example, the hotline).
5. Responding to allegations of improper activities and, when necessary, developing a
corrective action plan.
6. Auditing and monitoring to identify potential areas of risk.
7. Investigation and remediation of identified systemic problems and non-employment
or retention of sanctioned individuals.
Compliance Policies
• The False Claims Act also imposes liability on an individual who may knowingly submit a
false record in order to obtain payment from the government.
– An example of this may include a government contractor who submits records that he
knows (or should know) is false and that indicate compliance with certain contractual or
regulatory requirements.
• The third area of liability includes those instances in which someone may obtain money
from the federal government to which he may not be entitled, and then uses false
statements or records in order to retain the money.
– An example of this so-called “reverse false claim” may include a hospital who obtains
interim payments from Medicare throughout the year, and then knowingly files a false
cost report at the end of the year in order to avoid making a refund to the Medicare
program.
There are stiff financial penalties for violations of the False Claims Act.
False claims can result in exclusion from Medicare and/or Medicaid
Programs.
Healthcare Fraud & Abuse
NON-RETALIATION
No one will be punished or terminated simply for calling the
Hotline or reporting a compliance-related problem.
Feel free to review this course until you are confident about
your knowledge of the material presented.
Click the Take Test button on the left side when you are ready
to complete the requirements for this course.
Click the Exit button on the left to close the Student Interface.