Healthcare Compliance

Order Description You are the new compliance officer for a large not-for-profit acute care hospital system. You will have compliance oversight for six hospitals in two states, a physician group of 200 physicians, and 30 non-physician practitioners. Two of the hospitals have level one trauma centers. Your hospitals also allow community physicians to have privileges. When you were hired you were aware that the compliance program for the organization was not very robust. The CEO and the Board of Directors hired you to update the program and help assure it is an effective compliance program. There are limited policies and procedures. Employees have been required to take a compliance orientation but annual compliance training is optional. There has been some limited auditing and monitoring. You will be responsible for the following compliance areas: Billing and coding Physician relationships Conflicts of interest Privacy Information Security Tax exempt status Based on this information, please Describe your process for assessing the state of the current compliance program; Identity the specific areas of potential risk for the organization; Outline what the compliance program will need to include to help address the risks you have identified; and Identify how you will determine which compliance issues need to be addressed first. 2. Short Essay Questions a. The IRS has governance guidelines looking for a robust conflicts of interest process within tax-exempt organizations. Briefly explain what exactly the IRS is interested in achieving with this guidance and why. b. Describe how the False Claims Act is applied to pharmaceutical manufacturers accused of violating FDA regulations prohibiting marketing of pharmaceuticals for off-label uses. c. You have been made aware of a potential Stark violation within your organization. If the allegation is true it could result in a substantial refund to the government. Briefly describe how you would initiate the investigation, what records you would want to look at, who you will talk to first and why, whether you would conduct the investigation following the OIG self-disclosure protocol or the CMS Self-Referral Disclosure Protocol, and any other information you believe relevant.