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Issue 5, May 21, 2002

• Interview exiting employeesto stop would-be whistleblowers in their tracks

  Don't let potential employee whistleblowers walk out your door without giving them the opportunity...

Issue 12, December 21, 2002 - VIEW THE FULL ISSUE

• Fee shifting in frivolous qui tam actions: Is it time to turn the tide?

  Incentive high to bring frivolous FCA suitsBy Mark L. MattioliWhat's stopping potential relators...

• Master medical necessity: It's essential to compliance

  Hospitals are losing millions of dollars each year due to medical necessity denials. Hospitals...

• Moving beyond Enron: Compliance plans for today's corporate culture

  Ecnailpmoc. That's compliance back-wards for you word-jumble junkies. And it's a poignant sign of...

• OIG releases 2003 Work Plan.

  Less emphasis on billing errors, more on quality of careProviders investigated by the Office of...

• Use the transactions and code sets extension form as your implementation guide

  Now that you've filed your extension form for the transactions and code sets rule, what next? Use...

• You’ve got to know when to code ’em.

  Outpatient rehab: Avoid the five biggest mistakes in codingFor some therapists, coding is...

Issue 11, November 21, 2002 - VIEW THE FULL ISSUE

• Fast track your privacy efforts

  Develop the documents you need to succeedCapitalize on existing policies and procedures, while...

• OIG releases compliance guidance for pharmaceutical manufacturers

  Pharmaceutical companies must educate their employees and agents on the anti-kickback statute and...

• OIG’s use of civil penalties v. false claims violations

  By Mark L. MattioliSecond in a two-part seriesIn October, we discussed some of the substantive...

• Problem reporting and nonretaliation policy

  Parties necessary for development and implementation• Compliance...

• Tips for communicating effectively with government prosecutors and investigator

  Your interactions with government prosecutors can tip the scales of justice in...

• Use Enron’s mistakes to guide your compliance program

  Part one of a two-part seriesThe name “Enron” has become synonymous with...

Issue 10, October 21, 2002 - VIEW THE FULL ISSUE

• Final privacy rule gives a road map for implementation

  Final privacy rule gives a road map for implementation When the Department of Health and Human...

• Increase reimbursement with a clinical documentation improvement program

  If your physicians aren't documenting properly, your hospital may not be receiving the payment it...

• Notice of privacy practices for protected health information

  Policy: It is the policy of ____________________ Hospital to inform a patient of the uses...

• OIG's use of civil penalties may dwarf false claims violations

  By Mark L. Mattioli Part one in a two part series Penalties under the False Claims Act (FCA...

• Patient discount programs can violate federal and state laws

  Avoid these common problem areas Offering patients discounts may seem altruistic, but the...

• Skilled nursing facilities: Prepare for the public unveiling of your quality mea

  Media coverage of neglect allegations in nursing homes has forced quality-of-care concerns onto...

Issue 9, September 21, 2002 - VIEW THE FULL ISSUE

• Avoid personal liability

  Protect yourself from fraud and abuse chargesIn nearly every high-profile fraud case these days...

• HIPAA hotline

  Health care facilities should include more in their business associate (BA) agreements than the...

• Gov’t links quality of care violations to False Claims Act

  Nursing home settlements to open way for more investigationsThe Office of Inspector General (OIG...

• St. Louis hospital boosts revenue and productivity with an efficient billing pr

  An effective compliance program combined with an efficient and accurate billing system can...

• Use False Claims Act to stop M+C payment abuse

  By Mark L. MattioliLitigation by providers against managed care organizations appears to be...

Issue 8, August 21, 2002 - VIEW THE FULL ISSUE

• Benchmark your compliance program’s effectiveness

  Most compliance programs have been in place for several years. Now, organizations must determine...

• Compliance guidance for ambulance suppliers offers risk analysis tips

  The ambulance industry has seen its share of fraud and abuse enforcement. Still, many...

• Courts’ attitude on qui tam may be changing

  By Mark L. Mattioli Most decisions under the False Claims Act (FCA) seem to favor the qui tam...

• Find your Stark exception when compensating physicians

  Hospitals can use reasonable interpretations, CMS saysEven if your hospital has good intentions...

• Overpayments: Be the first to tell the government

  Discovering that your facility has been overpaid can be frightening for even the most diligent...

• ‘Special authorizations’ required for research

  Tips to help you meet HIPAA authorization requirementsResearchers planning to review medical...

Issue 7, July 21, 2002 - VIEW THE FULL ISSUE

• ABNs: When in doubt, give them out

  When you go to a restaurant and order an entrée, you know the price up front. If you get...

• EMTALA makeover

  CMS proposes changes to ‘anti-dumping’ statuteSeveral “common-sense...

• Health care and compliance after 9/11

  By Ronald H. Levine, Esq.FBI Director Robert Mueller announced recently the hiring...

• Hints for transactions and code sets compliance

  HIPAA HotlineTwo-thirds of organizations are lagging in a key HIPAA regulation, a recent survey...

• Protect sensitive information with ‘rigorous’ attorneys

  The compliance and audit department may handle all your investigations and audits. However, if...

• Top ten internal investigation tips

  You don’t need to be Sherlock Holmes to investigate alleged misconduct in your organization...

Issue 6, June 21, 2002 - VIEW THE FULL ISSUE

• Concierge services: Tread carefully when rolling out the red carpet for annual

  Doctors charging patients an annual fee for a smorgasbord of health services and access advantages...

• Develop a framework for measuring compliance program effectiveness

  Figuring out what it means to have an effective compliance program is a daunting task with few...

• Legal Corner: GAO finds kinder, gentler DOJ

  By Mark L. MattioliOn June 3, 1998, with great fanfare and hoopla, the Department of Justice...

• Privacy and Confidentiality of Protected Health Information

  POLICYThe Company, its affiliates and business associates, and employees who have access to, use...

• Risk management: Maximize resources to get the best bang for your buck

  If you don’t know whether your organization is at risk of noncompliance, you’re...

• The clock is ticking: Strategies for meeting the privacy rule’s deadline

  What was once only a nagging task to complete in the distant future is almost here. On April 14...

Issue 5, May 21, 2002 - VIEW THE FULL ISSUE

• A Supreme Court decision could increase the potential for kickback suits

  Prosecutors may now have more ammunition to bring kickback suits focused on...

• Billing non-physician services: Tips to cut down the confusion

  Employing non-physician practitioners (NPPs) may improve quality of care and allow your facility...

• Don’t put business associate contracts away yet

  The Department of Health and Human Services (HHS) was not telling providers to take a vacation...

• Legal Corner: Economic credentialing: Doing your duty or soliciting a kickback?

  By Mark L. MattioliLast month, we explored the topic of economic credentialing by examining its...

• Proposed HIPAA privacy changes: Some relief, but don’t relax just yet

  The proposed changes to the Health Insurance Portability and Accountability Act of 1996 (HIPAA...

Issue 4, April 21, 2002 - VIEW THE FULL ISSUE

• Assess your risk of HIPAA noncompliance

  Tracking and fixing instances of noncompliance no longer cuts it. You need to take your efforts to...

• Don’t test the government with clinical research noncompliance

  The government has focused on investigating clinical research noncompliance for years, yet...

• Legal Corner: Economic credentialing: Compliance is stuck in the middle

  By Mark L. Mattioli First in a two-part seriesThe Office of Inspector General (OIG) has...

• Engaging techniques take training from boring to electrifying

  The days of staring out the classroom window waiting for recess are gone, so teachers, put...

• Establish a culture of compliance and integrity

  If you want your compliance program to be truly effective, it needs to transcend paper. By...

• HCA

  The Healthcare Company.DEPARTMENT: Ethics & Compliance POLICE DESCRIPTION: Ethics and...

Issue 3, March 21, 2002 - VIEW THE FULL ISSUE

• A smaller DRG window would shrink reimbursement

  Hospitals could face challenges this year if the Office of Inspector General (OIG) expands...

• Are your vendors ready to comply with the rules on transactions and code sets?

  Even if your facility is ready to comply with the rule on transactions and code sets (TCS) in the...

• Could Stark enforcement mean grim realities for your hospital?

  If your hospital administration thinks the Stark II final rule only affects physicians, think...

• Minimize conflicts of interest by guiding employees

  At the Franciscan Sisters of Chicago Service Corporation, every employee must disclose and refrain...

• Legal Corner: Quality of care as false claims violations

  The government declines to become a super-peer review committeeBy Mark L. MattioliThe False...

• Stop whistleblower suits by listening to your employees

  Don’t make the mistake of letting an employee’s complaint get out of control. When an...

Issue 2, February 21, 2002 - VIEW THE FULL ISSUE

• As hospitals see need for assessment, attorneys, consultants stand ready

  As hospitals see need for assessment, attorneys, consultants stand ready

• Assessment done, system forges ahead with all deliberate speed

  Assessment done, system forges ahead with all deliberate speed

• The ‘peer is you’ organization

  The ‘peer is you’ organization

• Legal Corner: Whistleblowers claim retaliation: A risk-management nightmare

  Legal Corner: Whistleblowers claim retaliation: A risk-management nightmare

• Second HIPAA guidance due out soon

  Second HIPAA guidance due out soon

Issue 1, January 21, 2002 - VIEW THE FULL ISSUE

• Corporate Compliance Officer 2001 Index

  Corporate Compliance Officer 2001 Index

• Don't plead ignorance: Clear new rules on medical necessity leave no excuse for

  Don't plead ignorance: Clear new rules on medical necessity leave no excuse for error

• Make sure you are meeting the billing criteria for outpatient observation servic

  Make sure you are meeting the billing criteria for outpatient observation services

• Legal Corner: Medicare+Choice: Bad encounter data may awaken the False Claims be

  Legal Corner: Medicare+Choice: Bad encounter data may awaken the False Claims beast

• No more going it alone: Find the correct Web resources

  - Frequently asked questions (FAQs) on the ambulance fee schedule...

• No quarter given: Eight ways to handle overpayments

  1. Find the origin of the problem. Did someone know about the overpayment? Was there a glitch in...

• Quality of care and the False Claims Act: Defense strategies for a new type of l

  Quality of care and the False Claims Act: Defense strategies for a new type of legal challenge

• Train employees to respect privacy, security; discipline them if they don't

  Train employees to respect privacy, security; discipline them if they don’t