First Healthcare Compliance CONNECT- July 2016

®
CONNECT
July 2016
An Exclusive Monthly Publication for Clients
Compliance Myths:
DEBUNKED
Meet
our
Staff!
2016 OIG Work
Plan Updates
Partner Spotlight:
Coding Strategies

Important Compliance Dates
July
3
New fire safety requirements for certain healthcare facilities
compliance by July 3, 2016
July
5
August
1
August
1
September
6
September
30
Providers new to the EHR incentive program will be able
to attest online for any 90 day reporting period for 2016
starting July 5, 2016
Increasing penalties for FCA violations effective August
1, 2016
OSHA Penalty Adjustments to take effect August 1, 2016
CMS removing the HCAHPS Pain Management dimension
from the Hospital Value-Based Purchasing (VBP)
Program for CY 2017. Comment period ends September
6, 2016
One-year grace period for ICD-10 ends September 30,
2016
In This Issue:
Important Compliance Dates
Meet the Staff
Did You Receive an OCR Notice for the Phase 2 Audit? What’s Next?
4 Compliance Myths: Debunked
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First Healthcare Compliance, LLC © 2016

Meet the Staff
We are excited to introduce to you to members of the First Healthcare
Compliance team!
Ebony McNeill
Client Services Specialist
What aspect of your role do you enjoy the most?
My favorite part of my job is working with our clients. On days when I walk in thinking
I don’t have much on my schedule, I’m always pleasantly surprised to find out that I’m
busy all day long helping to support our clients’ on-the-spot needs. Our conversations
involve everything from training needs to technical support to compliance questions.
I enjoy building relationships with them. It makes even the most difficult tasks feel
like fun challenges. I want every practice, hospital, billing company and skilled care
nursing facility to feel that they receive my all.
Before working at First Healthcare Compliance, what was the most unusual or interesting job you ever had?
Most of my experience has been with banking institutions, but something unusual for me was when I worked for a lighting,
sign and electrical services company. I had to learn about all the different types of lights, signs and emergency lighting.
Most people don’t realize there are so many different types of signs and emergency lighting. It’s funny now when I look at
store signs or emergency lighting, I can still identify the lighting style!
Would you rather be a tiny elephant or a giant hamster?
I think I would say the tiny elephant. In many cultures the elephant is seen as a symbol of honor. It is also praised for its
wisdom, cooperative spirit and loyalty. It represents moderation and eternity. Those are all qualities I admire.
Updates to the 2016 OIG Work Plan
Partner Spotlight: Coding Strategies
Upcoming Webinar Calendar
First Healthcare Compliance Referral Program
Contact Toll Free: 888-54-FIRST 3

Are your employees
due for their annual
training?
We are excited to
announce new versions
of our OSHA, HIPAA
and GHS training
modules!
These new videos give
you more choices when
assigning the federally
required modules.
By Sheba Vine, JD, CPCO
Now that OCR has officially started the Phase 2
HIPAA Audit Program, are you adequately prepared
to be an auditee? OCR is currently compiling
its pools of potential auditees that will be selected
at random for auditing purposes. Many healthcare
providers have already received this OCR notice
requesting verification of contact information which
must be responded to within 14 days. While this
notice does not necessarily indicate that the provider
will be audited, the provider will be entered
into the pool of potential auditees. In conducting its
data gathering efforts, OCR will also request completion
of an Audit Pre-Screening Questionnaire to
gather information on the size, type, and operations
of potential auditees, which can be viewed on the
HHS website.
1st Round- Desk Audits
The first round of audits will be in the form of desk
audits, which is scheduled to be completed by
December 2016. These desk audits will be completed
in two sets, with the first set focused on
covered entities and the second set focused on
business associates. Selected auditees will receive
email notification from OCR along with an initial
request for documentation and data. Auditees
will only have 10 business days to respond to the
request by submitting the requested information
via OCR’s new secure online portal. Providers
will be required to identify and provide detailed
information on each of its business associates.
And depending on the findings of the desk audit,
auditees may be subject to a subsequent onsite
audit. Upon completion of the desk audit, OCR will
prepare and share its draft findings. Auditees are
granted 10 business days to respond to the draft
findings with any written comments, and OCR will
then issue a final audit report within 30 days.
2nd Round- Onsite Audits
The second round of audits will be conducted in the
form of onsite visits, which will encompass a more
comprehensive examination compared to that of
the desk audit. Selected auditees will receive email
notification from OCR. The on-site audit starts with
an entrance conference that will review the audit
process, followed by the actual audit that can last
from three to five days.
Read more about audit protcol!
All videos contain
up-to-date information
to ensure that your
employees understand
the importance of
OSHA, HIPAA and GHS
guidelines.
Join us on
Social Media!
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First Healthcare Compliance, LLC © 2016

By Julie Sheppard, BSN, JD, CHC
Compliance in healthcare is comprised
of complex laws and
regulations. This complexity often leads
to confusion. It’s not surprising that a
few common myths exist. If you’re
responsible for compliance and would
like to separate fact from fiction, keep
reading.
Myth #1: We’re a small organization
and there’s no way we can be
expected to do all of this.
Unfortunately, organizations of all sizes
are held accountable when it comes to
compliance regulations. Federal fraud,
waste and abuse, HIPAA and OSHA
apply equally. Enforcement occurs
regardless of size.
Myth #2: Our Electronic Health
Records (EHR) takes care of it.
While some EHRs provide great functionality,
there isn’t one system that
serves as a substitute compliance officer
or covers all of the areas of risk.
Myth #3: The policies and procedures
drafted by our attorney are all
we need.
In the past, many organizations maintained
a binder of policies that became
outdated before training or implementation
could occur. Compliance is now
part of the day-to-day operations and
woven into the culture of any organization
striving to follow best practices.
Myth #4: We enter into a Business
Associate Agreement with everyone,
so we’re covered.
Business Associate Agreements are
an important part of managing relationships
with business associates.
Dr. Jill Brooks, our Senior Director of
Education, emphasizes that “covered
entities should be very concerned about
the possibility of a major breach originating
from a business associate.”
For more details about each of these
myths, visit our blog!
Contact Toll Free: 888-54-FIRST 5

By Jill Brooks, MD, CHCO
Fighting fraud, waste and abuse continues to be
the focus of the Department of Health and Human
Services (HHS) and the Office of the Inspector General
(OIG). Almost 80 percent of HHS’ budget is spent on
Medicare, Medicaid and CHIP, totaling near $985
million for FY 2015. The ongoing goal for Center for
Medicare and Medicaid Services (CMS) is to achieve
an accurate and appropriate Medicare payment system
and to increase the efficiency of identification and
recovery of improper payments. The mid-year update
of the 2016 OIG Work Plan includes all of the current
updates, revisions and deletions. Future changes will
include oversight of hospice care, certification surveys
and hospice-worker licensure requirements, skilled
nursing facilities’ compliance with patient admission
requirements and evaluation of CMS’ Fraud Prevention
System.
One notable deletion from the mid-year update is the
removal of the OIG’s evaluation of the Office of Civil
Rights (OCR) for the adequacy of oversight of the
covered entities and business associates regarding
protection of electronic PHI. Let this serve as a warning
that the OCR HIPAA Phase 2 audits are underway
using the revised OCR comprehensive audit protocols.
Highlights of the OIG’s new and revised updates for
hospitals, providers, nursing homes and home health
are as follows:
HOSPITALS- New and Revised Updates:
• Outpatient Outlier Payments for Short-Stay Claims
• Intensity-Modulated Radiation Therapy
• Medicare Oversight of Provider Based Status
• Analysis of Salaries Included in Hospital Cost
Reports
NURSING HOMES- New Updates:
• Skilled Nursing Facility Prospective Payment
System Requirements
• Potentially Avoidable Hospitalizations of Medicare
and Medicaid Eligible Nursing Home
• National Background Check Program for Long-
Term Care Employees
HOME HEALTH- New and Revised Updates:
• Medicare Home Health Fraud Indicators
• Oversight and Effectiveness of Medicaid Waivers
• Home Health Prospective Payment System
Requirements
OTHER PROVIDER AND SUPPLIERS- New Updates:
• CMS’ Implementation of New Medicare Payment
System for Clinical Diagnostic Laboratory Tests–
Mandatory Review
For more information about each of these updates,
review the full article here.
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First Healthcare Compliance, LLC © 2016

Partner Link
An Interview with Melody Mulaik, President of Coding
Strategies.
How does Coding Strategies support compliance
professionals?
We work with clients to accurately identify compliance
risks and current areas of concern to make sure these
are addressed in a practical and appropriate manner.
We also focus on providing relevant and to-the-point
education to help prevent future compliance issues.
What do you see as the biggest compliance risk
related to coding?
One of the most common compliance concerns clients
have relates to provider documentation. We work
closely with our clients to understand their scope of
services and then with this knowledge we review
provider documentation. As educators, our goal is to
provide feedback on areas our clients can focus on for
improvement. We see ourselves as a member of their
team working with them to achieve a common purpose
– complete and accurate documentation, appropriate
coding and timely reimbursement.
As educators, what do you enjoy most about working
with your clients?
One of our favorite types of engagements is when we
get to work directly with the physicians. Because so
much in the coding and compliance arena hinges on
the physician’s documentation, working directly with
them to identify areas of concern and respond to their
questions is vital to achieving everyone’s goals. We like
to think of ourselves as translators for the physicians
because we take the coding/documentation requirements
and present them in a way that makes sense
clinically to the physician.
Coding Strategies has created a special offer
for First Healthcare Compliance clients:
Coding Strategies is pleased to offer two special pricing
options for the auditing of E&M and/or office based
procedures.
Offer #1: Their expert consultants will perform a case-bycase
review of 10 electronic encounters per provider for the
reduced rate of $350 per provider.
or
Offer #2: Their expert consultants will review 50 electronic
encounters of your choosing for the reduced rate of $1,500.
Both offers include an executive summary identifying trends
and potential opportunities for further review.
For more information, call
877.626.3464 or email
karen.perts@codingstrategies.com
Note: This offer expires
on December 31, 2016.
If you missed the July 13th webinar on ICD-10 Updates for 2017 with
Karna Morrow of Coding Strategies, it is now available on our YouTube
channel and will be available as an assignable training module!
Contact Toll Free: 888-54-FIRST 7

Join Us for These Upcoming Webinars
and Earn Complimentary CEU Credits!
July 19th @12pm EDT
OSHA for Medical and Dental Office
Employees
Kelly Ogle, BSDH, MIOP, CMP, CHOP
Doctor’s Management
August 16th @12pm EDT
Three Recent HIPAA Breaches
Encryption Failed to Prevent
Mary Beth Gettins, Esq.
Gettins’ Law
November 15th @12pm EST
Enterprise Risk Management in
Healthcare
Mike Midgley, RN, JD, MPH,
CPHRM, FASHRM
Swiss Re
December 13th @12pm EST
Is a Firewall Enough Security for My
Business?
Albert Whale, CEH, CHS, CISA, CISSP
IT Security, Inc.
September 20th @12pm EDT
Dealing with Bullying in the
Workplace
Lauren Russell, Esq.
Young Conaway Stargatt & Taylor, LLP
October 11th @12pm EDT
What Healthcare Employers Should
Know About Exclusion Screening
PreCheck
First Healthcare Compliance Referral Program
Don’t forget about our referral program! The tremendous growth realized
during our first few years in business was derived primarily from our
clients’ endorsements and referrals. We are so grateful for this, and for the
opportunity to continue helping your practice achieve its compliance goals.
Give us a call today, or visit the “My Account” section of your compliance
portal to get more information about current rewards. We look forward to
making new connections through your support!
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First Healthcare Compliance, LLC © 2016