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Donald Sinko, CPA Cleveland Clinic Chief Integrity Officer

HIPAA, Documentation, and Billing Compliance, Oh My!. Donald Sinko, CPA Cleveland Clinic Chief Integrity Officer. Promoting a Culture of Integrity and Ethical Behavior. Commitment to a Strong Corporate Compliance Program Strong senior management support

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Donald Sinko, CPA Cleveland Clinic Chief Integrity Officer

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  1. HIPAA, Documentation, and Billing Compliance, Oh My! Donald Sinko, CPA Cleveland Clinic Chief Integrity Officer

  2. Promoting a Culture of Integrityand Ethical Behavior Commitment to a Strong Corporate Compliance Program • Strong senior management support • Awarded 2009/2010 World’s 100 Most Ethical Companies • Comply with federal, state and local laws and regulations • Policies and standards of conduct

  3. Chief Integrity Officer: Reporting Lines Audit Committee of the Board of Directors Chief of Staff Corporate Compliance Committee Chief Integrity Officer CEO Office of Internal Audit Office of Corporate Compliance

  4. Promoting a Culture of Integrityand Ethical Behavior Integrity of Our Process • Compliance program procedures to prevent, detect and correct non-compliance • Compliance with contracts is audited • Cleveland Clinic has adopted the PhRMA Code and the AdvaMed Code of Ethics • Nationally recognized conflicts of interest policy

  5. Increased Scrutiny and Regulations • Mandating compliance (CMS, OIG Congress) • HIPAA privacy and security • Electronic medical record documentation • RAC and insurance company billing audits • FDA research audits • Physician contracts • Quality and safety • Form 990 tax compliance • Conflicts of interest

  6. Patient Data Privacy and Security • American Recovery and Reinvestment Act • Establishing standards • Importance of encrypting data • Laptops, thumb drives, Blackberry’s • Increased penalties • Properly dispose of PHI • De-Identify patient information • Breach reporting standards • HIPAA security risk analysis

  7. Other Compliance Issues • HIPAA • Unauthorized access • Unauthorized disclosures • Patient access to mental health records • Protecting drug and alcohol treatment records • HIPAA 5010 • Documentation shortcuts (e.g., copy & paste) • Coding/billing practices • Governmental improper payment initiatives • RAC, MIC, MAC, ZPIC

  8. Research Compliance Issues • Billing research charges vs. std. of care • Compliance with IRB approved protocols • HIPAA related to outside researchers • Ownership of research data • Consenting process • Conflicts of interest

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