Steven Baruch - Health Care Compliance Association

Publisher:
Health Care Compliance Association, 888-580-8373
Executive Editor:
Roy Snell, CEO, roy.snell@hcca-info.org
Contributing Editor:
Gabriel Imperato, Esq., CHC
Editor:
Margaret R. Dragon, 781-593-4924, margaret.dragon@hcca-info.org
Copy Editor:
Patricia Mees, CHC, CCEP, 888-580-8373, patricia.mees@hcca-info.org
Layout and Production Manager:
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HCCA Officers:
Jennifer O’Brien, JD, CHC
HCCA President
Medicare Compliance Officer
UnitedHealth Group
Frank Sheeder, JD, CCEP
HCCA 1st Vice President
Partner
Jones Day
Shawn Y. DeGroot, CHC-F, CHRC, CCEP
HCCA 2nd Vice President
Vice President Of Corporate Responsibility
Regional Health
John C. Falcetano, CHC-F, CIA, CCEP-F, CHRC
HCCA Treasurer
Chief Audit/Compliance Officer
University Health Systems
of Eastern Carolina
Catherine M. Boerner, JD, CHC
HCCA Secretary
President
Boerner Consulting, LLC
Daniel Roach, Esq.
Non-Officer Board Member
to the Executive Committee
Vice President Compliance and Audit
Catholic Healthcare West
Julene Brown, RN, MSN, BSN, CHC, CPC
HCCA Immediate Past President
Director of Corporate Compliance
Innovis Health
CEO/Executive Director:
Roy Snell, CHC, CCEP-F
Health Care Compliance Association
Counsel:
Keith Halleland, Esq.
Halleland Habicht PA
Board of Directors:
Urton Anderson, PhD, CCEP
Chair, Department of Accounting and
Clark W. Thompson Jr. Professor in
Accounting Education
McCombs School of Business
University of Texas
Marti Arvin, JD, CPC, CCEP-F, CHC-F, CHRC
Chief Compliance Officer
UCLA Health Sciences
Angelique P. Dorsey, JD, CHRC
Research Compliance Director
MedStar Health
Brian Flood, JD, CHC, CIG, AHFI, CFS
National Managing Director
KPMG LLP
Margaret Hambleton, MBA, CPHRM, CHC
Senior Vice President
Ministry Integrity, Chief Compliance Officer
St. Joseph Health System
Dave Heller
VP and Chief Ethics and Compliance Officer
Edison International
Rory Jaffe, MD, MBA
Executive Director, California Hospital Patient
Safety Organization (CHPSO)
Matthew F. Tormey, JD, CHC
Vice President
Compliance, Internal Audit, and Security
Health Management Associates
Debbie Troklus, CHC-F, CCEP-F, CHRC
Assistant Vice President
for Health Affairs/Compliance
University of Louisville
Sheryl Vacca, CHC-F, CCEP, CHRC
Senior Vice President/Chief Compliance
and Audit Officer
University of California
Sara Kay Wheeler, JD
Partner–Attorney
King & Spalding
Compliance Today (CT) (ISSN 1523-8466) is published by the Health Care
Compliance Association (HCCA), 6500 Barrie Road, Suite 250, Minneapolis, MN
55435. Periodicals postage-paid at Minneapolis, MN 55435. Postmaster: Send
address changes to Compliance Today, 6500 Barrie Road, Suite 250, Minneapolis,
MN 55435. Copyright 2010 Health Care Compliance Association. All rights
reserved. Printed in the USA. Except where specifically encouraged, no part of this
publication may be reproduced, in any form or by any means without prior written
consent of the HCCA. For Advertising rates, call Margaret Dragon at 781-593-
4924. Send press releases to M. Dragon, 41 Valley Road, Nahant, MA 01908.
Opinions expressed are not those of this publication or the HCCA. Mention of
products and services does not constitute endorsement. Neither the HCCA nor
CT is engaged in rendering legal or other professional services. If such assistance is
needed, readers should consult professional counsel or other professional advisors for
specific legal or ethical questions.
Health Care Compliance Association • 888-580-8373 • www.hcca-info.org
INSIDE
4 CEU: Mobility disabilities: A technical assistance manual
for health care providers By David H. Ganz and Gary W. Herschman
New guidance on the accommodations that are required when
providing accessible care for patients with disabilities.
9 RACs are coming to Medicare Advantage, Part D and
Medicaid By Gloryanne Bryant
An expansion of RAC oversight means more time and resources
will be needed and annual work plans may need revision.
10 Provider signature guidelines and solutions: Autograph
please! By Janet Marcus
Verifiable author of record signatures on medical records are key
for continuity of care and smooth claims processing.
13 Social Networking By John Falcetano
14 Meet the first CHC-F Candidate: Steven Baruch, Sutter
Health/Alta Bates Summit Medical Center
An interview by Debbie Troklus
16 Newly Certified CHCs and CHRCs
17 Letter from the CEO By Roy Snell
Whistleblower
22 CEU: The complexity of compliance basics: A CCO’s
pursuit of knowledge By H. Rebecca Ness
Compliance professionals need a wealth of knowledge and more
than ordinary management skills to succeed.
24 The evolving role of the chief compliance and ethics
officer: A survey by the HCCA and SCCE By Adam Turteltaub
Publicly traded, privately held, and non-profit entities vary widely
on factors that affect the independence of compliance professionals.
26 Physician compliance education outside of the hospital
environment By Kia R. Earp
A savvy office manager will keep compliance issues on the radar
and keep the physicians and office staff informed to prevent fraud.
29 Compliance 101: Stark and academic medical centers:
A primer By Kenneth DeVille and Joan A. Kavuru
A broad introduction to basic Stark issues to help compliance
professionals find trouble spots that require further legal assistance.
34 Health care reform and its effect on compliance
programs By Cathy Cahill-Egolf
As the regulatory landscape changes, new methods to combat
fraud, waste, and abuse may change the way we do business.
38 CEU: Feature Focus: Federal medical record requests:
Setting up a RAC and CERT response team
By Michael G. Calahan
An effective, three-step approach to help you stay ahead of the
curve as the number of record requests increases.
42 Patient visits: Reforms increase provider responsibilities
By Angela Miller
Providers are required to make more face-to-face visits and be
prepared to justify billing for services based on medical records.
44 Individual liability for health care fraud: Enforcement
agencies raise the stakes By Gabriel L. Imperato
Recent settlements demonstrate the government’s willingness to
hold individuals accountable, not just organizations.
46 Medicare beneficiaries remain vulnerable to Medicare
Advantage marketing schemes By Mark Stiglitz
CMS is working to remove agents who don’t play by the rules.
49 New HCCA Members
3
December 2010