Compliance
A Corporate Compliance Program is a formal program
which establishes internal controls to ensure that the entity operates
within the law. The complexity of a compliance program should correspond
to the size and complexity of the facility.
At Feeley &
Driscoll we use our experience gained in working with other healthcare
entities and provide compliance review services in the following areas:
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Medicare
and Medicaid:
coding, 72-hour rule, fraud and abuse, medical necessity, false claims
act, Stark I and Stark II.
-
Operations: conflicts
of interest, purchasing and procurement, Board of Directors training,
JCAHO and state surveys, contract administration, EPA, OSHA, clinical
laboratories.
-
Finance: internal
financial controls, bond indenture covenants, employee compensation
within reasonable limits, IRS intermediate sanctions, unrelated
business income, community service benefit, property and income tax
exemptions.
-
Human
Resources/Labor: wage
and hour administration, Americans with Disabilities Act, Family
Medical Leave Act, benefits administration.
Feeley
& Driscoll has staff with experience in each of these areas and is
able to provide the level of service desired by the organization.
Our typical corporate compliance review consists of three levels:
-
Level
One-Overview of Compliance Systems: general
overview of corporate compliance program that includes board of
directors’ issues, risk review, major issue identification and
completion of a general questionnaire.
-
Level
Two-Testing of Compliance Systems:
Appropriate testing of risk areas identified resulting in qualified
opinion on the overall compliance system and a determination of
whether each system is operating as designed.
-
Level
Three-Audit of Compliance Systems: Detailed
testing and research regarding specifically identified items to gain
the necessary understanding and assurance for each item. Examples of areas that may require detail review include
chargemaster, admitting/business office, home health agency, physician
practices, skilled nursing facilities, cost reports, etc.
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