First Healthcare Compliance CONNECT February 2022
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<strong>CONNECT</strong><br />
<strong>February</strong> <strong>2022</strong><br />
<br />
A Monthly Publication for the <strong>Healthcare</strong> <strong>Compliance</strong> Community<br />
FAQ Corner:<br />
Do we need to keep a log<br />
of sample medications<br />
dispensed to patients?<br />
Infographic:<br />
10 Common OSHA<br />
Violations in the<br />
<strong>Healthcare</strong> Setting<br />
What is OSHA<br />
<strong>Compliance</strong> Training?<br />
Welcome to our Newest<br />
Editorial Council Members<br />
1st Talk <strong>Compliance</strong>:<br />
Fraud, <strong>Healthcare</strong>, COVID-19<br />
and the False Claims Act
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In This Issue:<br />
<strong>Compliance</strong> Super Ninja<br />
FAQ Corner: Do we need to keep a log of<br />
sample medications dispensed to patients?<br />
Infographic: 10 Common OSHA Violations in<br />
the <strong>Healthcare</strong> Setting<br />
What is OSHA <strong>Compliance</strong> Training?<br />
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<strong>Compliance</strong> Super Ninja <br />
Lisa Filler, HR Generalist<br />
Elevate Women’s Health<br />
How would you describe your experience with <strong>First</strong><br />
<strong>Healthcare</strong> <strong>Compliance</strong>?<br />
1st <strong>Compliance</strong> is very thorough and adaptive to the changing times especially<br />
with the new COVID regulations. I have really enjoyed their expertise.<br />
What do you enjoy most about working with The Women’s Health Group?<br />
Women’s Health is a passion of mine. This entire group from the top down makes sure women are taken care<br />
of and are the highest priority of our day.<br />
Would you rather be a superhero or the world’s best chef? Why?<br />
HMMMMMM this is a hard one. I am going with the chef! Feeding the family and them loving the meal is the<br />
best feeling! Not to mention toddlers eat nothing lol.<br />
Welcome to our Newest Editorial Council<br />
Members<br />
Honoring Our 2021 Presenter of the Year<br />
Contact Toll Free: 888-54-FIRST 3
FAQ Corner<br />
Do we need to keep a log of sample medications dispensed to patients?<br />
Yes. Your organization should have a process for managing all medications received and dispensed to track<br />
outdated and recalled medications and to be able to trace back dispensed medications.<br />
All sample medications received from pharmaceutical companies must be documented in an inventory log.<br />
A patient distribution log should be used to track medications that are dispensed to patients. We provide<br />
sample logs for this purpose in the document library of the Quarterly zone.<br />
In addition, medications must be stored in a secure area to prevent unauthorized access and all<br />
manufacturer recommendations regarding storage should be followed. Click here for our blog on the<br />
subject.<br />
Explore the FAQs tab in your compliance solution<br />
to find answers to your compliance questions!<br />
CLIENT<br />
ALERT<br />
The Most Comprehensive<br />
<strong>Healthcare</strong> <strong>Compliance</strong> Course<br />
The Fundamentals is a user-friendly, four-module<br />
online course designed to help healthcare professionals<br />
understand the essential principles and practices of<br />
compliance.<br />
BUY COURSE NOW<br />
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Contact Toll Free: 888-54-FIRST 5
What is OSHA <strong>Compliance</strong> Training?<br />
<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong> Staff<br />
Congress created the Occupational Safety and Health<br />
Administration, more commonly known as OSHA,<br />
following the passage of the Occupational Safety<br />
and Health Act of 1970 to enforce workplace laws<br />
and standards, as well as provide training, outreach,<br />
education and assistance.<br />
OSHA coverage extends to most private sector employers<br />
and their workers. For this article, we’re going to focus<br />
on the healthcare sector and how employers can<br />
maintain a safe working environment for their employees.<br />
Worker Safety in Hospitals<br />
Did you know that a hospital is one of the most<br />
hazardous places to work? In 2019, U.S. hospitals<br />
recorded 221,400 work-related injuries and illnesses,<br />
which is almost twice the rate for the private industry.<br />
There are several reasons for this, including the<br />
manual lifting of patients, caregiver fatigue, exposure<br />
to chemicals and drugs, exposure to communicable or<br />
infectious diseases, violence, and stress. These injuries<br />
and illnesses come at a high cost for the healthcare<br />
injury.<br />
To create safe working conditions and decrease the<br />
number of injuries and illnesses in hospitals and<br />
healthcare facilities, healthcare employers must comply<br />
with OSHA regulations. Learning about these guidelines<br />
through OSHA compliance training is imperative.<br />
What Is Included in <strong>Healthcare</strong> Employee<br />
OSHA Training?<br />
Employers must develop a comprehensive training<br />
program and provide employees with annual training.<br />
Training content must be up-to-date and aligned with the<br />
U.N. Globally Harmonized System of Classification and<br />
Labeling of chemicals (GHS).<br />
New employees must be informed about the hazardous<br />
chemicals they will potentially be exposed to during the<br />
workday and receive additional training whenever there<br />
are changes to existing chemical hazards and/or new<br />
hazardous chemicals are brought into the workplace.<br />
Employee training should include a detailed explanation<br />
of the GHS label requirements and the 16-section Safety<br />
Data Sheet format. Employees must also know where<br />
Safety Data Sheets are kept in the workplace so that<br />
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they can find them quickly in the event of an emergency.<br />
Training should also instruct on methods to detect the<br />
presence or release of hazardous chemicals.<br />
Under the Occupational Safety and Health Act, OSHA<br />
has the authority to issue workplace health and safety<br />
regulations known as OSHA Standards. There are nine<br />
OSHA standards that are most frequently addressed<br />
regarding the healthcare industry.<br />
• The Hazard Communication Standard<br />
• Bloodborne Pathogens Standard<br />
• Ionizing Radiation Standard<br />
• Emergency Action Plan Standard<br />
• Fire Safety Standard<br />
• Medical and <strong>First</strong> Aid Standard<br />
• Personal Protective Equipment Standard<br />
• Exit Routes Standard<br />
• Electrical Safety Standard<br />
Where Can You Receive OSHA Training?<br />
<strong>Healthcare</strong> employers can receive OSHA training from 1st<br />
<strong>Healthcare</strong> <strong>Compliance</strong>. The module includes the OSHA<br />
standards that healthcare providers must comply with,<br />
as well as the consequences of OSHA violations and a<br />
plan for OSHA compliance. Our 1stPrep training solution<br />
includes a library with hundreds of modules and a virtual<br />
training log which is helpful in case of an audit.<br />
Furthermore, <strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong> offers<br />
comprehensive compliance management software that<br />
will help your healthcare organization stay in compliance<br />
with OSHA, HIPAA and fraud, waste, and abuse laws.<br />
With our flexible, scalable software, you’re able to<br />
share, track and manage compliance, as well as view<br />
compliance status across all locations in real time.<br />
Have the peace of mind that your healthcare organization<br />
is compliant in all federal healthcare regulatory areas.<br />
Contact us today and learn how we can help you stay<br />
current in OSHA training for employees and more.<br />
COVID-19 <strong>Healthcare</strong><br />
<strong>Compliance</strong> Updates<br />
In response to the global outbreak of the novel coronavirus<br />
disease (COVID-19), the Secretary of Health and Human<br />
Services declared a public health emergency on January 31,<br />
2020. Federal agencies have taken action by issuing updates<br />
and guidance to navigate the crisis. This ebook provides<br />
healthcare providers with important developments and<br />
resources that impact federal healthcare laws.<br />
DOWNLOAD NOW<br />
Contact Toll Free: 888-54-FIRST 7
Welcome to our Newest<br />
Editorial Council Members<br />
Catherine Short<br />
The <strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong> team<br />
aspires to excellence in healthcare<br />
compliance education, and we’re honored<br />
to serve as a trusted resource for<br />
thousands of compliance professionals,<br />
healthcare administrators, providers, and<br />
business associates throughout the United<br />
States. Our growing Editorial Council<br />
provides collaborative expertise in a broad<br />
range of complex topics. Please join us in<br />
welcoming our two newest members of<br />
this impressive Editorial Council.<br />
employee terminations—with the goal of avoiding<br />
litigation before it begins. Her counseling practice<br />
includes handbook revisions, effective policy<br />
implementation, and on-site training on legal<br />
compliance.<br />
Lauren has developed and conducts specialized<br />
in-house training for emerging legal issues<br />
including the pregnancy, reproductive rights,<br />
and family care provisions of the Delaware<br />
Discrimination in Employment Act. One of her<br />
current programs outlines the complexities of the<br />
Lauren Moak Russell<br />
Lauren specializes in the representation of employers<br />
on a range of issues relating to compliance with<br />
local, state, and federal labor and employment<br />
laws and constitutional provisions. She provides<br />
compassionate and responsive counsel, targeted at<br />
achieving client goals while minimizing cost and risk.<br />
Lauren emphasizes client counseling—on issues<br />
ranging from wage and hour compliance, to<br />
workplace training and investigations, to effective<br />
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#MeToo movement and offers executives essential<br />
information on harassment avoidance and modifying<br />
corporate culture. Lauren also conducts high-level<br />
investigations of discrimination and harassment on<br />
behalf of employers.<br />
When litigation becomes necessary, Lauren is a<br />
dedicated advocate, aggressively pursuing her clients’<br />
best interests and providing clear guidance at each<br />
stage of the proceeding. Lauren has litigated a wide<br />
variety of employment-related matters to successful<br />
resolutions, including employment discrimination,<br />
non-competition, and constitutional law cases.<br />
Lauren has experience in each of Delaware’s state<br />
and federal courts, as well as the U.S. Court of<br />
Appeals for the Third Circuit. Lauren also regularly<br />
assists clients in administrative proceedings before<br />
state and federal administrative agencies, including<br />
the EEOC, the Delaware Office of Anti-Discrimination,<br />
and the Delaware Unemployment Insurance Appeals<br />
Board.<br />
corporate guidance to clients. She has advised<br />
clients on state professional licensure laws, CLIA<br />
standards, state laboratory laws, government and<br />
private payor reimbursement policies and billing<br />
rules, federal and state fraud and abuse rules and<br />
regulations, state telehealth laws, and HIPAA rules<br />
and regulations. She has provided assistance to<br />
entities during licensure and accreditation surveys,<br />
government investigations, and through payor audits<br />
and disputes.<br />
In addition to providing regulatory guidance to<br />
clients, Liz is also knowledgeable in evaluating how<br />
a business opportunity or arrangement implicates<br />
a provider’s unique regulatory framework. Liz has<br />
counseled clients not only on the regulatory aspects<br />
of an arrangement as described above, but she<br />
is also experienced in reviewing and negotiating<br />
relevant contractual and legal documentation<br />
in connection with contemplated business<br />
arrangements.<br />
Elizabeth Sullivan<br />
Liz is Chair of McDonald Hopkins’ national <strong>Healthcare</strong><br />
Practice Group and a member of the firm’s Board<br />
of Directors. She began her legal career in the<br />
<strong>Healthcare</strong> Practice group at McDonald Hopkins and<br />
later served as an attorney in the legal department at<br />
The Cleveland Clinic Foundation before returning to<br />
McDonald Hopkins as a member.<br />
While at the Cleveland Clinic, Liz provided regulatory<br />
advice and transactional guidance to various service<br />
lines, including the clinical laboratory, professional<br />
pathology, imaging, transplant, and remote and<br />
distance health teams. Over the course of her<br />
career, Liz has assisted various types of healthcare<br />
providers, including clinical laboratories, hospitals,<br />
physician specialty groups, telehealth providers,<br />
transplant centers, and surgery centers.<br />
Liz has experience providing regulatory, licensing,<br />
compliance, reimbursement, contractual, and<br />
Liz earned a J.D. and Certificate of Advanced Studies<br />
in Health Law from the University of Pittsburgh<br />
School of Law, an M.A. in Bioethics and a B.A.,<br />
cum laude, in Political Science from Case Western<br />
Reserve University.<br />
Contact Toll Free: 888-54-FIRST 9
Honoring Our 2021<br />
Presenter of the Year<br />
Catherine Short<br />
Each year several thousand healthcare<br />
compliance professionals rely on <strong>First</strong><br />
<strong>Healthcare</strong> <strong>Compliance</strong> complimentary<br />
online education to supplement their<br />
knowledge base and stay up to date.<br />
We’re honored to collaborate with<br />
talented presenters, and we recognize the<br />
presenter of the most popular live webinar<br />
annually.<br />
During 2021 Melody W. Mulaik, a trusted member<br />
of the <strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong> Editorial Council<br />
was featured on our podcast 1st Talk <strong>Compliance</strong><br />
and shared expertise with webinars AUC Delayed but<br />
not Gone and the extremely popular 1,2,3’s of Billing,<br />
Coding, and Auditing.<br />
Melody W. Mulaik is the President of Revenue<br />
Cycle Coding Strategies. She is a frequent speaker<br />
and author for nationally recognized professional<br />
organizations and publications. Melody’s areas<br />
of expertise include coding and compliance,<br />
management engineering, operations improvement<br />
and she is nationally recognized for her extensive<br />
radiology expertise.<br />
Melody often<br />
speaks at national<br />
conferences on many<br />
topics including<br />
Interventional and<br />
Diagnostic Radiology<br />
coding, Internal Audit<br />
Program Development,<br />
Coding <strong>Compliance</strong><br />
and other healthcare<br />
compliance<br />
issues. Recent speaking engagements include the<br />
Association of Community Cancer Centers (ACCC),<br />
AHRA: The Association for Imaging Management,<br />
Radiology Business Management Association (RBMA),<br />
<strong>Healthcare</strong> Billing Management Association (HBMA)<br />
and the Radiological Society of North America (RSNA).<br />
Melody is the AHRA liaison to the American College of<br />
Radiology (ACR) Economics Commission and her firm,<br />
RCCS, serves as consulting support for the Society of<br />
Interventional Radiology (SIR).<br />
Melody is a frequent author for national publications<br />
and writes the bi-monthly coding column for AHRA’s<br />
Radiology Management and the <strong>Healthcare</strong> Billing<br />
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Management Association’s (HBMA) Billing. Her work<br />
has also appeared in RT Image, Imaging Economics,<br />
Radiology Today, and Radiology Business Journal.<br />
Melody co-authored Revenue Cycle Coding Strategies’<br />
Coding Guides for Diagnostic Radiology and<br />
Interventional Radiology.<br />
Prior to her current position, Melody held the position<br />
of Vice President of Billing <strong>Compliance</strong> for the largest<br />
national billing company, where she was responsible<br />
for the implementation, oversight, and maintenance of<br />
the billing compliance program.<br />
Melody holds a Master of Science in Health<br />
Systems (MSHS) degree and a Bachelor of Industrial<br />
Engineering (BIE) degree, both from the Georgia<br />
Institute of Technology (Georgia Tech), in Atlanta,<br />
Georgia. She also holds the professional certification<br />
of Certified Radiology Administrator (CRA), Certified<br />
Professional Coder (CPC), Certified Outpatient Coder<br />
(COC) and Radiology Certified Coder (RCC), and<br />
Radiology Certified Coder – Interventional (RCC-IR).<br />
Melody has achieved Fellow status with the AHRA<br />
(FAHRA) and is a recent recipient of the prestigious<br />
AHRA Gold Award for her organizational and industry<br />
contributions.<br />
C. Trey Scott, Coordinating Attorney at<br />
COVID-19 <strong>Healthcare</strong><br />
Kennedy, Attorneys & Counselors at Law<br />
will present Under Pressure: Reporting<br />
<strong>Compliance</strong><br />
Appeals<br />
Toolkit<br />
for the Fifth Circuit.<br />
Requirements with OCR for Breaches at the<br />
upcoming Virtual HIPAA Privacy and Security<br />
Summit 2021 <strong>Healthcare</strong> on November compliance 18. amidst COVID-19 Summit! presents new challenges<br />
for hospitals and healthcare providers. At top importance is the<br />
Trey received his Bachelor of Science and Master of<br />
Business degrees<br />
question<br />
from Texas<br />
of<br />
Tech<br />
how<br />
University<br />
to slow<br />
and his<br />
or stop the spread of COVID-19, while<br />
ensuring that your organization stays compliant.<br />
Juris Doctorate from Texas Wesleyan University School<br />
of Law (now Texas A&M University School of Law.) While<br />
in law school, Trey was Now a member more than of the ever, arbitration your compliance department needs to have the<br />
necessary tools to help track, analyze, and respond to compliance challenges.<br />
competition team as well as a student bar association<br />
To help navigate the process, we’ve gathered our best COVID-19 resources<br />
representative. He also was a law clerk to the 106th<br />
below. If you need further assistance, please contact us here.<br />
District Court of the State of Texas. Trey has significant<br />
experience in healthcare law. This experience includes:<br />
medical malpractice litigation, administrative and<br />
regulatory appeals and disputes, professional board<br />
VIEW TOOLKIT<br />
United States District Courts for the Northern, Southern,<br />
Eastern, and Western Districts of Texas. Trey is also<br />
licensed to practice before the United States Court of<br />
Click here for more information or to register for the<br />
matters, and overpayment disputes. Trey is licensed to<br />
practice law before Texas State Courts as well as the<br />
Contact Toll Free: 888-54-FIRST 11
Risk Management Considerations for<br />
the <strong>Healthcare</strong> <strong>Compliance</strong> Officer:<br />
Training, Incident Management, Governing Boards,<br />
and Measures Unique to COVID-19<br />
It’s no secret that healthcare is one of America’s most heavily regulated<br />
industries with substantial fines and penalties for non-compliance. Complex<br />
regulations and mandates make compliance management a necessity.<br />
<strong>Healthcare</strong> organizations particularly rely on the skills and attributes of their<br />
compliance officer to navigate the expansive regulatory framework.<br />
DOWNLOAD NOW<br />
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Referral Appreciation Program<br />
Receive a $50 gift card* when you refer a client!<br />
<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong> is delighted to offer<br />
a Referral Appreciation Program to say thank you<br />
for helping us to continue to grow. For each new<br />
1st Professional or 1st Premium client originating<br />
from a referral, <strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong> will<br />
provide a $50 gift card as a token of appreciation.<br />
LEARN MORE<br />
<strong>Healthcare</strong><br />
<strong>Compliance</strong><br />
Symposium<br />
Early Bird<br />
Tickets<br />
Available<br />
now<br />
April 28, <strong>2022</strong><br />
REGISTER NOW<br />
Contact Toll Free: 888-54-FIRST 13
hosted by Catherine Short<br />
Catherine Short speaks with Shauna Itri, Partner at Seeger Weiss LLP on the topic of “Fraud, <strong>Healthcare</strong>,<br />
COVID-19 and the False Claims Act.” A whistleblower or qui tam action can provide financial rewards to<br />
individuals who have information that a company/individual has committed fraud. The primary statutes under<br />
which this relief may be sought are the federal and state False Claims Acts (“FCAs”). In addition to the FCAs,<br />
there are other statutes which apply to tax fraud, securities fraud, and in California, fraud on private insurance<br />
companies. This episode will provide an overview of the False Claims Acts, the knowledge and skills to be<br />
able to recognize a potential whistleblower case, and understand the unique procedures utilized in filing<br />
whistleblower cases/tips. We will also delve into recent trends in cases brought (or that could be brought)<br />
under the False Claims Act including cases involving mined data and potential fraud related to COVID-19.<br />
Listen weekdays at<br />
7:30am, 3:30pm, 11:30pm ET<br />
Check out our Show Page!<br />
Looking for the latest compliance insights?<br />
Subscribe to our feed and don’t miss a thing!<br />
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WORD SEARCH<br />
G J Q G M C S T Z D O E B Z H W L A G E<br />
V Q H F C X L H Z C A C D G F D C S S T<br />
Q V V Q D L B S G G Y I E N P C N L K A<br />
N R E G U L A T I O N T V O R D Q A N N<br />
B L T I C H S U D Z C C I L O R K T J O<br />
J L Z B O B X U P D G A S W F L E I H I<br />
G I G V M Y G B D S H R N T E C K P G S<br />
W E U Y P C P S H R U P E N S U T S N S<br />
A R L E L I O D F O M J H E S L K O I A<br />
I A V I I T O C O T R G E M I T K H D P<br />
B C L S A S Z E Q A A F R E O U R P O M<br />
N H E O N O H K S R L M P S N R O M C O<br />
U T N L C N I Z B T V X M R A E W C D C<br />
G L A S E G P A Z S D R O U L I E H L A<br />
E A V J I A W U Z I X A C B S Y M U E Z<br />
B E G F X I P U T N Y Q Y M S M A G W W<br />
F H W T K D T K J I T H P I C K R J E A<br />
I H P L F S Q N D M M G Y E L E F H Q G<br />
M F W V T L K P G D H Z S R G V D C K S<br />
R P P N F V Q K N A I C I S Y H P I M N<br />
HEALTHCARE COMPLIANCE COMPREHENSIVE<br />
PROFESSIONAL DIAGNOSTIC CODING<br />
ADMINISTRATORS PRACTICE COMPASSIONATE<br />
CULTURE REGULATION HOSPITALS<br />
PHYSICIAN REIMBURSEMENT FRAMEWORK<br />
Contact Toll Free: 888-54-FIRST 15
Upcoming and On-Demand Webinars<br />
Training<br />
MAR 15, 2021<br />
Under Pressure: Reporting Requirements with OCR for<br />
Breaches<br />
Register<br />
ON DEMAND<br />
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change in contact information.<br />
NEW FEATURES!<br />
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Tab<br />
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Zone access for your Account / Client Dashboards<br />
as well as for your Managers and<br />
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