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Publisher:
Health Care Compliance Association, 888-580-8373
Executive Editor:
Roy Snell, CEO, roy.snell@hcca-info.org
Contributing Editor:
Gabriel Imperato, JD, CHC, 888-580-8373
Manager, Articles and Advertisments:
Margaret R. Dragon, 781-593-4924, margaret.dragon@hcca-info.org
Communications Editor:
Patricia Mees, CHC, CCEP, 888-580-8373, patricia.mees@hcca-info.org
Layout:
Gary DeVaan, 888-580-8373, gary.devaan@hcca-info.org
HCCA Officers:
Rory Jaffe, MD, MBA, CHC
HCCA President
Julene Brown, RN, BSN, CHC, CPC
HCCA 1st Vice President
Billing Compliance Manager
MeritCare Health System
Jennifer O’Brien, JD, CHC
HCCA 2nd Vice President
Shareholder
Halleland Lewis Nilan & Johnson PA
Urton Anderson, PhD, CCEP
HCCA Treasurer
Chair, Department of Accounting and
Clark W. Thompson Jr. Professor in
Accounting Education
McCombs School of Business
University of Texas
Gabriel Imperato, Esq, CHC
HCCA Secretary
Managing Partner
Broad and Cassel
Shawn Y. DeGroot, CHC-F, CCEP
Non-Officer Board Member of
Executive Committee
Vice President Of Corporate Responsibility
Regional Health
Steven Ortquist, JD, CHC-F, CCEP, CHRC
HCCA Immediate Past President
Partner
Meade & Roach
CEO/Executive Director:
Roy Snell, CHC, CCEP
Health Care Compliance Association
Counsel:
Keith Halleland, Esq.
Halleland Lewis Nilan & Johnson PA
Board of Directors:
Marti Arvin, JD, CHC-f, CPC, CCEP, CHRC
Privacy Officer
University of Louisville
Angelique P. Dorsey, CHRC
Research Compliance Director
MedStar Health
Dave Heller
Chief Ethics & Compliance Officer
Qwest Communications
Joseph Murphy, JD, CCEP
Co-Founder Integrity Interactive
Co-Editor ethikos
Karen A. Murray, MBA, FACHE, CHC, CHA
Corporate Compliance Officer
Yale New Haven Hospital
F. Lisa Murtha, JD, CHC
Managing Director
Huron Consulting Group
Daniel Roach, Esq.
Vice President Compliance and Audit
Catholic Healthcare West
Frank Sheeder, JD, CCEP
Partner
Jones Day
Debbie Troklus, CHC-F, CCEP, 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
Greg Warner, CHC
Director for Compliance
Mayo Clinic
Compliance Today (CT) (ISSN 1523-8466) is published by the Health Care Compliance
Association (HCCA), 6500 Barrie Road, Suite 250, Minneapolis, MN 55435. Subscription
rate is $295 a year for nonmembers. Periodicals postage-paid at Minneapolis, MN
55435. Postmaster: Send address changes to Compliance Today, 6500 Barrie Road,
Suite 250, Minneapolis, MN 55435. Copyright 2008 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 subscription information and advertising rates, call Margaret Dragon
at 781-593-4924. Send press releases to M. Dragon, PO Box 197, 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.
4 Cultural competency standards: Using the GAO Yellow Book
elements — By Maria B.J. Chun
9 Introducing Compliance & Ethics Social Networking
— By Shawn Leonard
10 What CMS gives, the courts take way: Patients in ambulances
and EMTALA — By Jeffrey Fitzgerald
14 Meet Cathy Garrey, Compliance and Quality Assurance Manager,
McHenry County Mental Health Board
— an interview by Gabriel L. Imperato
19 Letter from the CEO — By Roy Snell
21 Organizational compliance culture: What message is your board
and senior management sending — By Jeff Sinaiko
23 Medicare’s medical necessity criteria: A mystery in the making
— By Lester J. Perling
27 Exploring the question: Does this really make a compliance
program “effective” — By Catherine Boerner
30 Newly Certified CHCs
31 Certification – The recognized mark of a professional
— By Margaret Dragon
32 CEU: The 1-2-3s of claims sampling to resolve overpayment
errors — By B. Bo Martin
36 Improving competitiveness and compliance through agent/broker
online training — By Susan Mollet and Martha Braunstein
38 Feature focus: Coordinating external requests for information in
the Compliance Office — By Cornelia M. Dorfschmid
43 The what, why, and how of Medicare Coverage Analysis – Part 1
— By Ofer Amit
46 CEU: Quality of care and compliance: Existing challenges
and first steps for hospitals — By Cheryl L. Wagonhurst and
Nathaniel M. Lacktman
48 Conference Calendar 2009
53 SEC Disclosure: Managing information at FDA-regulated
companies — By Elizabeth P. Gray and Jessica Matelis
54 Go Local – Upcoming Regional Conferences
59 CEU: Complying with the HIPAA Privacy Rule: What you need to
know — By Rebecca C. Fayed
72 New principles can help advance independent corporate
monitoring — By Vincent L. DiCianni.
78 Newly Certified CHRC
82 Compliance Today Editorial Board
83 Ask Leadership
84 Corruption enforcement actions target foreign doctors and hospital
employees — By Robert Christopher Cook and Louis P. Gabel
86 Category B device trials: Looking forward and backward
— By Sumathy Sundarababu
90 New HCCA Members
Health Care Compliance Association • 888-580-8373 • www.hcca-info.org
3
October 2008