Services

Compliance

• Development of Compliance Plan
• Development of Compliance Process
• Risk Assessment
• Audit Plan Development
• Policies & Procedures
• Education
• Investigation
• Review Organization Structure

Formal compliance programs help health care organizations operate within state and federal laws. Because the laws change and staff turns over, compliance requires continuous organizational attention. The heavy fines and penalties that can be levied for non-compliance more than justify the cost and effort necessary to maintain an effective, ongoing compliance effort.

McBee Associates believes effective compliance programs:

• Engrain into the corporate culture the need for all employees to understand the federal and state laws and regulations that affect their jobs;
• Ensure employees have the skills needed to successfully perform their job functions;
• Offer employees continual training in their job responsibilities;
• Establish an organizational structure that encourages compliance;
• Document all service provided, and policies and procedures, especially those in subsidiaries and satellite locations.

Development of a Compliance Plan

Active management participation is critical in plan development. During this phase, McBee Associates acts as a catalyst. We assist management in all functions to help them understand the importance of the plan development and the implementation stages.

Working with management, we set the standards for ongoing review and annual monitoring of plan activities. These steps help ingrain compliance activities into the client's corporate culture.

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Development of a Compliance Process

McBee Associates believes an effective compliance program is a continuous process. From the start, we assist our health care clients with developing that process. At every stage, McBee Associates works with client management to develop a compliance process that meets their specified needs. We begin with a written plan and remain on the job for implementation and to monitor key ingredients in the compliance program's success.

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Risk Assessment

Identifying areas at risk for non-compliance is the first step in compliance process development. Generally these areas have complex functions, high employee turnover, reimbursement issues, and potential inadequate supervision. Identification of these risk areas facilitates establishment of appropriate internal controls, periodic audits, and staff education.

To address the risk of non-compliance, McBee Associates reviews the organizational structure, interviews key department heads, traces work flows, and assesses performance levels. We also review policies and procedures. Based on our analyses, McBee Associates provides a report identifying areas with the highest risk.

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Internal Audit Function

A crucial part of compliance is an effective internal audit function. An internal audit routinely reviews identified high risk areas. A properly planned internal audit has a stated purpose, a work program, work papers, and a final report. The first draft of the report is presented to senior management.

McBee Associates has trained auditors who help establish an internal audit function, provide guidelines for the work program, and prepare work papers and the final report. We even help develop criteria for frequency of an internal audit.

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Policies and Procedures

A successful compliance program requires established policies and procedures for employees to follow. Employees in the high risk areas need training and periodic testing.

With our extensive operational experience in all financial areas, McBee Associates is uniquely qualified to complete this task. McBee Associates assists with policy and procedures updates, reviews them for internal control weaknesses, establishes compliance monitoring processes, and develops employee training programs.

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Employee Education

In a fraud review, the Office of the Inspector General (OIG) considers employee qualifications a key compliance indicator. Is the staff performing Medicare billing qualified to do so? Are employees current with AWA changes and new regulations? To adequately answer these questions, health care organizations need established qualifications and ongoing training and testing for employees in each position. Our training work reduces risk of non-compliance, and as a bonus, clients may experience increases in work quality that offset their training and testing costs.

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Investigation

When a potential compliance issue is reported, an institution must complete a formal investigation. The methodologies used and the results of the investigation should be documented. If non-compliance is discovered, they must be reported to the appropriate agencies. Every attempt should be made to invoke the attorney/client privilege.

McBee Associates can assist an institution with developing a formal investigation process and creating specific work plans for audits. McBee Associates routinely provides technical support to institutions' attorneys during investigations.

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Review Organizational Structure

The organization’s structure should encourage and support compliance. For example, employees responsible for the profitability of a function should not be involved in coding or billing. The employee may be tempted to maximize reimbursement by using codes that may not be justified by the level of service performed. The staff that performs billing should report to a supervisor who has extensive knowledge of the processes and regulations involved.

McBee Associates can review an institution’s organizational structure to determine areas that may increase the risk of non-compliance. McBee Associates reviews both the formal and informal reporting structures of an organization. A detailed assessment addresses the reporting structures, identifies apparent weaknesses, and makes recommendations to modify the structure.

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