Sample Compliance Monitoring Plan for FY 20??
|
Corporate | |||||||
|---|---|---|---|---|---|---|---|
|
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
|
Annual Compliance Education |
Failure to meet Federal Sentencing Guidelines |
Annually |
100% |
All | |||
|
Hotline Compliance Calls and Compliance Investigations |
Ineffective Compliance Program |
Monthly |
100% |
All | |||
|
Medical Director Payments |
Stark and Anti-Kickback compliance |
Quarterly |
100%, 25% of medical directors each quarter |
All | |||
|
Non-Monetary Compensation |
Stark and Anti-Kickback compliance |
Monthly |
100% |
All | |||
|
Repayments within 60 Days |
CMS 60-day Payment Rule, False Claims Act |
Monthly |
100% |
All | |||
|
Excluded Providers - Employees, Vendors, Physicians |
Federal Sentencing Guidelines |
Monthly |
100% |
All | |||
|
Licensure - CNAs, LPNs, RNs, PT, OT, Speech and other |
State law |
Monthly |
100% |
All | |||
|
PBJ Medical Director Timesheets |
CMS Payroll Based Journal compliance |
Monthly |
100% |
All | |||
|
Management Certifications |
Ineffective Compliance Program |
Annually |
100% |
All | |||
|
Conduct gap analysis of Compliance Program with the OIG's "Measuring Compliance Program Effectiveness: A Resource Guide" and the DOJ's "Evaluation of Corporate Compliance Programs" and develop action plan |
Ineffective Compliance Program |
Annually |
NA |
Home Office | |||
|
Compliance/Privacy Self-Assessment |
Ineffective Compliance Program |
Annually |
100% |
All | |||
|
Open Payments Database |
Conflicts of Interest |
Annually |
100% contracted physicians |
All | |||
|
Skilled Nursing Facilities | |||||||
|
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
|
Staffing Tags and CMPs |
CMS Regulations |
Monthly |
100% |
All | |||
|
Staffing Ratios Compliance |
CMS Regulations |
Monthly |
100% |
All | |||
|
Staffing Hotline Calls and Complaints |
CMS Regulations |
Monthly |
100% |
All | |||
|
Regulatory - Survey Tags and CMPs |
CMS Regulations |
Monthly |
100% |
All | |||
|
Regulatory - New Life Safety Requirements |
CMS Regulations |
Monthly |
100% |
All | |||
|
New Advanced Beneficiary Notices |
CMS Regulations |
Annually |
2 buildings each segment |
Sample | |||
|
Involuntary Discharges |
CMS Regulations |
Annually |
100% |
All | |||
|
Home Health | |||||||
|
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
|
Home Health PEPPER Data |
CMS Regulations |
Annually |
5 residents |
Random selection from locations that are outliers | |||
|
Research | |||||||
|
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
|
Research - Appropriate approvals of research studies (IRB, individual consent and authorization) |
Human Subjects Protections laws, HIPAA |
Annually |
TBD based on number of open studies |
All | |||
|
Physician Enterprise | |||||||
|
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
|
NP Bell Curves |
Inappropriate coding, billing, False Claims |
Quarterly |
25% of NPs each quarter so 100% are reviewed |
All | |||
|
NP Resident Volumes |
High volumes combined with coding at high levels could lead to False Claims |
Quarterly |
25% of NPs each quarter so 100% are reviewed |
All | |||
|
Rehabilitation | |||||||
|
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
|
Rehabilitation PEPPER Data |
False Claims |
Monthly |
5 residents |
Random selection from buildings that are outliers | |||
|
Behavioral Health | |||||||
|
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
|
Psychotropic Medication Use and rates of Terrets, Schizophrenia and Huntington's |
CMS Regulations |
Quarterly |
5 residents |
Random selection from buildings that have highest use of psychotropic medications | |||
|
Telemedicine | |||||||
|
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
|
Telehealth Consents |
HIPAA |
Annually |
25 residents |
Random selection from buildings with Telehealth |
Bryant Flynn | ||
|
Assisted Living Facilities | |||||||
|
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
|
Distribution of Notice of Privacy Practices |
HIPAA |
Annually |
25 residents, split equally among locations |
All | |||
|
Personal Care | |||||||
|
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
|
Distribution of Notice of Prvacy Practices |
HIPAA |
Annually |
25 residents, split equally among locations |
All | |||