First Healthcare Compliance CONNECT May 2022
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<strong>CONNECT</strong><br />
<strong>May</strong> <strong>2022</strong><br />
<br />
A Monthly Publication for the <strong>Healthcare</strong> <strong>Compliance</strong> Community<br />
CIAs, Exclusions,<br />
and Your Practice<br />
What to know about<br />
Operating Clinical<br />
Laboratories<br />
– Nuts and Bolts<br />
Revenue Cycle and<br />
<strong>Compliance</strong> Summit<br />
Let’s Talk About Sex, Baby:<br />
Common Mistakes and Pitfalls<br />
When Addressing Sex and<br />
Pregnancy Discrimination in the<br />
Workplace<br />
Julie Sheppard on the<br />
Importance and Value of<br />
HCCA Membership<br />
1st Talk <strong>Compliance</strong>:<br />
Medical Error & Patient<br />
Advocacy – How Can We Have<br />
More Candor?
Got a Minute? Please Rate Us!<br />
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In This Issue:<br />
CIAs, Exclusions, and Your Practice<br />
What to know about Operating Clinical<br />
Laboratories – Nuts and Bolts<br />
Revenue Cycle and <strong>Compliance</strong> Summit <strong>2022</strong><br />
Let’s Talk About Sex, Baby: Common Mistakes<br />
and Pitfalls When Addressing Sex and<br />
Pregnancy Discrimination in the Workplace<br />
2<br />
<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>
<strong>Compliance</strong> Super Ninja <br />
Kristy Phillips, Office Administrator<br />
James E. Fox M.D. PLLC<br />
How would you describe your experience with <strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>?<br />
My experience has been great! The use of this compliance program has made compliance something that<br />
is much more manageable. The ability to continually track compliance, licensure, and other necessary<br />
components is one less thing off my plate as a practice administrator.<br />
What do you enjoy most about working with James E. Fox M.D. PLLC?<br />
I enjoy the daily challenges. No day is the same at our practice. The constant challenge and change help me<br />
grow and evolve as a manager.<br />
Would you rather never sit in traffic again or never wait in line again? Why?<br />
I would prefer never to wait in line again. At least in the car, I can listen to music and have my quiet time.<br />
Julie Sheppard on the Importance and Value of<br />
HCCA Membership<br />
1st Talk <strong>Compliance</strong>: Medical Error & Patient<br />
Advocacy – How Can We Have More Candor?<br />
Contact Toll Free: 888-54-FIRST 3
FAQ Corner<br />
Does the HIPAA Privacy Rule prohibit businesses or individuals from asking whether<br />
their customers or clients have received a COVID-19 vaccine?<br />
No. The Privacy Rule does not prohibit any person (e.g., an individual or an entity such as a business),<br />
including HIPAA covered entities and business associates, from asking whether an individual has received<br />
a particular vaccine, including COVID-19 vaccines.<br />
<strong>First</strong>, the Privacy Rule applies only to covered entities (health plans, health care clearinghouses, and<br />
health care providers that conduct standard electronic transactions) and, to some extent, their business<br />
associates.<br />
Second, the Privacy Rule does not regulate the ability of covered entities and business associates to<br />
request information from patients or visitors. Rather, the Privacy Rule regulates how and when covered<br />
entities and business associates are permitted to use and disclose protected health information (PHI)<br />
(e.g., PHI about whether an individual has received a COVID-19 vaccine) that covered entities and business<br />
associates create, receive, maintain, or transmit. Thus, the Privacy Rule does not prohibit a covered entity<br />
(e.g., a covered doctor, hospital, or health plan) or business associate from asking whether an individual<br />
(e.g., a patient or visitor) has received a particular vaccine, including COVID-19 vaccines, although it does<br />
regulate how and when a covered entity or its business associate may use or disclose information about<br />
an individual’s vaccination status.<br />
Additional examples. The Privacy Rule does not apply when an individual:<br />
• Is asked about their vaccination status by a school, employer, store, restaurant, entertainment venue,<br />
or another individual.<br />
• Asks another individual, their doctor, or a service provider whether they are vaccinated.<br />
• Asks a company, such as a home health agency, whether its workforce members are vaccinated.<br />
• Other state or federal laws address whether individuals are required to disclose whether they have<br />
received a vaccine under certain circumstances.<br />
Please see https://www.hhs.gov/hipaa/for-professionals/privacy/guidance/hipaa-covid-19-vaccinationworkplace/index.html<br />
Explore the FAQs tab in your compliance solution<br />
to find answers to your compliance questions!<br />
CLIENT<br />
ALERT<br />
4<br />
<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>
Contact Toll Free: 888-54-FIRST 5
CIAs, Exclusions, and Your Practice<br />
Rachel V. Rose, JD, MBA<br />
Contracting with or employing an excluded<br />
person can result in a government enforcement<br />
action.<br />
Before delving into a recent U.S. Department of Justice<br />
(DOJ) settlement, which involved employing an “excluded”<br />
individual, it’s important to appreciate some of the tools<br />
that the U.S. Department of Health and Human Services<br />
Office of the Inspector General (HHS-OIG) has at its<br />
disposal – corporate integrity agreements (CIA) and<br />
exclusion from all federal programs.<br />
CIAs – are negotiated by HHS-OIG “with healthcare<br />
providers and other entities as part of the settlement<br />
of Federal health care program investigations arising<br />
under a variety of civil false claims statutes. Providers<br />
or entities agree to the obligations, and in exchange, OIG<br />
agrees not to seek their exclusion from participation<br />
in Medicare, Medicaid, or other Federal health care<br />
programs.” Typically, a CIA lasts 5 years and the person<br />
who enters into the CIA must make scheduled reports to<br />
HHS-OIG. Importantly, CIAs are specific to the facts and<br />
circumstances of a particular matter and include breach<br />
and default provisions, which enable HHS-OIG to impose<br />
additional monetary penalties (i.e., Stipulated Penalties).<br />
A material breach of the CIA “constitutes an independent<br />
basis for the provider’s exclusion from participating in<br />
Federal healthcare programs.”<br />
Exclusions – have been around since 1977 and are<br />
imposed by HHS-OIG; however, they may arise because<br />
of a False Claims Act case or other matter that was<br />
initiated through or by DOJ. HHS-OIG’s authority to<br />
impose exclusions is derived from the Social Security<br />
Act §§ 1128, 1156.“The scope of an exclusion under<br />
section 1128 of the Act is from all Federal health care<br />
programs, as defined in 42 CFR 1001.2. … Exclusions<br />
under section 1156 of the Act do not reach other Federal<br />
programs (although HHS or another Federal agency<br />
could separately initiate a suspension or debarment of<br />
an excluded person from other Federal procurement<br />
or nonprocurement programs).” The process begins<br />
when a person receives a Notices of Intent to Exclude<br />
(NOI). From there, the recipient of the NOI is given the<br />
opportunity to respond. Once all the information is<br />
considered, HHS-OIG renders its decision. If the findings<br />
substantiate exclusion, the person is notified. From<br />
there, they may appeal to an HHS Administrative Law<br />
Judge and further appeal to the HHS Departmental<br />
Appeals Board (DAB). After the DAB renders its decision,<br />
judicial review in a U.S. District Court is also available.<br />
Reinstatement of an individual or entity is not automatic;<br />
rather, the person must apply for reinstatement. If<br />
reinstated, the person receives written notice from<br />
HHS-OIG that they have been reinstated. The excluded<br />
individual may begin the process 90 days before their<br />
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period of exclusion ends.<br />
On March 18, <strong>2022</strong>, the DOJ announced that Windham<br />
Eye Care Practice and its Owners Pay $192K for<br />
Employing “Excluded” Individual. Specifically, the federal<br />
and state governments entered into a civil settlement<br />
agreement “to resolve allegations that they improperly<br />
employed an individual who was excluded from all<br />
federal healthcare programs.” Windham Eye Group (WEG)<br />
employed Michael Vallone as its practice administrator<br />
from February 2010 through <strong>May</strong><br />
2021. Previously, Mr. Vallone was<br />
convicted of healthcare fraud in<br />
the District of New Jersey and<br />
was excluded from all federal<br />
healthcare programs under<br />
§1128 of the Social Security Act.<br />
As noted by the DOJ, when<br />
HHS-OIG “excludes an individual<br />
or entity from federal health<br />
care programs, no program<br />
payments may be made for<br />
items or services furnished by<br />
that excluded individual or entity.”<br />
(emphasis added). The relevance<br />
to the WEG was that a portion of the reimbursements<br />
received from the federal healthcare programs were<br />
used to pay Mr. Vallone’s salary and benefits.<br />
I have often reiterated the phrase, “an ounce of<br />
prevention is worth a pound of cure.” HHS-OIG issued<br />
an Updated Special Advisory Bulletin in <strong>May</strong> 2013,<br />
emphasizing that in order to avoid potential liability,<br />
health care providers and organizations providing<br />
services directly or indirectly should check the List of<br />
Excluded Individuals/Entities on the HHS-OIG website.<br />
It is imperative that entities receiving remuneration<br />
from Federal health care programs – whether directly<br />
or indirectly, have both background checks and<br />
exclusion checks as part of their policies and<br />
procedures.<br />
About the Author<br />
Rachel V. Rose, JD, MBA, advises clients<br />
on compliance, transactions, government<br />
administrative actions, and litigation involving<br />
healthcare, cybersecurity, corporate and<br />
securities law, as well as False Claims Act<br />
and Dodd-Frank whistleblower cases. She<br />
also teaches bioethics at Baylor College of<br />
Medicine in Houston. Rachel can be reached<br />
through her website, www.rvrose.com.<br />
Originally posted on: physicianspractice.com<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.<br />
DOWNLOAD NOW<br />
Contact Toll Free: 888-54-FIRST 7
What to know about Operating Clinical<br />
Laboratories – Nuts and Bolts<br />
Catherine Short<br />
Elizabeth Sullivan and Emily Johnson are<br />
both Members of McDonald Hopkins, a<br />
business law and advocacy law firm, and<br />
led the presentation What to Know About<br />
Operating Clinical Laboratories – Nuts<br />
and Bolts at the <strong>Healthcare</strong> <strong>Compliance</strong><br />
Symposium <strong>2022</strong> on April 28, <strong>2022</strong>.<br />
Liz, based in the<br />
Cleveland office, is<br />
Chair of McDonald<br />
Hopkins’ national<br />
<strong>Healthcare</strong> Practice<br />
Group and a member<br />
of the firm’s Board of<br />
Directors. She began<br />
her legal career in the<br />
<strong>Healthcare</strong> Practice<br />
group at McDonald Hopkins and later served as an<br />
attorney in the legal department at The Cleveland<br />
Clinic Foundation before returning to McDonald<br />
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 />
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 />
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<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>
elevant contractual and legal documentation<br />
in connection with contemplated business<br />
arrangements.<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 />
Emily Johnson, based in the Chicago office, focuses<br />
her practice on matters primarily for clients in the<br />
healthcare industry.<br />
She provides<br />
regulatory and<br />
compliance assistance<br />
on both a federal<br />
and state level. She<br />
has assisted clinical<br />
laboratories, hospitals,<br />
long-term acute<br />
care hospitals, community hospitals, physician<br />
specialty groups, telehealth providers, surgery<br />
centers, healthcare associations, pharmacies, and<br />
other healthcare providers on regulatory, licensing,<br />
compliance, reimbursement, contractual, and<br />
corporate matters. She has provided support to<br />
entities during licensure and accreditation surveys<br />
and assisted in navigating state professional<br />
licensure laws, CLIA standards and state and federal<br />
laboratory laws and regulations, government and<br />
private payor reimbursement, state and federal fraud<br />
and abuse rules, state telehealth laws, and state and<br />
federal pharmacy regulation. She also has advised<br />
clients on direct to consumer testing issues and<br />
applicable state requirements.<br />
She also has experience with provider-based<br />
compliance issues and the 340B Federal Drug<br />
Pricing Program, including implementation, program<br />
compliance, audit preparation, and preparing for<br />
audits conducted by the Office of Pharmacy Affairs.<br />
In addition, she has significant experience with<br />
HIPAA compliance, including drafting HIPAA policies<br />
and procedures, breach response and notification,<br />
drafting responses to investigations conducted by<br />
the Office for Civil Rights, and advising clients on<br />
proactive HIPAA compliance and breach prevention.<br />
Prior to joining McDonald Hopkins, Emily served as<br />
healthcare attorney/senior consultant at a national<br />
legal-based healthcare management consulting firm<br />
and outside counsel to the National Association of<br />
Navigating Workplace Violence<br />
Prevention Under OSHA<br />
Workplace violence is a serious issue, especially in healthcare<br />
facilities. The Occupational Safety and Health Administration<br />
(OSHA) responded in 2015 by updating and publishing their<br />
guidelines on how to best prevent workplace violence.<br />
DOWNLOAD NOW<br />
Contact Toll Free: 888-54-FIRST 9
Revenue Cycle and <strong>Compliance</strong> Summit <strong>2022</strong><br />
Catherine Short<br />
Revenue Cycle Coding Strategies<br />
and <strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong><br />
Offer Revenue Cycle and <strong>Compliance</strong><br />
Summit with Expert Speakers on June<br />
23, <strong>2022</strong><br />
Revenue Cycle Coding Strategies (RCCS) and <strong>First</strong><br />
<strong>Healthcare</strong> <strong>Compliance</strong> to provide resources for<br />
professionals facing the challenges of auditing,<br />
billing, and coding compliance. The virtual half-day<br />
online educational event will be held on June 23,<br />
<strong>2022</strong>, from 12:00p.m. EST until 4:30 p.m. EST and<br />
registration is open to the public.<br />
“During this time of continuous change, quality<br />
education about compliance related to the revenue<br />
cycle is imperative”, states Julie Sheppard, Founder<br />
and President of <strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>.<br />
Sheppard continues, “we rely on RCCS as a trusted<br />
resource for our clients.” Melody W. Mulaik, President<br />
of RCCS is a nationally recognized expert and the<br />
<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong> 2021 presenter of the<br />
year.<br />
Four learning modules will be offered with<br />
opportunities for learning credits. Attendees are<br />
eligible to receive 4 CLE in Pennsylvania. This<br />
program has been approved for 4 continuing<br />
education unit(s) by PAHCOM and Practice<br />
Management Institute®.<br />
The agenda for the educational workshop<br />
in EST:<br />
12:00 p.m.-12:15 p.m. Virtual Waiting Room and<br />
Welcome<br />
12:15 p.m. – 1:15 p.m. Michael Denbow, Esq.<br />
Responding to and Defending Government<br />
Investigations: What to do When the Government<br />
“Knocks” On Your Door<br />
1:15 p.m. -1:20 p.m. Break<br />
1:20 p.m.- 2:20 p.m. Melody W. Mulaik 1,2,3’s of<br />
Auditing: How to Ensure Ongoing Proactive Coding<br />
& Documentation Audits for Reimbursement and<br />
<strong>Compliance</strong><br />
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<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>
2:20 p.m. -2:25 p.m. Break<br />
2:25 p.m. -3:25 p.m. Sara Spurlock, Esq. Under<br />
Attack: Ransomware Threats, Prevention Tips, and<br />
Response Strategy for Health Care Providers<br />
3:25 p.m. -3:30 p.m. Break<br />
3:30 p.m.-4:30 p.m. Melody W. Mulaik The “Other”<br />
<strong>Compliance</strong> Challenges: Credentialing, Credit Balance,<br />
Appropriate Use Criteria (AUC) and More!<br />
About Revenue Cycle Coding Strategies: Revenue<br />
Cycle Coding Strategies is a trusted partner of<br />
private practices, healthcare systems, hospitals,<br />
and other industry stakeholders, providing solutions<br />
for challenges in all aspects of the charge capture<br />
process. For more information, please visit https://<br />
rccsinc.com/<br />
Register now for this virtual event.<br />
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 />
Contact Toll Free: 888-54-FIRST 11
Let’s Talk About Sex,<br />
Baby: Common Mistakes<br />
and Pitfalls When<br />
Addressing Sex and<br />
Pregnancy Discrimination<br />
in the Workplace<br />
Catherine Short<br />
Lauren Moak Russell, Counsel at<br />
Young Conaway Stargatt & Taylor, LLP<br />
will led the presentation Let’s Talk<br />
About Sex, Baby: Common Mistakes<br />
and Pitfalls When Addressing Sex<br />
and Pregnancy Discrimination in<br />
the Workplace at the <strong>Healthcare</strong><br />
<strong>Compliance</strong> Symposium <strong>2022</strong> on April<br />
28, <strong>2022</strong>.<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 />
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<br />
and conducts<br />
specialized in-house<br />
training for emerging<br />
legal issues including<br />
the pregnancy,<br />
reproductive<br />
rights, and family<br />
care provisions of the Delaware Discrimination in<br />
Employment Act. One of her current programs<br />
outlines the complexities of the #MeToo movement<br />
and offers executives essential information on<br />
harassment avoidance and modifying corporate<br />
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 />
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<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>
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 />
C. Trey Scott, <strong>Healthcare</strong> Coordinating compliance Attorney at amidst COVID-19 presents new challenges<br />
Kennedy, Attorneys for hospitals & Counselors and healthcare at Law providers. At top importance is the<br />
will present Under question Pressure: of how Reporting to slow or stop the spread of COVID-19, while<br />
Appeals for the Fifth Circuit.<br />
Requirements with OCR ensuring for Breaches that your at the organization stays compliant.<br />
upcoming Virtual HIPAA Privacy and Security<br />
Summit 2021 on Now November more than 18. ever, your compliance Summit! department needs to have the<br />
necessary tools to help track, analyze, and respond to compliance challenges.<br />
Trey received his To Bachelor help navigate of Science the and process, Master of we’ve gathered our best COVID-19 resources<br />
Business degrees from Texas below. Tech If University you need and further his assistance, please contact us here.<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 a member of the arbitration<br />
competition team as well as a student bar association<br />
representative. He also was a law clerk to the 106th<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 />
matters, and overpayment disputes. Trey is licensed to<br />
practice law before Texas State Courts as well as the<br />
COVID-19 <strong>Healthcare</strong><br />
<strong>Compliance</strong> Toolkit<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 />
Contact Toll Free: 888-54-FIRST 13
Julie Sheppard on the Importance and<br />
Value of HCCA Membership [Podcast]<br />
Adam Turteltaub<br />
If you have ever considered joining the<br />
Health Care <strong>Compliance</strong> Association<br />
(HCCA) but haven’t, this podcast will<br />
give you cause to reconsider.<br />
Julie Sheppard, Founder and President of <strong>First</strong><br />
<strong>Healthcare</strong> <strong>Compliance</strong> joined the association a<br />
decade ago when she was looking for a reliable<br />
source of information on healthcare compliance<br />
issues. She wanted an unbiased, trusted source<br />
of information that would keep her updated on the<br />
challenges of managing compliance.<br />
range of HCCA programs, from an Academy to web<br />
conferences to reading the magazine <strong>Compliance</strong><br />
Today.<br />
She also obtained her Certified in <strong>Healthcare</strong><br />
<strong>Compliance</strong> (CHC) designation, which she sees as a<br />
means to differentiate herself and demonstrate her<br />
expertise.<br />
Listen in to learn more about her journey with HCCA<br />
and how she sees healthcare compliance evolving<br />
over the next few years.<br />
Through the years she has taken advantage of a wide<br />
Listen Now<br />
14<br />
<strong>First</strong> <strong>Healthcare</strong> <strong>Compliance</strong>, LLC © <strong>2022</strong>
Revenue Cycle and<br />
<strong>Compliance</strong> Summit<br />
June 23, <strong>2022</strong><br />
REGISTER NOW<br />
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<br />
most heavily regulated industries with<br />
substantial fines and penalties for noncompliance.<br />
Complex regulations and mandates<br />
make compliance management a necessity.<br />
<strong>Healthcare</strong> organizations particularly rely on the<br />
skills and attributes of their compliance officer<br />
to navigate the expansive regulatory framework.<br />
DOWNLOAD NOW<br />
Contact Toll Free: 888-54-FIRST 15
hosted by Catherine Short<br />
1st Talk <strong>Compliance</strong> features guest Kathleen W. McNicholas, MD, JD, CHC, CCEP, Consultant and Patient<br />
Advocate with Medical Legal Patient Advocacy Inc., on the topic of “Medical Error & Patient Advocacy –<br />
How Can We Have More Candor?” Kathleen joins our host, Catherine Short to review medical error and<br />
provide an approach to harmed patients. The CANDOR program of Communication and Optimal Resolution<br />
will be explained. CANDOR is well established and has been successfully adopted by many medical centers.<br />
Without CANDOR in place, patients may benefit from the use of the principles and the help of a board-certified<br />
patient advocate.<br />
Listen weekdays at<br />
7:30am, 3:30pm, 11:30pm ET<br />
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