Sample Compliance Monitoring Plan for FY [2022]
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
---|---|---|---|---|---|---|---|
Corporate | |||||||
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%, with 25% of medical directors each quarter |
All | |||
Nonmonetary 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 (i.e., employees, vendors, physicians) |
Federal Sentencing Guidelines |
Monthly |
100% |
All | |||
Licensure (i.e., CNAs, LPNs, RNs, PT, OT, speech, and other) |
State law |
Monthly |
100% |
All | |||
Payroll based journal (PBJ) medical director timesheets |
CMS PBJ compliance |
Monthly |
100% |
All | |||
Management certifications |
Ineffective compliance program |
Annually |
100% |
All | |||
Conduct gap analysis of compliance program with the Office of Inspector General’s Measuring Compliance Program Effectiveness: A Resource Guide and the Department of Justice’s Evaluation of Corporate Compliance Programs and develop an action plan |
Ineffective compliance program |
Annually |
N/A |
Home office | |||
Compliance/privacy self-assessment |
Ineffective compliance program |
Annually |
100% |
All | |||
Open Payments database |
Conflicts of interest |
Annually |
100% of contracted physicians |
All | |||
Skilled Nursing Facilities | |||||||
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 | |||||||
Home health Program for Evaluating Payment Patterns Electronic Report (PEPPER) data |
CMS Regulations |
Annually |
5 residents |
Random selection from locations that are outliers | |||
Research | |||||||
Research: Appropriate approvals of research studies (institutional review board, individual consent and authorization) |
Human subjects protection laws, Health Insurance Portability and Accountability Act (HIPAA) |
Annually |
TBD based on the number of open studies |
All | |||
Physician Enterprise | |||||||
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 | |||||||
Rehabilitation PEPPER Data |
False claims |
Monthly |
5 residents |
Random selection from buildings that are outliers | |||
Behavioral Health | |||||||
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 | |||||||
Telehealth consents |
HIPAA |
Annually |
25 residents |
Random selection from buildings with telehealth | |||
Assisted Living Facilities | |||||||
Distribution of notice of privacy practices |
HIPAA |
Annually |
25 residents, split equally among locations |
All | |||
Personal Care | |||||||
Distribution of notice of privacy practices |
HIPAA |
Annually |
25 residents, split equally among locations |
All |