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An effective compliance program requires a comprehensive infrastructure of policies and procedures to establish the framework of the program. Whether building a program from the very beginning or development of specialized policies to round out an existing program, MCA assists providers by assuring appropriate and organization specific policies are in place and up to date based on the operations of the provider.
Risk Analysis and Management
It is essential that every provider periodically review the areas of compliance risk that exist within the organization in order to identify any areas of weakness within the compliance program that could expose the provider to possible financial and non-financial losses such as theft, criminal and civil sanctions and program exclusion. MCA staff members have the expertise to guide providers through base line risk assessments, prioritization of identified risks and development of dynamic risk management strategies to address areas of exposure.
Program Effectiveness Reviews
Once a provider has gone through the process of developing and implementing a compliance program it is important to make sure the program is truly effective in detecting and deterring fraud, waste and abuse. The OIG has repeatedly stated programs that are not effective will actually work against a provider if they find themselves involved in an investigation. In order to assure effectiveness, the OIG recommends periodic independent reviews to establish the compliance program really does what it is designed to do. Through document review, interviews, surveys and sample testing MCA can review an existing compliance program to determine the effectiveness of the program.
The best compliance program is worthless if employees, vendors and other stakeholders don’t know about the program or how it works. MCA develops training modules for providers customized to their compliance program and workforce. Whether the training is done live or through an on-line experience the training skills of Gary Jones engage the listener in a way that brings the material alive and makes it relevant to their job on a daily basis. Providers who’s employees are engaged in the compliance program and understand the organization’s commitment to “do the right thing” are much less likely to experience serious violations of the program.
With the advent of technology meeting the requirements of both the Privacy Rule and the Security Rule is becoming more complex. It is important that HIPAA/HITECH compliance strategies are integrated into the fabric of each provider’s organization. From privacy audits to network security to policies and training addressing the release of protected health information, MCA, and it’s contractors, help providers navigate through the maze of regulations and develop privacy/security programs within a compliance program to minimize the potential for impermissible disclosure of PHI.
Contract Compliance Officer
Although it is a role vital to the success of a compliance program often the role of compliance officer is an “add-on” for an employee who already has more than enough to do on a daily basis. Providers can be left in a difficult position when a compliance officer leaves the organization and no one has been trained to step into the role. MCA staff has the experience and expertise to serve as the compliance officer for a provider on an interim or contract basis and to assure consistent implementation of a developed program.
Corporate Integrity Agreement Compliance
Our founder, Gary Jones, has experience in working with the OIG and guiding providers through the detailed requirements of a Corporate Integrity Agreement. From development of policies and procedures, to training, to implementation, to monitoring of quality of care activities, to satisfying reporting requirements, MCA can assist providers through the complicated, and sometimes, scary requirements of a CIA.
Internal Investigation Services
If a compliance program is truly effective there will come a time when a compliance concern is brought forward. The integrity of a compliance program depends on the proper investigation of each and every matter. Many concerns can be handled quickly through first level investigations but when the magnitude of a matter requires a more in depth investigation, many compliance officers may not feel qualified to conduct such an investigation. MCA staff can coordinate and/or conduct detailed investigations dealing with legal or regulatory issues, work with outside counsel to maintain the privileged nature of the investigation and provide guidance on corrective actions required.