Sample Compliance Monitoring Plan for FY 20??
Corporate | |||||||
---|---|---|---|---|---|---|---|
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
Annual Compliance Education |
Failure to meet Federal Sentencing Guidelines |
Annually |
100% |
All | |||
Hotline Compliance Calls and Compliance Investigations |
Ineffective Compliance Program |
Monthly |
100% |
All | |||
Medical Director Payments |
Stark and Anti-Kickback compliance |
Quarterly |
100%, 25% of medical directors each quarter |
All | |||
Non-Monetary Compensation |
Stark and Anti-Kickback compliance |
Monthly |
100% |
All | |||
Repayments within 60 Days |
CMS 60-day Payment Rule, False Claims Act |
Monthly |
100% |
All | |||
Excluded Providers - Employees, Vendors, Physicians |
Federal Sentencing Guidelines |
Monthly |
100% |
All | |||
Licensure - CNAs, LPNs, RNs, PT, OT, Speech and other |
State law |
Monthly |
100% |
All | |||
PBJ Medical Director Timesheets |
CMS Payroll Based Journal compliance |
Monthly |
100% |
All | |||
Management Certifications |
Ineffective Compliance Program |
Annually |
100% |
All | |||
Conduct gap analysis of Compliance Program with the OIG's "Measuring Compliance Program Effectiveness: A Resource Guide" and the DOJ's "Evaluation of Corporate Compliance Programs" and develop action plan |
Ineffective Compliance Program |
Annually |
NA |
Home Office | |||
Compliance/Privacy Self-Assessment |
Ineffective Compliance Program |
Annually |
100% |
All | |||
Open Payments Database |
Conflicts of Interest |
Annually |
100% contracted physicians |
All | |||
Skilled Nursing Facilities | |||||||
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
Staffing Tags and CMPs |
CMS Regulations |
Monthly |
100% |
All | |||
Staffing Ratios Compliance |
CMS Regulations |
Monthly |
100% |
All | |||
Staffing Hotline Calls and Complaints |
CMS Regulations |
Monthly |
100% |
All | |||
Regulatory - Survey Tags and CMPs |
CMS Regulations |
Monthly |
100% |
All | |||
Regulatory - New Life Safety Requirements |
CMS Regulations |
Monthly |
100% |
All | |||
New Advanced Beneficiary Notices |
CMS Regulations |
Annually |
2 buildings each segment |
Sample | |||
Involuntary Discharges |
CMS Regulations |
Annually |
100% |
All | |||
Home Health | |||||||
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
Home Health PEPPER Data |
CMS Regulations |
Annually |
5 residents |
Random selection from locations that are outliers | |||
Research | |||||||
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
Research - Appropriate approvals of research studies (IRB, individual consent and authorization) |
Human Subjects Protections laws, HIPAA |
Annually |
TBD based on number of open studies |
All | |||
Physician Enterprise | |||||||
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
NP Bell Curves |
Inappropriate coding, billing, False Claims |
Quarterly |
25% of NPs each quarter so 100% are reviewed |
All | |||
NP Resident Volumes |
High volumes combined with coding at high levels could lead to False Claims |
Quarterly |
25% of NPs each quarter so 100% are reviewed |
All | |||
Rehabilitation | |||||||
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
Rehabilitation PEPPER Data |
False Claims |
Monthly |
5 residents |
Random selection from buildings that are outliers | |||
Behavioral Health | |||||||
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
Psychotropic Medication Use and rates of Terrets, Schizophrenia and Huntington's |
CMS Regulations |
Quarterly |
5 residents |
Random selection from buildings that have highest use of psychotropic medications | |||
Telemedicine | |||||||
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
Telehealth Consents |
HIPAA |
Annually |
25 residents |
Random selection from buildings with Telehealth |
Bryant Flynn | ||
Assisted Living Facilities | |||||||
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
Distribution of Notice of Privacy Practices |
HIPAA |
Annually |
25 residents, split equally among locations |
All | |||
Personal Care | |||||||
Description of Monitoring Activity |
Risk |
Frequency |
Sample Size |
Locations |
Assigned To |
Date Completed |
Results |
Distribution of Notice of Prvacy Practices |
HIPAA |
Annually |
25 residents, split equally among locations |
All |