First Healthcare Compliance CONNECT March 2022

CONNECT 

March 2022 

 

A Monthly Publication for the Healthcare Compliance Community 

FAQ Corner: 

How should we handle employees 

who won’t complete training as 

assigned? 

Infographic: 

Compliance Tips for Healthcare 

Board Members 

Hardware Hacking 

in Healthcare: 

Expert Insights 

Healthcare Compliance Policies: 

Best Practices for Management 

and Distribution 

Delaware Law School and First 

Healthcare Compliance Announce 

Presenters for 5th Annual 

Healthcare Compliance 

Symposium 

1st Talk Compliance: 

Healthcare and Technology 

Negotiations

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In This Issue: 

Compliance Super Ninja 

FAQ Corner: How should we handle employees 

who won’t complete training as assigned? 

Infographic: Compliance Tips for Healthcare 

Board Members 

Hardware Hacking in Healthcare: 


2 

First Healthcare Compliance, LLC © 2022

Compliance Super Ninja 

Jennifer Colucciello 

Compliance Officer/Operations Director 

Kidney Care Specialists, LLC 

How would you describe your experience with First Healthcare Compliance? 

The 1stHCC platform has helped make tracking extremely easy, especially since we have 4 very different 

divisions. This platform has allowed for streamlining of compliance items and tracking. Having updates 

made due to new regulations is relatively quick and painless which helps us maintain compliance as new 

requirements are instituted. Definitely helps us stay compliant while doing so efficiently! 

What do you enjoy most about working with Kidney Care Specialists, LLC? 

Nephrology itself has such a huge impact on our patients and their caregivers. The KCS team is highly 

motivated and dedicated to treating our patients in the best way possible with the best care possible! Truly an 

honor to be part of this team! 

Would you rather read an awesome book or watch a good movie? Why? 

Definitely a book! Helps my entire mind escape for a bit to another time and place :) 


Best Practices for Management and 

Distribution 

1st Talk Compliance: Healthcare and 

Technology Negotiations 

Delaware Law School and First Healthcare 

Compliance Announce Presenters for 5th 

Annual Healthcare Compliance Symposium 

Contact Toll Free: 888-54-FIRST 3

FAQ Corner 

How should we handle employees who won’t complete training as assigned? 

Compliance should be a condition of employment. And as part of the Code of Conduct sample we provide, 

employees are required to complete compliance training. Employers may wish to enforce their training 

requirements through discipline. Discipline may include a verbal warning, written warning, suspension, up 

to and including termination. Of course, if your organization has a progressive discipline policy, it must be 

followed when disciplining employees (we provide a sample compliance program disciplinary action policy 

within the Compliance Policies and Procedures Sample). It is also important to be consistent in meting out 

discipline so as not to run afoul of discrimination laws. 

Explore the FAQs tab in your compliance solution 

to find answers to your compliance questions! 

CLIENT 

ALERT 

The Most Comprehensive 

Healthcare Compliance Course 

The Fundamentals is a user-friendly, four-module 

online course designed to help healthcare professionals 

understand the essential principles and practices of 

compliance. 

BUY COURSE NOW 

4 



Hardware Hacking in Healthcare: 


Catherine Short 

John Shegerian, Co-Founder, Chairman and 

CEO of ERI recently shared expert insights in 

the presentation, The Insecurity of Everything: 

Hardware Hacking Trends. 

Data security regulations now exist in all fifty states, 

federally, and internationally. Risks are universal as 

all businesses and individuals including healthcare 

professionals utilize devices that retain data that 

becomes vulnerable to cybercriminals. The healthcare 

industry and hospitals are increasingly at risk for 

ransomware and other types of cyberattacks. Several 

recent examples illustrate the risks and repercussions 

that result from a combination of inadequate resources 

and a lack of clear and effective cybersecurity guidelines. 

The pandemic has amplified many of the cyber risks 

associated with breaches and hardware hacking in 

healthcare. According to Shegerian, “Many of you are 

working from home or working in some sort of hybrid 

situation. We’ve learned that due to COVID, people 

started working for home without all the guardrails that 

are typically set up by CTOs in hospitals and healthcare 

settings. Workers at home unfortunately, started using 

their personal hardware, tablets, cell phones, laptops, 

desktops, for business 

purposes, and their 

business hardware, for 

personal purposes, it 

just happens when we 

have time crunches, 

when something breaks 

down, and we must go 

to a backup plan. That 

means there’s a cross 

contamination when data from one platform gets on to 

another. There’s a cross contamination of your personal 

data onto your professional hardware. And vice versa. 

This means if you work for a healthcare organization, or 

agency, and you believe there’s a chance that you’ve 

had cross contamination, which I’d be shocked if there 

wasn’t please adhere to the protocols provided by your 

Chief Technology Officer. Make sure data and devices are 

responsibly destroyed when it comes to end of life, not 

put on eBay or Craigslist.” 

To learn more, please stay tuned for John’s future 

podcast with host Catherine Short on 1st Talk 

Compliance. 

6 


Navigating Workplace Violence 

Prevention Under OSHA 

Workplace violence is a serious issue, especially in 

healthcare facilities. The Occupational Safety and Health 

Administration (OSHA) responded in 2015 by updating and 

publishing their guidelines on how to best prevent workplace 

violence. The OSHA workplace violence prevention 

guidelines help employees and employers alike by providing 

the necessary steps to maintain a safe work environment. 

DOWNLOAD NOW 

COVID-19 Healthcare 

Compliance Updates 

In response to the global outbreak of the novel coronavirus 

disease (COVID-19), the Secretary of Health and Human 

Services declared a public health emergency on January 31, 

2020. Federal agencies have taken action by issuing updates 

and guidance to navigate the crisis. This ebook provides 

healthcare providers with important developments and 

resources that impact federal healthcare laws. 

DOWNLOAD NOW 



Best Practices for Management 

and Distribution 

First Healthcare Compliance Staff 

Purposes of Policies in Healthcare 

Organizations 

Many healthcare organizations operate under a 

comprehensive set of policies and procedures that 

address a wide range of compliance-related issues, 

including physician relationships, conflicts of interest, 

OSHA and HIPAA Privacy and Security. These 

policies and procedures should be available to every 

employee and provider. 

Specific standards set by an entity as well as the 

elements of an effective compliance program 

provided by OIG/HHS offer frameworks for roles and 

committees to ensure consistency and integration 

of compliance activities and the effectiveness of the 

overall compliance program. 

A well-managed set of policies is critical to the wellbeing 

of any healthcare institution. Proper policies 

support activities by communicating expectations, 

establishing a culture of compliance, protecting 

in litigation matters, and ensuring the welfare of 

patients and staff. 

Important purposes of policies in the healthcare 

setting include: 

1. Provide the framework for the key elements of 

the compliance program 

2. Promote and support ethical behavior among 

staff 

3. Exhibit commitment to compliance and all 

regulations governing the organization 

Management and Distribution of 

Healthcare Compliance Policies 

In addition to creating, communicating, and 

maintaining policies within a healthcare organization, 

it is imperative to take steps to manage and 

distribute the policies effectively. 

1. Assign Responsibility 

An individual should be responsible for managing 

policies within the healthcare organization. 

Depending on the size of the entity, it may be 

either a full or part time position. 

8 


2. Control Access 

For the purposes of efficiency and privacy and 

security, the administrator should have full 

control when it comes to providing access for 

reading and editing policies. 

3. Track Policy Updates 

Tracking policy changes becomes a necessity 

to provide accurate information to compliance 

questions or auditors. 

First Healthcare Compliance offers several solutions 

that provide customizable sample Policies and 

Procedures. In addition, our Document Storage zone 

allows compliance personnel to upload, organize 

and distribute documents via the Training Zone for 

employee attestation. To learn more contact us 

today! 

C. Trey Scott, Coordinating Attorney at 

Kennedy, Attorneys & Counselors 

Compliance 

at Law 

Toolkit 

will present Under Pressure: Reporting 

Appeals for the Fifth Circuit. 

Requirements with OCR for Breaches at the 

upcoming Virtual 

Healthcare 

HIPAA 

compliance 

Privacy and Security 

amidst COVID-19 presents new challenges 

for hospitals and healthcare providers. At top importance is the 

Summit 2021 on November 18. 

Summit! 

question of how to slow or stop the spread of COVID-19, while 

Trey received his Bachelor ensuring of Science and that Master your of organization stays compliant. 

Business degrees from Texas Tech University and his 

Juris Doctorate from Texas Now more Wesleyan than University ever, your School compliance department needs to have the 

of Law (now Texas necessary A&M University tools to School help of track, Law.) analyze, While and respond to compliance challenges. 

in law school, Trey To was help a member navigate of the arbitration process, we’ve gathered our best COVID-19 resources 

competition team as well below. as a student If you bar need association further assistance, please contact us here. 

representative. He also was a law clerk to the 106th 

District Court of the State of Texas. Trey has significant 

experience in healthcare law. This experience includes: 

COVID-19 Healthcare 

VIEW TOOLKIT 

United States District Courts for the Northern, Southern, 

Eastern, and Western Districts of Texas. Trey is also 

licensed to practice before the United States Court of 

Click here for more information or to register for the 

medical malpractice litigation, administrative and 

regulatory appeals and disputes, professional board 

matters, and overpayment disputes. Trey is licensed to 

practice law before Texas State Courts as well as the 


Delaware Law School and 

First Healthcare Compliance 

Announce Presenters for 

5th Annual Healthcare 

Compliance Symposium 

April 28, 2022 


Attorneys and experts from various 

specialties and firms throughout the United 

States will serve as instructors for the 

educational event. 

WILMINGTON, Del. (PRWEB) January 30, 2022 -- 

The 5th annual Healthcare Compliance Symposium 

will be offered virtually. A broad range of timely 

topics will be covered including HIPAA, OSHA, 

Fraud, Waste and Abuse, Ethics, human resources 

compliance, and current challenges related to 

COVID. Attorneys, compliance officers, managers, 

nurses, medical assistants, healthcare professionals, 

business associates, and students are encouraged to 

attend. This convenient online learning event offers 

multiple CEUs and CLE in Delaware, New Jersey, and 

Pennsylvania. 

Attorneys and experts listed below from various 

specialties and firms throughout the United States 

will serve as instructors for the educational event: 

• Stephen D. Bittinger, Esq. 

• Emily Johnson, Esq. 

• Kathleen W. McNicholas, MD, JD, CHC, CCEP 

• Elizabeth Sullivan, Esq. 

• Rachel V. Rose, JD, MBA 

• Lauren Moak Russell, Esq. 

• Catherine Walters, Esq. 

The symposium is a joint effort to provide resources 

for professionals facing the challenges of the everchanging 

healthcare industry. The event will be held 

on April 28, 2022, with online access for virtual 

attendance. Discounts apply for Delaware Law School 

Alumni and clients of First Healthcare Compliance. 

Learn more and register now. 

About Delaware Law School: Widener University 

is a metropolitan university that connects curricula 

to social issues through civic engagement. Dynamic 

teaching, active scholarship, personal attention, 

applied leadership, and experiential learning are key 

components of the Widener experience. Delaware 

Law School is the First State’s only law school, 

providing a Juris doctor, legal graduate and paralegal 

10 


degree programs with an emphasis on developing 

legal professionals who reflect the Delaware Way and 

its traditions of civility, integrity and mutual respect. 

The school offers signature programs in corporate 

and business law, environmental law, family health 

law and policy, trial advocacy, and dignity rights. 

About First Healthcare Compliance: Founded 

in 2012 by a nurse attorney, the First Healthcare 

Compliance software solution creates confidence 

among compliance professionals through education, 

resources, and support in the areas of HIPAA, OSHA, 

human resources compliance, and fraud waste and 

abuse laws. Serving clients across the United States, 

the company’s evolving platform provides real-time 

insight for board reporting 

For more information please visit 

https://1sthcc.com/ 

Contact Information 


First Healthcare Compliance 

http://1sthcc.com 

302-416-4329 

Healthcare 

Compliance 

Symposium 

April 28, 2022 

REGISTER NOW 


Risk Management Considerations for 

the Healthcare Compliance Officer: 

Training, Incident Management, Governing Boards, 

and Measures Unique to COVID-19 

It’s no secret that healthcare is one of America’s most heavily regulated 

industries with substantial fines and penalties for non-compliance. Complex 

regulations and mandates make compliance management a necessity. 

Healthcare organizations particularly rely on the skills and attributes of their 

compliance officer to navigate the expansive regulatory framework. 

DOWNLOAD NOW 

12 


Referral Appreciation Program 

Receive a $50 gift card* when you refer a client! 

First Healthcare Compliance is delighted to offer a Referral Appreciation 

Program to say thank you for helping us to continue to grow. For each new 1st 

Professional or 1st Premium client originating from a referral, First Healthcare 

Compliance will provide a $50 gift card as a token of appreciation. 

LEARN MORE 


hosted by Catherine Short 

Catherine Short converses with Rachel V. Rose, JD, MBA, principal with Rachel V. Rose – Attorney at Law, 

P.L.L.C., Houston, TX and Bruce J. Lynskey, Co-Founder at ePrevenir, on the topic of “Negotiations in 

Healthcare and Technology.” Negotiating occurs in every facet of business and law. From contractual 

negotiations through settlement negotiations, it is a delicate dance. There are a variety of classic negotiation 

techniques, which include extreme posturing and “anchoring”. Healthcare and cybersecurity present unique 

challenges because of the looming exposure to a government investigation and either a civil and/or criminal 

action, even if a settlement is reached between two private parties. Here we will discuss approaches when 

negotiating contracts, settlements, and other items, which arise in healthcare and the cybersecurity industries. 

Listen weekdays at 

7:30am, 3:30pm, 11:30pm ET 

Check out our Show Page! 

Looking for the latest compliance insights? 

Subscribe to our feed and don’t miss a thing! 

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WORD SEARCH 

H J D O Q K Q N O I T A I C E R P P A Q 

L R C Z I M A F X Q Y X M E A P D O I H 

Y H W L W C R S T H G I S N I G Q F V M 

R E E N O I T A N I M I R C S I D C M L 

E A D W R M T T R A C K I N G M N Z T X 

H L J J P A N Q G T F Z Q U D N Y H I E 

N T P U A N E Z G R H S O K D X A D M F 

I H Q V K Y D A E M P L O Y M E N T V K 

I C R Q J D I J H H B J A Z Q M O P C K 

K A P X P V C M A N A G E M E N T B U Z 

P R E S P O N S I B I L I T Y R Y L T Y 

O E I G N T I U S W C R I T I C A L H P 

L L W J O T S V T S Y O M B Z R M N S U 

I K G J D C H A L L E N G E S U V E O W 

C C C O M P L I A N C E M U J I B H D N 

I H S W J L A V H Q U L E O C Y F G E X 

E M L X K T Z U R P I C C C I X J D L R 

S A C S L I G J B W W L S J N Z F B S Z 

D P T N P N S L A N O I S S E F O R P M 

X V T T D P D Q F D G K L V G E G G H T 

HEALTHCARE COMPLIANCE TRACKING 

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INCIDENT APPRECIATION CHALLENGES 

PROFESSIONALS DYNAMIC POLICIES 

CRITICAL RESPONSIBILITY INSIGHTS 


Upcoming and On-Demand Webinars 

Training 

APR 7, 2022 

DMEPOS - CMS Compliance and Requirements Updates 

Register 

APR 28, 2022 Virtual Healthcare Compliance Symposium 2022 

Register 

ON DEMAND Employment and Labor Law Round-up With 2022 

Forecast and Other HOT Topics 

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contact Client Services if you require additional 

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Initial Data - Free text comment field has been 

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888.54.FIRST or clientservices@1sthcc.com 

16

First Healthcare Compliance CONNECT March 2022

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