Right-Sizing Your ED Amid Health Reform
Dr. Randy Pilgrim offers tips on how to prepare your ED for future challenges during this era of health care reform.
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Maintaining the highest standards of corporate compliance
Schumacher Clinical Partners is committed to high standards of ethical conduct. Review our compliance programs and policies below.
[+] Corporate Compliance Program
In order to maintain its commitment to high standards of conduct, honesty and reliability in its business practices, the Schumacher Clinical Partners Board of Directors established a Compliance Program in July 1997. Our Compliance Program has been developed in accordance with applicable federal and state laws, and with guidance from federal authorities, including the United States Federal Sentencing Guidelines.
The Compliance Program provides a solid framework for structuring a comprehensive range of compliance activities that are designed to avoid legal and ethical problems, to effectively address compliance allegations as they may arise, and to remedy the effects of noncompliance. We incorporate elements as outlined in the OIG Guidelines for having an effective Compliance Program, including:
Code of Conduct & Policies and Procedures The company Code of Conduct provides guidance to all team members on carrying out daily activities within appropriate ethical and legal standards. The Code of Conduct was developed to help ensure we meet our ethical standards and comply with applicable laws, rules and regulations. It is a critical component of our overall Compliance Program and is an important resource — especially in situations where questions may arise about determining the right thing to do.
The Code of Conduct includes the potential consequences to both Company and our team members for failure to comply with all statutes, regulations and guidelines applicable to federal and state healthcare programs. The standards set forth in the code are mandatory and should be applied in all decision making. The business practices that are addressed in the code include, but are not limited to:
• coding and billing
• false claims act and deficit reduction act (whistleblower provisions)
• financial accounting systems
• stark law
• anti-kickback statute
• emergency medical treatment
• privacy of patient information
• conflict of interest
• gifts and business courtesies
• use of resources and assets
• corporate opportunities
• accuracy of records and document retention
• confidential business information
• information technology and resources
• requests for information pursuant to an investigation or legal proceeding
• political and charitable activities
• workplace violence
• workplace health
• workplace safety
• team member screening
• professional licensing
All Company team members are encouraged to conduct themselves in a way that supports the highest standards of ethics and integrity and to follow the standards set forth in our Code of Conduct and ethics and our policies and procedures without exception.
Education and Training All new team members must attend a Company Corporate Compliance Program training upon hire or contracting and annually thereafter. Each employee, including contractors, must receive, acknowledge and attest to the Code of Conduct. We also require annual distribution of the code, as well as employee receipt, review and attestation.
Additional specialized training is offered in areas such as HIPAA Privacy and Security, EMTALA, fraud and abuse, sexual harassment and Internal Controls Over Financial Reporting Program. Training is delivered through webcasts, online courses and instructor-led sessions. All training is tracked in the Company’s learning management system.
We have a full suite of compliance policies and procedures. We perform a routine review and revision of our policies and procedures to stay abreast of both internal and external developments. Team members receive and review updated policies and procedures, specifically those that are directly related to job function and accessible through Company portals.
Auditing and Monitoring Our Company has developed extensive auditing and monitoring of our Emergency Medicine and Hospitalist Medicine divisions to assess internal controls and processes for compliance with all applicable laws, rules and regulations. The Office of the Inspector General has published areas of concern and our compliance department has developed an annual work plan along with audit tools for each area of concern to assist in evaluating our Company’s risk for each of these areas. Compliance professionals work in conjunction with other departments to accomplish the necessary goals and objectives of our Compliance Program.
Privacy and Security Our Company is committed to maintaining the confidentiality, privacy and security of its patients’ protected health information. Consistent with the Health Insurance Portability and Accountability Act, we do not use, disclose or discuss patient-specific information, including patient financial information, with others unless it is necessary to serve the patient or required by law.
We are committed to being conscientious and accountable when handling confidential Company information. In addition, because of its confidential nature, business, health and financial information must be protected by an effective internal control environment, including policies and procedures to secure the Company’s assets, and made available outside the Company only with appropriate authorization and after consideration of the interests of the Company as a whole.
Protecting Company’s information assets is everyone’s responsibility. Examples of confidential information include:
• Patient’s protected health information
• Company financial information, including financial statements, payroll records, accounts payable summaries, vendor listings and price/cost information
• Written and verbal agreements between team members, agents, strategic partners, vendors and/or other third parties
• Trade secrets
• Due diligence information about potential acquisitions
• Customer lists and agreements, market share data and strategic plans
• Policies, procedures and processes
Compliance Hotline SCP's Compliance Hotline provides a confidential and anonymous line of communication for team members to report complaints or concerns Individuals may contact the Compliance Hotline 24 hours a day, seven days a week at 1.800.826.6762 or via email or website. The toll-free telephone number and website are hosted by an independent third party vendor.
Our Company makes every effort to maintain, within the limits of the law and within the bounds of an appropriate investigation, the confidentiality of the identity of any individual who uses the Compliance Hotline or dedicated website. There will be no retribution or discipline for anyone who reports a possible violation in good faith.
Compliance Oversight The success of our corporate Compliance Program relies on high-level oversight from our Board of Directors as well as buy-in, support and accountability from team members. Listed below are the committees and individuals who support our Compliance Program.
• The audit committee of our Board of Directors provides regular guidance regarding the direction of the Company’s Compliance Program. In addition, the committee receives regular reports on the status of the Compliance Program. Our Chief Compliance Officer has a direct reporting line to the audit committee.
• The compliance committee monitors the Compliance Program. It is comprised of members of senior leadership team and other key leaders within the Company.
• Our Chief Compliance Officer oversees the Compliance Program and evaluates compliance issues/concerns within the organization. The Chief Compliance Officer helps ensure that the Board of Directors, management and team members are in compliance with the rules and regulations of regulatory agencies, that Company policies and procedures are being followed and that behavior in the organization meets the Company’s Code of Conduct.
• Each team member has a shared responsibility and commitment to our mission of healthcare service to our patients. Compliance is the responsibility of every team member and to always do the right thing with integrity, and to make all clinical decisions based solely on the needs of the patient.
- Other Duties and Responsibilities
- Corporate Practice Medicine State Laws
- Nurse Practitioner/Physician Assistance State Practice Laws
- Internal Controls over Financial Reporting Program
[+] Emergency Medical Treatment and Active Labor Act
EMTALA (Emergency Medical Treatment and Active Labor Act) compliance involves the understanding and interpretation of multifaceted concepts. Review commonly asked EMTALA questions and answers below, and explore the online resources for more information.
- What are EMTALA requirements?
- What is a “medical screening examination”?
- What is an "emergency medical condition"?
- What is “necessary stabilizing” treatment?
- What is an “appropriate” transfer?
- What are “on call” responsibilities?
- What are the consequences of an EMTALA violation?
We encourage you to take the time to review the online resources provided below. They are intended to provide you with a functional knowledge of your professional and legal obligations under EMTALA, which will enhance and support your medical practice. Please feel free to contact us should you require any additional information.
Online EMTALA references
Interpretive Guidelines: http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/som107ap_v_emerg.pdf
[+] Additional Compliance Policies and Statements
- Nondiscrimination Statement: Schumacher Clinical Partners complies with applicable Federal civil rights laws and does not discriminate on the basis of race, color, national origin, age, disability, or sex. View the Nondiscrimination Statement for information on services available to our patients.
- Notice of Privacy Practice