FTLF Attorneys Adam Falcone, Michael Glomb, and Laura Hoffman recently led a comprehensive, multi-day training on corporate compliance for community behavioral health organizations presented by Familylinks, Allegheny HealthChoices, Conference of Allegheny Providers, and Holy Family Institute. The training centered on helping attendees protect their community behavioral health organization’s assets and minimize financial liabilities through effective corporate compliance programs.
The first day of the training explained current enforcement activities, described health reform’s compliance requirements, and identified the federal standards for effective compliance programs. In addition, the first day explained how to conduct a compliance risk assessment to identify key risk areas for community behavioral health organizations, develop an annual compliance workplan, and establish organization-wide accountability for compliance.
The second day of the training focused on potential areas of compliance risk for community behavioral health organizations. The training addressed compliance risks related to corporate governance, contracts and affiliations, billing and coding, and privacy and security under HIPAA and 42 CFR Part 2.
Building on the material presented over the prior two days, the week concluded with an optional three-day workshop to teach attendees how to conduct an effective internal investigation, featuring a role-playing exercise in which participants formed teams to conduct a mock investigation.
“As budgetary pressures grow at both the state and federal levels, policymakers will increasingly look to overpayment recoupments and penalties from providers to finance health care spending,” said Hoffman. “Compliance officers and management alike should make every effort to familiarize themselves with fraud and abuse laws and how to conduct internal investigations to make informed decisions on a range of issues from corrective action to litigation to government audits and investigations.”