TOP	Reimbursement Management | Third Party Management | Compliance Risk Management Strategic Management | Financial Management | Home COMPLIANCE RISK MANAGEMENT How Effective is Your Compliance Program? HBC knows an effective compliance program can mitigate potential fines and sanctions. In fact, ineffective programs, which are not properly implemented and enforced, pose more risk than not having a program at all. The services of HBC will lower the probability of an adverse result in a focused medical review. What Elements are Required? According to the Federal Sentencing Guidelines, an effective program must contain seven key elements: 1. A general statement of conduct that promotes a clear commitment to compliance. 2. Recognition of the importance of compliance by the appointment of a trustworthy compliance officer with a high level of responsibility. 3. Effective training and education programs for all professional and support personnel. 4. Auditing and monitoring processes. 5. Specific and effective lines of communication between the compliance officer and professional and support personnel. 6. Internal investigation and enforcement through publicized disciplinary guidelines and actions. 7. Processes to respond to identified offenses and apply corrective action initiatives. Hospital-Based Physicians Face Greatest Risks Hospital-based practices are more apt to be drawn into question by government investigators for several reasons: • Hospitals and healthcare systems you serve are pronounced targets • Broader medical necessity demands for your sophisticated services • Reliance on hospitals for sufficiently detailed patient billing information • Significant discrepancies between physician coding and facility coding Our compliance assessment and ongoing risk management program provide an early warning detection system, which will lower your probability of inadvertent compliance exposure. HBC Compliance Management Services Written Procedures and Policies Standards of Conduct Medical Necessity Diagnostic/Procedure Coding Billing/Claims Processing Discount Arrangements Appointment of Compliance Officer Education and Training Communication Access to Compliance Officer Telephone/E-Mail Hotline Regular, Periodic Publications Auditing and Monitoring Regular, Periodic Audits Interviews with Key Personnel Formal Audit Reports Investigation/Response Strategy Disciplinary/Corrective Action Record Creation and Retention The HBC Difference • Comprehensive, up front compliance assessment • Customized, documented policies for areas of potential risk • Effective, ongoing documentation and enforcement program • Periodic, on-site education and training sessions • Regular, mandatory high-level corporate compliance meetings