webinars and collaboratives 2015 - healthtechs3€¦ · 16/06/2015 · cfo at iasis healthcare,...

Webinars and Collaboratives 2015

HealthTech Introductions

© HTMS 2015 | Slide 2

Diane Bradley HTMS Regional Chief Clinical Officer

Sara Stanton HTMS Vice President, Business Development

Cheri Benander HTMS Director of Compliance Consulting Services

A Strong History of Performance • HealthTech has been engaged in Hospital Management

since 1971 • Operated as Brim Healthcare prior to 2010. Founded by

healthcare pioneer Gene Brim • 45 years of experience in managing hospitals • Currently managing 18 hospitals across the US

• Provides consulting and recruitment services to over 50

hospitals nationwide

• Specializing in Community, Not for Profit, and Critical Access Hospitals and their Physician Practices


100 Great Community Hospitals • Adirondack Health, New York • Grant Regional Health Center,

Wisconsin • Hammond Henry Hospital, Illinois • Tomah Memorial Hospital, Wisconsin


50 Rural Hospital CEOs to Know • Chandler Ralph, Adirondack Health,

New York • Nicole Clapp, Grant Regional Health

Center, Wisconsin • John Gallagher, Sunnyside Community

Hospital, Washington • Phillip Stuart, Tomah Memorial

Hospital, Wisconsin

Our Team: We have walked a mile in your shoes HealthTech possesses an strong management team with deep operational expertise, extensive industry experience and a track record of delivering results for our clients


More than 20 years of experience in both health care and technology industries. Previously served as Senior Vice President at MedCath Corporation, Operations CFO at IASIS Healthcare, CEO US Operations for Craneware, Hospital CFO at Province Healthcare and Division Director Finance HCA

Voss has more than 30 years of healthcare administration experience including the past 20 years with HealthTech Management Services (formerly Brim Healthcare), serving as Executive Vice President and CEO at St. Anthony’s Memorial Hospital in Effingham, Illinois.

Certified Public Accountant with over 25 years of experience in health care management and has a deep understanding of business intelligence technology to drive operating improvements. Previously, he served as a Division CFO at IASIS Healthcare, HCA and Hospital CFO at Universal Health

Derek Morkel CEO

Michael Jennesse CFO

Greg Voss Regional VP

Neil Todhunter President

Brings over 37 years of healthcare experience, of which 30+ years were in the capacity of President and CEO of hospitals ranging from 200 to 300 beds, with services including acute care, behavioral health, home care, skilled care and physician practice management

Ron Winger Regional VP

Winger has more than 35 years healthcare administration experience, serving as president and CEO of four different not-for-profit and for-profit hospitals and health systems, including most recently as president and CEO at the Heart Hospital of New Mexico, a 55-inpatient bed facility in Albuquerque, New Mexico.

Brian Moyer EVP / CIO

Moyer served as President and CEO of NOVAS Technology Group, In the 1990's, Moyer was founder and President of MW Technologies, where he developed and sold the TAMS (Total Asset Management System) product suite into hospitals across the Midwest. He is heavily involved in the health IT community, serving as President of the HIMSS Tennessee Chapter.

Our Team: We have walked a mile in your shoes HealthTech possesses a strong management team with deep operational expertise, extensive industry experience and a track record of delivering results for our clients


Carolyn St. Charles Regional Chief Clinical Officer [email protected]

Julie Haynes Strategic Planning Consultant [email protected]

Diane Bradley Regional Chief Clinical Officer [email protected]

Susan Murphy Executive Director Supply Chain Resources [email protected]

Joy Smith Senior Patient Financial Consultant [email protected]

Michael Lieb Director, Physician Practice Management [email protected]

John Freeman Assistant Vice President [email protected]

Kevin Stringer Assistant Vice President [email protected]

HealthTech Consulting


Our Expertise

Executive Support

Group Purchasing

Clinical Operations

Physician Services

Strategy and Marketing

Revenue Cycle

Workforce Efficiencies

Managed Care

Compliance Consulting

Human Resources

Our Practices

Executive Education and Consulting

Margin Management

Compliance and Governance

Process Improvement

Clinical Operations

Physician Practice Excellence

Strategic Planning

Regulatory Readiness

Executive Placement

HealthTech Consulting


Compliance and Governance

Today’s Speaker Cheri Benander, MSN, RN, CHC, NHCE-C. Director of Compliance Consultant Services: In her role as Director of Compliance Consultant Services, Cheri Benander brings over 30 years of experience in various healthcare settings and has served in a variety of leadership roles including Vice President of Resident Care Services, Nursing Home Administrator, Interim Chief Nursing Officer, Director of Home Health and Hospice, and Privacy and Compliance Officer.

Benander received her foundational nursing education from Fort Scott Community College and her Bachelor’s and Master’s Degree in Nursing from the University of Phoenix. Benander is a Certified Healthcare Compliance professional through the HealthCare Compliance Association and is licensed as a Registered Nurse in Wyoming, Kansas and Missouri and as a Nursing Home Administrator in Wyoming.

Building an Effective Compliance Program

10

Cheri Benander, RN, MSN, CHC, NHCE-C

Director of Compliance Consulting Services

Objectives

Participants will be able to:

• Identify five benefits of a Compliance Program

• Describe eight elements of a Compliance Program

• Locate three resources that can be useful in implementing or improving a Compliance Program


What is a Compliance Program?

A systematic process

aimed at ensuring that the organization

and those that perform duties on behalf of the organization

comply with

the applicable laws, regulations and standards.


Source: HCCA- Health Care Professionals Manual

Are Compliance Programs Required?

• 1998- OIG Hospital Compliance Program Guidance

• 2005-OIG Supplemental Hospital Program Guidance

• US Federal Sentencing Guidelines; Chapter 8

• Corporate Integrity Agreements

• 2010-Patient Protection and Affordable Care Act


Benefits of a Compliance Program

• Prevention of Fraud, Waste and Abuse

• Fulfill Organizational Mission

• Commitment to Ethical Conduct

• Identify Weaknesses

• Identification and Prevention of Criminal and Unethical Conduct


Benefits of a Compliance Program

• Dissemination of Information

• Culture of Reporting

• Prompt Investigation and Corrective Action

• Minimize Losses to the Government

• Reduce Organizational Exposure to Liability


Source: 1998 OIG Hospital Program Guidance

Obstacles

• Commitment and buy-in • Lack of funding • Too many roles for compliance

professional • Interpreting laws and regulations • Lack of resources and staff • Lack of education and training • Resistance to change • Lack of or poor communication • Fear of retaliation/retribution • No internal enforcement


Source: Troklus , D. & Warner, G. (2011). Compliance 101 (3rd Ed)

Elements of a Compliance Program

1. Standards of Conduct/Policies and Procedures

2. Compliance Officer and Compliance Committee

3. Open Lines of Communication

4. Education and Training

5. Monitoring and Auditing

6. Enforcement and Discipline

7. Response and Prevention

8. Periodic Reassessment


Standards of Conduct

• Defined Commitment to Compliance

• Emphasis on Fraud and Abuse Prevention

• Process for decision-making

• Set Clear Expectations

• Translated and Comprehensible

• Attestation/Acknowledgement


Policies and Procedures

• Specific

• Identify areas of risk

• Reflect Federal and State Statutes, rules and regulations

• Realistic and Measureable

• Followed


Compliance Officer

• Focal Point for Compliance Activities

• Sufficient Training and Resources

• Reporting Structure

• Responsible for day-to-day operation of program

• Independently investigate and respond

• Periodically report to the Governing Board


Compliance Committee

• Committee Membership

• Advising the Compliance Officer

• Assisting with Program Implementation

• Analyze Environment and Identify Legal Requirements and Risk Areas.

• Develop Policies and Procedures

• Develop Internal Controls

• Develop a System to Evaluate and Respond



Open Lines of Communication

• Comfortable Culture

• Newsletters, Posters, Bulletin Boards etc.

• Policies and Procedures

• Ensure Confidentiality and Anonymity

• Methods to Report

– Open Door

– Supervisor

– Email

– Suggestion Box

– Hotline


Education and Training


• Most Important Line of Defense

• Mandatory

• General Compliance Session

• Department Specific Education

• Initial, Ongoing and Annual

• Standards of Conduct

• Documented


Monitoring and Auditing • Process for continual improvement

• Varies depending on the organization

• Qualified Individuals

• Concurrent or Retrospective Audits

• Perform on-site visits

• Methods – Document Review

– Interview staff

– Questionnaires • Current Employees

• Exit Interviews

• Avoid Duplication


Enforcement and Discipline

• Articulate Expectations

• Outline Disciplinary Action

• Policies-

– Publicized and Readily Available

– Fair and Consistent

• Background and Exclusion Checks


Response and Prevention

Stop Mitigate Prevent Monitor


Periodic Reassessment

• Annual Evaluation

• Internal or External Assessments

• GANTT Chart

• SWOT Analysis

• NY OIG Self-Assessment Tool

• Elicit Employee Feedback

– Focus Groups

– Surveys


Privacy and Security

• Component of the Compliance Program

• Includes

– Privacy Rule

– Security Rule • Administrative, Physical and Technical Safeguards

– Breach Notification Rule


Compliance Resources

• Office of Inspector General Website http://oig.hhs.gov/

• Office of Civil Rights Website http://www.hhs.gov/ocr/office/index.html

• NY Office of the Medicaid Inspector General http://www.omig.ny.gov/compliance

• United States Sentencing Commission (Chapter 8) http://www.ussc.gov/training/organizational-guidelines/2013-ussc-guidelines-manual

• Health Care Compliance Association (HCCA) http://www.hcca-info.org/

• HealthTech


http://oig.hhs.gov/

http://oig.hhs.gov/

http://www.hhs.gov/ocr/office/index.html

http://www.hhs.gov/ocr/office/index.html

http://www.omig.ny.gov/compliance

http://www.omig.ny.gov/compliance

http://www.ussc.gov/training/organizational-guidelines/2013-ussc-guidelines-manual











http://www.hcca-info.org/




References • Josephs, A., Ortquist, S., Saunders, B.L., Snell, R., Troklus, D. (Eds.). (2015). The Health

Care Compliance Professional’s Manual available from http://hcpm.mediregs.com/cgi-bin/_subs/afs_gen?page=hccpm

• “OIG General Supplemental Compliance Program Guidance for Hospitals; Notice,”. 70 Federal Register 19 (31 January 2005), pp 4858-4876. Retrieved June 8, 2015 from https://oig.hhs.gov/fraud/docs/complianceguidance/012705HospSupplementalGuidance.pdf

• “OIG Compliance Program Guidance for Hospitals; Notice” 63 Federal Register 35(23 February 1998), pp 8987-8998. Retrieved June 7, 2015 from https://oig.hhs.gov/authorities/docs/cpghosp.pdf

• Patient Protection and Affordable Care Act (ACA) of 2010 Pub. L. No. 111-148, § 6401; 124 Stat. 751 (2010).Retrieved June 8, 2015 from http://www.gpo.gov/fdsys/pkg/PLAW-111publ148/pdf/PLAW-111publ148.pdf

• Troklus, D. & Warner, G. (2011). Compliance 101 (3rd ed.).Minneapolis, MN: Health Care Compliance Association.

• U.S. Department of Health & Human Services and Office of Inspector General. (n.d). A Roadmap for New Physicians: Avoiding Medicare and Medicaid Fraud and Abuse; Speaker Notes. Retrieved June 7, 2015 fromhttp://oig.hhs.gov/compliance/physician-education/index.asp

• USSC Federal Sentencing Guidelines (2012). Effective compliance and ethics programs. Retrieved April 5, 2015 from http://www.ussc.gov/sites/default/files/pdf/guidelines-manual/2012/manual-pdf/Chapter_8.pdf


http://hcpm.mediregs.com/cgi-bin/_subs/afs_gen?page=hccpm




https://oig.hhs.gov/fraud/docs/complianceguidance/012705HospSupplementalGuidance.pdf



https://oig.hhs.gov/authorities/docs/cpghosp.pdf

https://oig.hhs.gov/authorities/docs/cpghosp.pdf

http://www.gpo.gov/fdsys/pkg/PLAW-111publ148/pdf/PLAW-111publ148.pdf





http://www.ussc.gov/sites/default/files/pdf/guidelines-manual/2012/manual-pdf/Chapter_8.pdf





Contact Information

Cheri Benander

[email protected]

Cell 615-636-9042


mailto:[email protected]



webinars and collaboratives 2015 - healthtechs3€¦ · 16/06/2015 · cfo at iasis healthcare,...

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