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:

• 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.

To contact Feeley & Driscoll, please click here or call us at 1 (800) 392-6192.