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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


Got a Minute? Please Rate Us!<br />

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of our community spreading the word about us.<br />

Share Your Success Story<br />

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we could receive! Please take a moment of your time<br />

to rate us online so that others can benefit from your<br />

experience. It’s a simple way to help us grow and<br />

improve.<br />

We appreciate your support and look forward to<br />

hearing from you!<br />

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 />

4<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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<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>


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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<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>


#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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<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>


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 />

12<br />

<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>


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 />

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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 />

Hardware Hacking Trends - The Insecurity of Everything<br />

All Upcoming Webinars<br />

All On Demand Webinars<br />

IMPORTANT<br />

In the interest of your security, login credentials are<br />

for individual use only and not to be shared. Please<br />

contact Client Services if you require additional<br />

manager level users and/or if there has been a<br />

change in contact information.<br />

NEW FEATURES!<br />

HIPAA Zone - New Documents and Updated<br />

Policies are available in the HIPAA Zone Resources<br />

Tab<br />

Great News! You can now customize and Manage<br />

Zone access for your Account / Client Dashboards<br />

as well as for your Managers and<br />

Supervisors. Contact Client Services<br />

for details.<br />

Employee Zone/<strong>Compliance</strong> Detail<br />

Initial Data - Free text comment field<br />

has been added.<br />

COVID Vaccination Status/ COVID Testing -<br />

Additional fields have been added to assist you<br />

with tracking COVID vaccination and COVID Testing.<br />

Contact Client Services if you have any questions or<br />

would like to turn COVID alerting off.<br />

CLIENT<br />

ALERT<br />

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Contact our Client Services Team with your questions!<br />

888.54.FIRST or clientservices@1sthcc.com<br />

16<br />

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