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My course is Finance for Health care – Master of Health AdministrationCompliance Interview:Activity: As a new manager in the finance department responsible for the Revenue Cycle function, you are interested in learning the level of readiness, education, and training of the department staff as it relates to compliance. In order to obtain an accurate picture, a meeting with the Corporate Compliance Officer was requested. With the meeting set for Monday morning (plan on 45 minutes), there are a number of items that will need to be considered as you reflect on the experiences learned at your previous position. Prior to giving notice and submitting your letter of resignation, the Office of the Inspector General (OIG) was completing their audit of the Corporate Compliance Plan and reviewing the organizations practices as they relate to the with the Responsible Corporate Officer Doctrine (RCO) . It was rumored that the company was going to be subjected to a Corporate Integrity Agreement (CIA) because of weak policies, lack of training programs, unclear communication of compliance initiatives, and failure to implement the Corporate Compliance Program that was approved by the board prior to the resignation of the organization’s Chief Executive Officer.Question: Develop an interview agenda (about 10 questions, with appropriate citations in APA format) and be certain to consider not only your prior experience as you make a list of your questions but also a careful ear and eye for hints of the type of compliance issues present with your new employer such as their focus on the proposed Treasury regulations section 501r, on charitable Hospital Organizations, FDA Red Flag Rules, Accounting control over Recovery Audit Adjustments, Privacy and HIPAA, Consumer Collection Laws. Also, develop for each question the Compliance Officer’s response and appropriate reference citations in APA format. In addition to the standard approach to agenda development (list of topics, estimate of time for each item to be discussed, and any written material that you would like to have the Compliance Officer review prior to the meeting) be aware of the meeting time and the politics of the office.Mid Term Examination RubricCriteriaRatingsPtsThis criterion is linked to a Learning OutcomeFormatting25.0 ptsThis criterion is linked to a Learning OutcomeResearch25.0 ptsThis criterion is linked to a Learning OutcomeInterview Questions40.0 ptsThis criterion is linked to a Learning OutcomeGrammer10.0 ptsTotal Points: 100.0I attached my classmate work please look at it and take an idea * PLEASE DON’T COPY *
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AGENDA
Compliance Interview
November 5, 2017
10 AM – 10.45 AM
Meeting called by Sultan Alsahli
Attendees:
Corporate Compliance Officer
Location:
Meeting Room (1031)
10:00 – 10:04 AM
Introduction
10:05 – 10:08 AM
10:09 – 10:12 AM
10:13 – 10:16 AM
10:17 – 10:19 AM
10:20 – 10:22 AM
Corporate Compliance Plan
Corporate Integrity Agreement
Revenue Cycle Function
Responsible Corporate Officer Doctrine
Break
10:23 – 10:26 AM
10:27 – 10:30 AM
10:31 – 10:33 AM
10:34 – 10:35 AM
FDA Red Flag Rules
Accounting control over Recovery Audit
Adjustments
Privacy and HIPAA
Break
10:36 – 10:38 AM
10:39 – 10:42 AM
10:43 – 10:45AM
Treasury regulations section 501r
Fair Debt Collection Practices Act (FDCPA)
Conclusion
The objective of the meeting:
• Learning the level of readiness, education, and training of the department
staff as it relates to compliance. In order to obtain an accurate picture.
• Reviewing the organization performs as they relate to the main topics.
Additional Instruction:
A copy of the interview agenda has to be sent prior the meeting.
Q1. What are the critical elements of a Corporate Compliance Plan? And what
are major threats that affect the compliance to a plan?
There are various critical components of a Corporate Compliance Plan. Firstly, a
successful compliance plan has to be created on a solid establishment of ethics that
are fully and openly authorized by top administration. Another component of a solid
compliance program is appropriately training company officers, staff and third parties
on relevant regulations, laws, corporate policies and prohibited conduct (Fox, 2013).
Furthermore, there are many major threats that affect the compliance to a plan, for
example, lack of commitment, inadequate policies and procedures, and ignoring
identified problems. Organization have to display its commitment to the compliance
plan. If the compliance officer and compliance committee are uncreative, compliance
would not be apparent as a high priority. Moreover, Policies and procedures have to
be clear, accurate, and written in order to avoid any errors and variation from standard
operating procedures (Fogel, 2004).
Q2. What is a Corporate Integrity Agreement? And how can the organization
deal with the concerns which make the organization at a risk of Corporate
Integrity Agreement?
A corporate integrity agreement (CIA) is a document that shapes the obligations to
which an entity agrees as part of a civil settlement. “An entity agrees to the CIA
obligations in exchange for the Office of Inspector General’s (OIG) agreement that it will
not seek to exclude the entity from participation in Medicare, Medicaid, or other Federal
health care programs (OIG)”.
Moreover, the organization has already created a compliance plan, and it is committed to
make sure that it will comply with the whole set standards. In other words, it works
effectively to identify and predict any corporate integrity agreement risk in the
organization. On the other hand, the organization is committed to offering training to the
staff on several issues (Vaidya, 2013). Furthermore, a copy of the corporate integrity
agreement and policies had already been distributed in each department, and there is a
qualified trainer who explains anything that is not understood in the agreement weekly.
Q3. What are the essential components of effective Revenue Cycle Management?
And is the cost of the The International Classification of Diseases, Tenth Edition
(ICD-10) implementation worth making the transition?
There are several essential factors that lead to an effective revenue cycle management.
Development of software that automates the procedures is the first essential factors. In
other words, web-based services which allow patients to deal with the billing cycle
and contact with the providers when they need them. Moreover, real-time insurance
verification is one of the essential factors. Revenue cycle management systems with
built-in “rules engines” can prevent mistakes and give information such as copayments and possible mistakes in insurance claims before they occur (Houseman,
2015). Regarding to the cost of ICD-10 implementation, there are costs related to
implementation of ICD-10, likewise there are costs to implement any healthcare
change. The size of the healthcare organization determines the cost of implementation
ICD-10. In fact, any delaying in implementation ICD-10 will cost the industry money.
Furthermore, there is an economic and public health cost from the continual use of
ICD-9 because of the reliance on inaccurate data (Virtual Office Ware).
Q4. How can the officers in the organization keep themselves protected from the
Responsible Corporate Officer Doctrine? And would you give me examples of
misbehavior for which the Human Services’ Office of Inspector General may
seek to exclude officers under the RCO doctrine?
The officers in the organization must do their best to make sure that they address the
compliance issues. The officers, also, have to be in the forefront in encouraging
training as well as compliance, thus to make sure that the issues related to compliance
are addressed. Therefore, the chances of noncompliance will be decreased, and the
officers will not face the risk of Responsible Corporate Officer Doctrine (Lane, 2011).
Moreover, there are many examples of misbehavior may seek to exclude officers:

“Systemic organization compliance violations, including financial misconduct,
suggestive of a lack of institutional control

Intentional refusal by executives to respond to compliance misconduct

Evidence of obstruction of justice

Recidivist corporate behavior

Situations where management or board members failed to act in the face of a
known duty to act demonstrating a disregard for their compliance obligations”
(Meidl, 2012).
Q5. Who is covered by the new Identity Theft Regulations? And what did the
organization do in regards to complying with the FDA Red Flag rules?
There are three different sets of requirements of the Identity Theft Regulations, and each
set applies to different parties:

The first requirement deals with address discrepancies, and applies to all users of
consumer reports.

The second group of requirements deals with identity theft prevention (the so
called “red flags”) and applies to all financial institutions (such as a bank or
thrift) and to all other creditors, including private mortgage lenders, and people
who regularly arranges for credit.

The third set of requirements apply to companies that issue credit or debit cards.
Furthermore, the organization has a strong system to make sure that there are detection
and prevention of identity theft. It has a written program that prevent any identity theft
and in case it happens, it will be detected and mitigated (Vaidya, 2013). There is no
doubt that the organization has fully complied with the Red Flag rule in order to identify
identity theft issues.
Q6. Does the organization have a solid Accounting control over Recovery Audit
Adjustments? And when the organization should respond to RAC audits and
adjustments?
The organization has an accounting department; however, it is not fully in control of the
recovery audit adjustments. It does not have qualified staff who can be entrusted with the
role. Nevertheless, we will have a strong account control over the recovery that ensures
the efficiency and transparency in any transactions in the organization. Moreover, the
organization should respond to RAC in some situations, for example receiving an
announcement of RAC audit adjustments, suspecting that it could have billed for and/or
been received payment for services that are possibly non-reimbursable, and/ or
concerning about some issues that have not been recognized (hfma, 2010).
Q7. What does Gramm-Leach-Bliley Act mean to the hospital? And why should the
organization comply with Privacy and HIPAA?
The privacy of consumer financial information can be controlled by GrammLeach-Bliley Act (GLB). GLB plays a significant role in hospitals that are involved in
financial activities. Consumers have the right to get a notice when the hospital uses their
information. This is an additional requirement from Health Insurance Portability and
Accountability Act (HIPAA) privacy announcement necessities (Druce, 2012).
Moreover, there are many penalties for noncompliance and depend on the level of
negligence and can variety between $100 to $50,000 per violation. An organization
should comply to avoid the penalties and fines for noncompliance regardless other
benefits (Vaidya, 2013). Thus, the organization can decrease the cost when being
committed to HIPAA privacy and security rules.
Q8. What are the new requirements which Charitable Hospitals should satisfy to
be described in section 501r?
When ACA was legislated, the program added new requirements for health care
organizations that operate one or more hospital facilities to achieve the sections
501(c)(3). Each 501(c)(3) organization has to reach some general requirements on a
facility-by-facility basis: Create written financial assistance and emergency medical
care policies; limit expanses charged for emergency or other medically necessary care
to individuals eligible for assistance under the hospital’s financial assistance policy;
conduct a CHNA and adopt an implementation strategy at least once every three years
(IRS, 2015).
Q9. What acts are required or prohibited under the Fair Debt Collection
Practices Act (FDCPA)?
The FDCPA states a number of conditions with which debt collector must comply in
the collection process of a debt, including the following: “Validating the debt
requirement, prohibition against harassing or abusive practices, prohibition against
providing false or misleading information, prohibition against using unfair or
unconscionable means to collect a debt, payments must be applied in accordance with
the consumer’s instructions in the event of multiple debts, and prohibition against
furnishing deception forms” (Experian).
Q10. Conclusion: finally, do you think that we have covered all suitable
precautions in all the topics mentioned in this interview?
In fact, all these topics are meaningful, and I have gain a useful information about
how we can do to avoid violations in compliance. I, also, feel that our discussion was
so educational and valuable. However, reinforcement and emphasizing on the policies
and procedures are essential to maintain the corporate integrity.
I appreciate your time and consideration.
References
Vaidya, A. (2013, March 20). 10 Steps for Ensuring HIPAA Compliance.Retrieved
from:http://www.beckershospitalreview.com/legal-regulatory-issues/10-stepsfor-ensuring-hipaa-compliance.html
Fox, T. (2013, May 23). What Are the Essential Elements of a Corporate Compliance
Program? LexisNexis® Legal Newsroom Corporate. Retrieved from
https://www.lexisnexis.com/legalnewsroom/corporate/b/fcpacompliance/archive/2013/05/23/what-are-the-essential-elements-of-acorporate-compliance-program.aspx
Fogel, L. (2004). Making the Commitment to Compliance. Retrieved from
https://oig.hhs.gov/faqs/corporate-integrity-agreements-faq.asp
Houseman, T. (2015, November 18). Top Questions About Healthcare Revenue Cycle
Management. Group one health source. Retrieved from
http://www.grouponehealthsource.com/blog/bid/73843/questions-andanswers-about-revenue-cycle-management
Virtual Office Ware Healthcare Solutions. (2000). Is the cost of the ICD-10
implementation worth making the transition? Retrieved from
http://vowhs.com/icd-10-qa/
Lane, M. C. (2011, August 16). The Responsible Corporate Officer Doctrine: Finding
Executives Guilty of Crimes for What They Don’t Know. Retrieved
from:http://www.wnj.com/Publications/The-Responsible-Corporate-OfficerDoctrine-Findi
Meidl, H. Karlson, M. (2012). The Rise of the RCO Doctrine in Health Care.
HFMA. (2010). Accounting for RAC Audit Adjustments and Exposures.
Retrieved from: https://www.hfma.org/RACAccounting/
Druce, M. (2012). Ensuring Compliance with Consumer Credit Laws. Retrieved
from: http://www.carepayment.com/hospital/resources.html
IRS. (2015, June 5). New Requirements for 501(c)(3) Hospitals Under the Affordable
Care Act.retrieved from:https://www.irs.gov
Experian. (n.d.). FDCPA Compliance. Fair Debt Collection Practices Act (FDCPA)
and Large Debt Collection Participants. Retrieved from:
http://www.experian.com/regulatory-compliance/consumerinformation/fdcpa-and-large-debt-collection-participants.html
AGENDA
Compliance Interview
November 5, 2017
10 AM – 10.45 AM
Meeting called by (……………)
Attendees:
Corporate Compliance Officer
Location:
Meeting Room (1031)
10:00 – 10:04 AM
Introduction
10:05 – 10:08 AM
10:09 – 10:12 AM
10:13 – 10:16 AM
10:17 – 10:19 AM
10:20 – 10:22 AM
Corporate Compliance Plan
Corporate Integrity Agreement
Revenue Cycle Function
Responsible Corporate Officer Doctrine
Break
10:23 – 10:26 AM
10:27 – 10:30 AM
10:31 – 10:33 AM
10:34 – 10:35 AM
FDA Red Flag Rules
Accounting control over Recovery Audit
Adjustments
Privacy and HIPAA
Break
10:36 – 10:38 AM
10:39 – 10:42 AM
10:43 – 10:45AM
Treasury regulations section 501r
Fair Debt Collection Practices Act (FDCPA)
Conclusion
The objective of the meeting:
• Learning the level of readiness, education, and training of the department
staff as it relates to compliance. In order to obtain an accurate picture.
• Reviewing the organization performs as they relate to the main topics.
Additional Instruction:
A copy of the interview agenda has to be sent prior the meeting.
Q1. What are the critical elements of a Corporate Compliance Plan? And what
are major threats that affect the compliance to a plan?
There are various critical components of a Corporate Compliance Plan. Firstly, a
successful compliance plan has to be created on a solid establishment of ethics that
are fully and openly authorized by top administration. Another component of a solid
compliance program is appropriately training company officers, staff and third parties
on relevant regulations, laws, corporate policies and prohibited conduct (Fox, 2013).
Furthermore, there are many major threats that affect the compliance to a plan, for
example, lack of commitment, inadequate policies and procedures, and ignoring
identified problems. Organization have to display its commitment to the compliance
plan. If the compliance officer and compliance committee are uncreative, compliance
would not be apparent as a high priority. Moreover, Policies and procedures have to
be clear, accurate, and written in order to avoid any errors and variation from standard
operating procedures (Fogel, 2004).
Q2. What is a Corporate Integrity Agreement? And how can the organization
deal with the concerns which make the organization at a risk of Corporate
Integrity Agreement?
A corporate integrity agreement (CIA) is a document that shapes the obligations to
which an entity agrees as part of a civil settlement. “An entity agrees to the CIA
obligations in exchange for the Office of Inspector General’s (OIG) agreement that it will
not seek to exclude the entity from participation in Medicare, Medicaid, or other Federal
health care programs (OIG)”.
Moreover, the organization has already created a compliance plan, and it is committed to
make sure that it will comply with the whole set standards. In other words, it works
effectively to identify and predict any corporate integrity agreement risk in the
organization. On the other hand, the organization is committed to offering training to the
staff on several issues (Vaidya, 2013). Furthermore, a copy of the corporate integrity
agreement and policies had already been distributed in each department, and there is a
qualified trainer who explains anything that is not understood in the agreement weekly.
Q3. What are the essential components of effective Revenue Cycle Management?
And is the cost of the The International Classification of Diseases, Tenth Edition
(ICD-10) implementation worth making the transition?
There are several essential factors that lead to an effective revenue cycle management.
Development of software that automates the procedures is the first essential factors. In
other words, web-based services which allow patients to deal with the billing cycle
and contact with the providers when they need them. Moreover, real-time insurance
verification is one of the essential factors. Revenue cycle management systems with
built-in “rules engines” can prevent mistakes and give information such as copayments and possible mistakes in insurance claims before they occur (Houseman,
2015). Regarding to the cost of ICD-10 implementation, there are costs related to
implementation of ICD-10, likewise there are costs to implement any healthcare
change. The size of the healthcare organization determines the cost of implementation
ICD-10. In fact, any delaying in implementation ICD-10 will cost the industry money.
Furthermore, there is an economic and public health cost from the continual use of
ICD-9 because of the reliance on inaccurate data (Virtual Office Ware).
Q4. How can the officers in the organization keep themselves protected from the
Responsible Corporate Officer Doctrine? And would you give me examples of
misbehavior for which the Human Services’ Office of Inspector General may
seek to exclude officers under the RCO doctrine?
The officers in the organization must do their best to make sure that they address the
compliance issues. The officers, also, have to be in the forefront in encouraging
training as well as compliance, thus to make sure that the issues related to compliance
are addressed. Therefore, the chances of noncompliance will be decreased, and the
officers will not face the risk of Responsible Corporate Officer Doctrine (Lane, 2011).
Moreover, there are many examples of misbehavior may seek to exclude officers:

“Systemic organization compliance violations, including financial misconduct,
suggestive of a lack of institutional control

Intentional refusal by executives to respond to compliance misconduct

Evidence of obstruction of justice

Recidivist corporate behavior

Situations where management or board members failed to act in the face of a
known duty to act demonstrating a disregard for their compliance obligations”
(Meidl, 2012).
Q5. Who is covered by the new Identity Theft Regulations? And what did the
organization do in regards to complying with the FDA Red Flag rules?
There are three different sets of requirements of the Identity Theft Regulations, and each
set applies to different parties:

The first requirement deals with address discrepancies, and applies to all users of
consumer reports.

The second group of requirements deals with identity theft prevention (the so
called “red flags”) and applies to all financial institutions (such as a bank or
thrift) and to all other creditors, including private mortgage lenders, and people
who regularly arranges for credit.

The third set of requirements apply to companies that issue credit or debit cards.
Furthermore, the organization has a strong system to make sure that there are detection
and prevention of identity theft. It has a written program that prevent any identity theft
and in case it happens, it will be detected and mitigated (Vaidya, 2013). There is no
doubt that the organization has fully complied with the Red Flag rule in order to identify
identity theft issues.
Q6. Does the organization have a solid Accounting control over Recovery Audit
Adjustments? And when the organization should respond to RAC audits and
adjustments?
The organization has an accounting department; however, it is not fully in control of the
recovery audit adjustments. It does not have qualified staff who can be entrusted with the
role. Nevertheless, we will have a strong account control over the recovery that ensures
the efficiency …
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