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Basic Compliance Policies and Procedures

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Basic Compliance Policies

Basic Compliance Policies

(January 5, 2016): Now that you have appointed an individual to be responsible for the compliance program and created a compliance committee to help the compliance officer, the focus should turn to basic compliance policies and procedures. If an effective compliance program is like a house with a solid roof to protect the inhabitants from bad weather, policies and procedures function as the studs and support structure. Like walls, policies and procedures establish the outlines of a program, delineating areas of focus. Another way of looking at this is that the basic policies and procedures serve as the constitution of your compliance program. Accordingly, every compliance program should have certain policies at a minimum. The most important ones are (in no particular order):

  1. Code of Conduct. This is the basic commitment to comply with federal, state and local applicable rules and regulations applicable to healthcare and your practice. The importance of this policy cannot be overstated. To put it very simply, this policy must say you will not lie, cheat or steal.

  2. Appointment of a compliance officer and description of duties and powers. If the compliance officer is like the president, then this policy describes what executive powers that individual has.

  3. Ineligible persons and sanctions screening. This policy state that you will not employ, contract with, accept referrals or prescriptions from, or make referrals to individuals or entities that are sanctioned, excluded or debarred from federal and state health care programs.

  4. Licensure status. Like the ineligible persons policy, this policy should address which individuals must maintain licensure and state that the practice will not employ, contract with, accept referrals or prescriptions from, or make referrals to individuals and entities that are not properly licensed. The policy should also indicate how you will verify licensure status and what actions will be taken if you cannot validate proper licensure status.

  5. Hotlines and reporting methods for employees, patients and others. This policy should clearly establish how individuals can report concerns and ask questions or request guidance. A key component must be a statement that the reporter may remain anonymous and will not face retaliation for good faith reports.

  6. Document internal corrective actions taken. This policy should outline the general steps that will be taken to investigate a report of possible problems. The policy should include direction for how to document the results of the investigation and what, if any, corrective actions were required and implemented.

  7. Training.  We all know how much the rules and regulations in health care are changing. This policy should indicate how you will be training staff, general topics, frequency of training, and how you will document completion of the training. This policy should also include the repercussions for failure to complete the training as required.

  8. Internal auditing and monitoring. This policy should outline your process for conducting audits. If you are billing any insurer, whether federal OR private, you should be conducting audits routinely. Identify what the risk areas are for your practice. The risk areas could be related to particular services, CPT codes, or a particular insurer. As with the Investigations policy, this policy should also detail what actions you will take in response to results that reveal a possible issue.

  9. Conflicts of interest. It is not possible to eliminate potential conflicts of interest unless you live on a desert island, isolated from contact with the rest of the world. Accordingly, the first step is identify possible conflicts of interest (for example, family or business relationships, outside employment, ownership interests, etc.). The policy should require that all potential conflicts of interest be disclosed. Once disclosed, the policy should provide a method for addressing the potential conflict of interest. Some conflicts of interest are so significant or impact the practice in such a way that the underlying situation must be unwound. For example, a contract might have to be terminated or a relationship ended. Other conflicts of interest can be managed. Again, the policy should provide for documentation of the disclosure and what actions are taken to end or manage the conflict of interest.

  10. Waivers of copayments and deductibles, discounts, charity care, and beneficiary inducement. One of the fastest ways to get in trouble is to inconsistently apply and collect copayments and deductibles or offer discounts, as insurers will take the position that this is an improper beneficiary inducement of the federal and state anti-kickback laws. There are ways to provide free or discounted care, but it must be done thoughtfully and following established procedures. In addition, this is a key area to develop documentation demonstrating adherence to the requirements.

  11. Returning overpayments. Since audits are likely to result in overpayments, you must commit to promptly returning any identified overpayments. A good place to start are the Medicare policy manuals, particularly those of the Medicare Administrative Contractor (MAC). Likewise, private insurers often have policies on refunding overpayments. Don’t forget that the Affordable Care Act requires that Medicare and Medicaid overpayments be returned within 60 days from the identification of the overpayment.

  12. HIPAA requirements must be met. Actually, the HIPAA policies are more an entire set of policies that address compliance with the Privacy Rule, the Security Rule, and the Breach Notification Rule. I will address HIPPA policies in more detail in a future article.

  13. Document retention. This policy should outline what your document retention and destruction policy and procedures are. Not every document needs to be kept forever, and you should create retention time periods for different kinds of documents (including patient medical records). Don’t forget to include electronically maintained documents. One provision the policy absolutely must contain is a requirement that if the practice is under audit, investigation or any other form of scrutiny, that no documents relating to that matter be destroyed, including deletion of emails.

This baker’s dozen of basic compliance policies is only a starting point. A practice’s book of policies should include additional policies that address its particular needs or risks. In fact, I would be extremely worried if I walked into a practice and did not find at least half a dozen more policies specific to the practice. Also, the policies book need not be limited to compliance policies. The practice should also have HR policies, finance policies, patient care policies and OSHA policies

All policies should be reviewed on an annual basis and updated as necessary. This includes eliminating policies that are no longer appropriate or relevant and writing new ones. All policies should be written in a template that permits you to document when a policy was last reviewed and when it was last changed.

And finally, policies should not be like the recipe for Coca Cola, kept in a vault and only known to a few. All staff members should have access to and understand the policies, so a best practice is to place the policies in a binder in a common area, easily accessible by all staff members. If you have an intranet, post them on the intranet. Post them on a bulletin board in the staff break room. Make them widely available. Train on them, repeatedly. Never be in a situation where a staff member can say, “Oh, I didn’t know that was our policy!”

Next month we’ll examine exclusions and why they are so important in more depth.

H-Kocher-photo-2-199x300Heidi Kocher, Esq. is a health law attorney with the firm, Liles Parker, Attorneys & Counselors at Law.  Liles Parker has offices in Washington DC, Houston TX, McAllen TX and Baton Rouge LA.  Our attorneys represent dentists, orthodontists and other health care professionals around the country in connection with government audits of Medicaid and Medicare claims, licensure matters and transactional projects.  Need assistance?  For a free consultation, please call: 1 (800) 475-1906.

How to Implement a Compliance Plan in Your Practice

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Confused-Doctor(September 17, 2015): Despite the fact that Medicare and Medicaid requires that participating providers implement a compliance plan, most small providers have yet to complete the necessary steps to accomplish this requirement.  “My office manager went to a continuing education program, and she’s come back telling me we need a compliance program. I don’t know about that. I know I need to be in compliance with all those rules and regulations, but it seems to be complex and confusing. Do I really need one? How do I put a program into place without spending enormous sums? We’re a small practice and we don’t have a lot of extra time and money to spend on compliance activities.”

This is how my clients often approach me with questions about compliance programs. Or, they have been the recipient of an audit letter from either Medicare or a private insurer. Let’s face it, the requirements for compliance programs are here to stay. Not only are compliance programs now required by the federal government for any provider who receives Medicare or Medicaid reimbursement (see section 6401 of the Affordable Care Act), they are also required by many private insurance companies. Within the last year, I have seen increasing numbers of network provider contracts from private insurance companies include a requirement that the provider have a compliance program. So, having a functional compliance program is no longer an option but a requirement.

To that end, over the next year, we will be exploring the basic elements of an effective compliance program, as well as topics related to a solid compliance program. Let’s start with what a compliance program is and is not. A compliance program is not a document that is placed in a binder on a high shelf in your office, to be dusted off only annually or when faced with scrutiny by insurance companies or, God forbid, state or federal regulators. Instead, a compliance program should become part of the fabric of doing business in your practice. When implemented correctly, a compliance program can help identify potential trouble spots in your practice and give you a framework for addressing those trouble spots. Of course, a functioning and effective compliance program can also help minimize fines and, if things go south, could keep a civil matter from turning into a criminal matter.

A compliance program is also not a mumu – one size does NOT fit all. Just as there are differences between patients, there are differences between practices, the risks they face and the best methods of addressing those risks. An effective compliance program recognizes that while the structure of most compliance programs is similar, it takes into account the practice’s size and sophistication, the medical specialty, and the patient population. For this reason, compliance programs in a box or purchased off the Internet really are not desirable and often cost a practice more money in customization and sometimes tears down the road. A perfect example is the recent settlement by Anchorage Community Mental Health Services in relation to a HIPAA breach, where the government noted the ineffectiveness of the “sample” compliance policies and documents the provider put forward as its compliance program.

The basic elements of an effective compliance program are not complicated. They are:

  1. Designating an individual to serve as compliance officer and creating a compliance committee, particularly for larger organizations.
  2. Implementing a standard of conduct and policies and procedures relevant to the practice’s operations.
  3. Conducting effective training and education.
  4. Instituting effective methods of communication
  5. Conducting internal monitoring and auditing
  6. Enforcing the policies and standards through well-publicized disciplinary guidelines
  7. Responding promptly to violations and taking appropriate corrective action.

Each month we will explore each of these topics, discussing how to implement a compliance plan, and how to do so in a cost-effective fashion. Along the way, we will also discuss various forms of guidance available to practices when you implement a compliance plan that is tailored for the specific needs and risks of your individual practice. Let’s start with one right away – the federal government itself. The Office of Inspector General of the U.S. Department of Health and Human Services (“OIG”) has published a number of “Compliance Program Guidances”, intended to help different provider types understand and implement compliance practices specific to and appropriate for their particular branch. One of the guidances is specifically written for individual and small group physician practices and published in October 2000. It’s available here: http://oig.hhs.gov/authorities/docs/physician.pdf. In fact, this document is so basic to a physician practice’s compliance program that I strongly recommend that every compliance program have this document printed off, included among the compliance program documents, and readily available for staff member review. Although this document was published in 2000 (and therefore refers to CMS as HCFA and doesn’t make reference to the Affordable Care Act), it can be considered a bit like the U.S. Constitution – a document that creates the foundation for what comes after and points to a better future.

H-Kocher-photo-2-199x300Heidi Kocher, Esq. is a health law attorney with the firm, Liles Parker, Attorneys & Counselors at Law.  Liles Parker has offices in Washington DC, Houston TX, McAllen TX and Baton Rouge LA.  Do you need to implement a complaince plan?  Call one of our experienced health care attorneys for assistance. For a free consultation, please call: 1 (800) 475-1906.

Mandatory Compliance Programs for Medicaid & Medicaid Providers?

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Mandatory compliance programs are required under the ACA.(July 30, 2014):  In recent years, both the type and the frequency of Medicare and Medicaid audits of health provider and supplier claims have greatly increased.  Not surprisingly, these administrative enforcement actions have led to a wide variety of adverse collateral effects, ranging from Medical Board investigations to the initiation of private payor audits.  Notably, the development and implementation of mandatory compliance programs can go a long way towards identifying potential problems needing remediation, thereby reducing your level of regulatory risk. Hopefully, these corrective measures will prevent the need for federal, state and private payors auditing bodies to disrupt your operations and conduct their own assessment of your claims.  As you would expect, it is far easier to create and implement an effective compliance plan than it would be to face an administrative, civil or criminal enforcement action due to your failure to fully comply with all applicable statutory and regulatory requirements.

A well-designed compliance program can benefit a physician’s practice by speeding up and optimizing the proper payment of claims, minimizing billing mistakes and hopefully reducing the chances that an audit will be conducted by one of the many contractors now working for the Centers for Medicare and Medicaid Services (CMS), the Department of Health and Human Services, Office of Inspector General (HHS-OIG), or the Department of Justice (DOJ).

The Affordable Care Act (ACA)  includes a provision which authorizes the Secretary, HHS to mandate that health care providers and suppliers establish a compliance program as a condition of their enrollment in Medicare, Medicaid, or the Children’s Health Insurance Program (CHIP).  As the statute provides:

‘‘(7) COMPLIANCE PROGRAMS.—‘‘(A) IN GENERAL.—On or after the date of implementation, as determined by the Secretary under subparagraph (C), a provider of medical or other items or services or supplier within a particular industry sector or category shall, as a condition of enrollment in the program under this title, title XIX, or title XXI, establish a compliance program that contains the core elements established under subparagraph (B) with respect to that provider or supplier and industry or category.”

While the Secretary, HHS, has yet to announce a date when all health care providers and suppliers must fully meet this requirement, it is important to keep in mind that for all practical purposes, that date has already arrived for most active health care practices.   Why do we believe that having an effective compliance program is already a necessity?  Several of the reasons we believe an effective compliance program is already required are outlined below.

I.  When Did Mandatory Compliance Programs Enter the Picture?

At the outset, it is important to keep in mind that if your practice or other health care organization is a participating provider and accepts Medicare Managed Care, you are already required to have implemented an effective compliance program.  Pursuant to 42 C.F.R. §§ 422.503(b)(4)(vi), 423.504(b)(4)(vi), and as incorporated into Chapter 21, Section 30 of the “Medicare Managed Care Manual”:

All sponsors are required to adopt and implement an effective compliance program, which must include measures to prevent, detect and correct Part C or D program noncompliance as well as FWA. The compliance program must, at a minimum, include the following core requirements: 1. Written Policies, Procedures and Standards of Conduct; 2. Compliance Officer, Compliance Committee and High Level Oversight; 3. Effective Training and Education; 4. Effective Lines of Communication; 5. Well Publicized Disciplinary Standards; 6. Effective System for Routine Monitoring and Identification of Compliance Risks; and 7. Procedures and System for Prompt Response to Compliance Issues.

These seven elements are functionally equivalent to the seven elements of an effective compliance plan identified by HHS-OIG in its publication, Compliance Program for Individual and Small Group Physician Practices.

As a result of these rules, all providers and suppliers accepting Medicare Managed Care already obligated to have implemented an effective compliance program.  In addition to Medicare Managed Care, many of the providers and suppliers now participating in state Medicaid program are also required to have an effective compliance program in place.  As a final point in this regard, we are now starting to see private payors incorporating a requirement that providers and suppliers implement a plan in order to participate in their program.

To address the question posed, in view of the above mandates, are participating providers required to have an effective compliance program in place?   Well, the answer is that it “depends.”  While most participating providers likely fall into one or more the categories which already obligate a provider to have a program in place, some participating individual providers and entities do not meet the categories of provider outlined above.  While the Secretary, HHS, has yet to announce when the remaining participating providers must comply with the provision of the ACA.  One this appears clear, as the percentage of providers and suppliers covered by these requirements continues to increase, we believe that it will become easier and easier for the Secretary, HHS, to require that all health care providers and suppliers adopt an effective compliance program — one that will that addresses the will be a certainty in the near future — regardless of whether the Secretary, HHS issues a deadline in this regard.

II.  Mandatory Compliance Programs Can Reduce Your Level of Regulatory Risk:

Reducing exposure to liability is one of the main reasons to implement and maintain a compliance lan. If a practice has and follows an active compliance program, it evidences that the medical practice has made reasonable efforts to avoid and detect misbehavior. It also shows regulating agencies that the requisite intent to commit health care fraud was not present. If wrongdoing is found, but a practice can establish that there was no intent to commit fraud, as evidenced by their compliance plan, penalties could be largely reduced.

III.  OIG’s Guidelines to a Physician Practice Compliance Program:

An effective compliance plan should be designed, implemented, and enforced with the goals of preventing, detecting, and correcting any inappropriate and potentially criminal conduct. Each physician’s practice will need its own unique plan to properly suit its services, and there is no single model plan to follow.

However, OIG has issued suggested compliance program guidance that was initially voluntary, but now is mandatory under the ACA.  OIG’s suggested compliance program includes seven components that a physician practice can use as a basis to create an effective program. These components are:

  1. Conducting internal monitoring and auditing;

  2. Implementing compliance and practice standards;

  3. Designating a compliance officer or contact;

  4. Conducting appropriate training and education;

  5. Responding appropriately to detected offenses and developing corrective action;

  6. Developing open lines of communication; and

  7. Enforcing disciplinary standards through well-publicized guidelines.

It is also recommended that a compliance plan states a code of ethical standards that is distributed and discussed within the practice. The standards should be made clear to employees and contractors, including the intent of the practice to take actions to uphold those standards. A baseline audit is highly recommended to identify areas in need of correction and risk areas that may need to be the focus of the compliance plan, such as medical record documentation, coding, or diagnostic testing criteria. After an initial baseline audit, a physician’s practice should conduct continuous and period audits thereafter. Finally, a compliance plan should include a process for responding to both staff and patient complaints, addressing identified offenses, and taking corrective action to prevent further similar offenses. If an internal investigation uncovers a material violation, a decision must be made, with counsel, whether to report the matter to the federal government. Disclosure may reduce sanctions; failure to disclose could limit the reduced culpability protections the plan might otherwise provide.

IV.  Final Remarks:

In today’s health care marketplace, recent laws and regulations illustrate the government’s focus on scrutinizing the actions of physician practices and other health care providers. A compliance plan tailored to the practice’s needs can help protect the organization from potential administrative, civil and criminal sanctions.  Need help putting an effective compliance program in place?  Give us a call.  The cost of development and implementation are probably far lower that your potential liability resulting from continuing going down the wrong road, in terms of documentation, coding or billing.

Robert W. Liles

Robert W. Liles, Esq., serves as Managing Partner at Liles Parker, Attorneys & Counselors at Law.  Liles Parker attorneys represent health care providers around the country in connection with both regulatory and transactional legal projects. For a free consultation, call Robert at: (800) 475-1906.

Does One of Your Employees Suffer from a Chronic Illness or Medical Condition? Consider the ADA When Assessing Their Request for Additional Medical Leave

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American with Disabilities Act -- ADA

(March 19, 2013):  It’s a fact of life – essentially all us will likely fall ill or develop a chronic medical condition at some point during our employment.  Employees working in physician offices, home health agencies and for Durable Medical Equipment (DME) suppliers are no exception.  When this occurs, owners and managers cannot forget their obligations under the American Disabilities Act (ADA) and its amendments under the Americans with Disabilities Act Amendments Act of 2008 (ADAAA).

I.  A Recent Decision by the EEOC Shows How Important ADA / ADAAA Compliance Can Be:

A recent decision in a Maryland case against a large physician practice illustrates the importance of considering each request for medical leave in a reasonable fashion.  In this case, an employee who suffered from Crohn’s Disease worked as an assistant for the practice, answering phones, scheduling appointments and conducting other administrative duties.  While undergoing treatment for her Crohn’s, she required two weeks of medical leave.  During this period, she went to the emergency room twice and was hospitalized at least once.  When she contacted the company to ask for an additional day (of unpaid leave), she was fired.  The fired employee filed a complaint with EEOC and the case ultimately resulted in a disability discrimination lawsuit being filed against the employer for alleged violations of the ADA Ultimately, the case was settled and the fired individual recovered $92,500.

II.  What Lessons Can You Learn from This ADA Case Settlement?

When assessing this case, the EEOC argued that the employer’s failure to provide a “reasonable accommodation” to the employee was a violation of the ADA.  As the EEOC specifically commented, the employer’s:

“. . . lateness and attendance policy violated the Americans with Disabilities Act, as amended (ADA), because it did not provide for exceptions or modifications to the attendance policy as a reasonable accommodation for individuals with disabilities.”

When it was unable to settle the case prior to filing suit, the EEOC brought an action against the employer for violations of the ADA and the ADAA.  When the case was subsequently settled, the District Director of EEOC’s Philadelphia District Office stated:

“It is not only a good business practice to provide reasonable and inexpensive accommodations that allow employees with disabilities to remain employed, it is required by federal law.”

In addition to the $92,500 settlement, the agreement reached requires that the employer modify its policies to permit the “reasonable accommodation for employees with disabilities.”  Additionally, the medical practice was also required to train all of its supervisory, managerial and human resources personnel on the ADA and post a notice regarding the resolution of the lawsuit at its facilities.  Ultimately, health care providers can avoid these problems entirely if they approach these situations in a reasonable fashion and recognize their obligations under the ADA.

III.   Conclusion.

Compliance with the ADA and other applicable statutes designed to prohibit and prevent employment discrimination of all of types should be an integral part of your Compliance Plan.  These obligations cannot be delegated or dispensed with contractually.  Therefore, we strongly recommend that you examine your personnel practice to help ensure that you are fully complying with the letter and the spirit of the law in this regard.

Healthcare lawyerRobert W. Liles is the Managing Member at Liles Parker.  He has extensive experience working on health care employment issues, in both a unionized and a non-unionized environment.  Should you have questions in this regard, please feel free to call Robert for a free consultation.  He can be reached at: 1 (800) 475-1906.


Employing Excluded Individuals Can Cost You!

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Employing Excluded Individuals(August 27, 2012):  As you may know, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) has the statutory authority to exclude providers from participation in federal health care programs. An exclusion is arguably the most serious penalty OIG can levy (we’ve previously called it the “nuclear bomb” of health care enforcement) and in essence prohibits an individual from working in the health care industry at all.  There are two types of exclusions: mandatory and permissive. Under its mandatory exclusion authority, OIG must exclude an individual, and they have no discretion to reduce or withhold the punishment. Mandatory exclusions generally last for 5 years. Permissive exclusions, on the other hand, are at the discretion of OIG, taking into account the egregiousness of the conduct, the danger to the Medicare Trust Fund or patients, and the provider’s prior history. Many permissive exclusions are for 3 years, but OIG can shorten or lengthen this time period based on mitigating or aggravating factors.

II.  Employing Excluded Individuals:

But what if it’s not you that is excluded, but instead an employee you hire? Are you on the hook for employing this excluded person? The short answer is yes. Under the civil monetary penalties (CMP) laws, OIG has the authority to assess substantial fines and penalties for several violations, including employing excluded individuals when the employer “knows or should know” that the person was excluded. In most instances, the government takes the position that the employer should have known about an employee’s exclusion based on the provider’s affirmative obligation to check the OIG and GSA databases, and the relative ease with which these databases may be accessed and searched. The knowledge requirement for employing excluded individuals essentially aligns with those of the False Claims Act (FCA): actual knowledge, reckless disregard, or deliberate ignorance.

II. Penalties for Employing Excluded Individuals:

The range of penalties OIG might assess for employing excluded individuals range far and wide. In the end, it really depends on whether the excluded individual is providing reimbursable health services that can be tied to a specific claim. If a doctor who is excluded, for instance, submits claims, the CMP laws call for a $10,000 penalty plus three times the amount claimed (not the amount the government actual pays). If, instead, a biller is excluded and works for a company, OIG usually assesses the company the value of the employee’s salary, sometimes multiplied. So if an excluded biller was paid $40,000 over the course of his or her exclusion, the company could be subject to penalties of $40,000 – $80,000, depending on the culpability of the company.

III.  Important Compliance Steps:

To prevent your company from employing excluded individuals, you should take two steps. First, you need to ensure that your Compliance Plan is effective, up-to-date, and followed by your employees. Establishing and enforcing an effective Compliance Plan is currently the most important step a health care provide can take to reduce the penalties incurred from the government, and reduce the risk of penalties altogether. We’ve discussed Compliance Plan implementation at length, but it bears repeating: get your Compliance Plan today, before you get a knock on the door from government investigators or contractors.

The other important step relates specifically to screening excluded individuals. You should check your current employees on a regular basis. We recommend every six months for smaller providers and once a month for larger providers (usually those with their own dedicated Compliance Officer). A new employee should be screened before they are officially hired, and you should ask on your employment applications if an applicant has ever been excluded from Medicare/Medicaid. In addition, and we can’t stress this enough, get an applicant’s social security number. Names change; numbers don’t. In our experience, the most common reason an employer hires an excluded individual is because they didn’t check all the possible names the individual might have. Many folks use their maiden name or some other alias, or the person checking simply hasn’t spelled the name correctly! As a result, it is best practice to also take down the applicant’s social security number and ask about other names used, so that all of these possibilities can be searched in the databases. At the end of the day, the most concrete way to establish if someone is or is not excluded is through their social security number.

Healthcare LawyerRobert Liles, in our Washington, D.C. office, advises clients on healthcare fraud and abuse matters, including exclusions and CMPs. In addition, he assists providers in implementing effective Compliance Plans and represents clients in Medicare overpayment appeals. For more information or a free 30 minute consultation, call Robert today at: 1 (800) 475-1906.

PMI’s Certified Medical Compliance Officer Program

January 27, 2011 by  
Filed under Firm News

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Certified Medical Compliance(January 26, 2011):    Robert W. Liles, J.D. Managing Partner at Liles Parker, has been asked by Practice Management Institute (PMI) to develop and present its new “Certified Medical Compliance Officer” (CMCO) program.  This Compliance Officer Certification course will be held over a five day period — February 3-4 and March 2-4, 2011.

I.  What is the Focus of PMI’s “Certified Medical Compliance Officer” Program?

This Certification course is uniquely designed to address the needs of non-hospital health care providers.  It is specifically for current and soon-to-be Compliance Officers working in Physician Practices, Home Health Agencies, Hospice Companies, Durable Medical Equipment Companies, Physical Therapy Clinics, Third-Party Billing Companies and other small to mid-sized health care provider entities.  Unlike other Certification courses, this program has been developed to meet your organization’s compliance needs, not those of a hospital or large provider institution.   The Compliance Officer Certification course and exam will take place in Dallas at the Texas Health Presbyterian Hospital Dallas.

II.  Instructors of PMI’s Certified Medical Compliance Officer Program:

The primary speakers during the first two days will be Mr. Liles and D.K. Everitt.  Please join Mr. Liles and Mr. Everitt in Dallas as they present the course.  Mr. Liles represents health care providers across the nation. He focuses his practice on healthcare compliance, large Medicare overpayment defense and regulatory matters.  Before entering private practice, he served as Deputy Director for Legal Programs at the U.S. Department of Justice, Executive Office for United States Attorneys (EOUSA).  Additionally, while at EOUSA, he also served as the country’s first National Health Care Fraud Coordinator, responsible for working with the civil and criminal health care fraud coordinators in each of the U.S. Attorney’s Offices around the country.

Mr. Everitt is a nationally-recognized Healthcare Compliance Officer, whose work includes assessing hundreds of medical practices and facilities, implementing Corporate Integrity Agreements and OSHA compliance training.  He has authored several compliance books and is credited with the definitive guide on OHSA for medical practices.  Mr. Eveirtt serves as president of The Compliance Division, L.L.C.  He has spent the last 25 years developing and managing corporate compliance programs and shares his talents as an Adjunct Lecturer and Preceptor for Trinity University’s Health Care Administration Graduate Studies department. He has shared his knowledge with participants at several of PMI’s conferences. Mr. Everitt also serves on PMI’s Contributing Editor Board of Experts.

To enroll in this class, or if you have any questions, call PMI at 1-800-259-5562 between the hours of 8 a.m. and 5 p.m., Monday through Friday. Seating is limited and will be provided on a first come first served basis.

Robert Liles Healthcare AttorneyRobert W. Liles, J.D., M.B.A., M.S., represents health care providers around the country in connection with Medicare, Medicaid and private payor audits.  He also provides regulatory compliance guidance and advice to providers and suppliers that participate in federal and state health benefits programs. For a free consultation, call:  1 (800) 475-1906.