Refuah Community Health
Collaborative (RCHC) PPS
Compliance Partner Training
2017
1
Welcome!
• In this training presentation, you will:
• Be provided an overview of the DSRIP Program and
RCHC
• Learn about RCHC’s Compliance Program and Partner
Responsibility under the Compliance Program
• Know who to contact with DSRIP related compliance
questions
2
RCHC’s Compliance Program
Introduction
•
•
•
•
What is DSRIP?
Delivery System Reform Incentive Payment program =
DSRIP
DSRIP´s purpose is to fundamentally restructure the
health care delivery system by reinvesting in the Medicaid
program, with the goal of reducing avoidable hospital use
by 25% over 5 years.
DSRIP aims to restructure the health care delivery system
through incentivizing and investing in provider
collaborations, also known as performing provider
systems (PPS).
Each PPS is required to commit to work on at least 5, but
no more than 11 projects defined under the DSRIP
program; each PPS must work with its Partners to identify
which Partners will work on which projects.
3
RCHC’s Compliance Program
Introduction
RCHC Background
• RCHC is the only federally qualified health center
led PPS
• Refuah Health Center- lead
• Serves Rockland and Orange Counties
• Mission is to provide high quality clinically
integrated health services that improve and
promote the health and wellbeing of the
communities we serve while effectively managing
medical costs.
4
Refuah CHC DSRIP PROJECTS
• Project 2.a.i.- Create an integrated delivery system focused on evidence
based medicine and population health management
• Project 2.a.ii - Increase Certification of Primary Care Practitioners with
PCMH Certification and/or Advanced Primary Care Models
• Project 2.c.i - Develop a Community-Based Health Navigation Service to
Assist Patients to Access Healthcare Services Efficiently
• Project 3.a.i - Integration of Primary Care and Behavioral Health
Services
• Project 3.a.ii - Behavioral Health Community Crisis Stabilization Services
• Project 3.a.iii - Implementation of Evidence-Based Medication
Adherence Program in Community-Based Sites for Behavioral Health
Medication Compliance
• Project 4.b.i - Promote Tobacco Use Cessation, Especially Among Low
SES Populations and those with Poor Mental Health
5
RCHC’s Compliance Program
Introduction
What exactly is compliance?
• Establishes and promotes a culture of integrity and
ethical behavior
• Utilizes tools to prevent and/or detect violations of
law or policy
• Encourages problems to be reported
• Provides a mechanism for constant monitoring
• Provides assistance in complying with complex
governmental regulations
• Safeguards public and private funds; helps control
fraud, waste, and abuse
6
RCHC’s Compliance Program
Introduction
As a Partner, what am I expected to do?
• Participate in good faith in meeting the
applicable metrics of the DSRIP program
• Implement training and education provided by
the PPS Lead
• Develop or maintain a compliance program
where required under NYS law
• Observe contractual and other compliance
requirements as required by the PPS Lead and
state law, regulation, and policy
7
RCHC Compliance Program
8
RCHC’s Compliance Program
Consists of…
• Compliance Plan
• Designation of a Chief Compliance Officer
• Written policies and procedures
• Anonymous reporting mechanism
• Training and education responsibilities
• Oversight from Executive Governing Board
• And more!
9
Role of Compliance Committee and
Executive Governing Body (“EGB”)
• The EGB is tasked with overseeing the Compliance Program and must
make reasonable efforts to ensure the Compliance Program is effective
and potential risk areas are identified and addressed.
• The Compliance Committee meets as needed and assists the EGB in the
oversight of compliance with legal and regulatory requirements of a PPS
under DSRIP, including but not limited to, ensuring that RCHC takes all
reasonable steps to ensure the Medicaid funds distributed as part of
DSRIP are not connected with fraud, waste or abuse
• Compliance Committee also reviews and approve compliance policies,
procedures and plans and ensures the program meetings OMIG
Requirements
10
RCHC Compliance Plan
• Mission is to instill a culture of prevention, detection,
and resolution of all instances of non-compliance with
DSRIP Rules and Regulations as well as PPS Protocols.
• Ensures that PPS Providers and Personnel are familiar
with DSRIP conditions of participations, applicable
federal and state rules and regulations, and properly
implement PPS Project Plans.
• Compliance Plan can be found online at:
http://www.refuahchc.org/compliance/
• Any questions about the Compliance Plan or policies
and procedures should be directed to Azizza Graziul,
Esq. at [email protected]
11
RCHC Policies and Procedures:
Where can I find them?
• Can be found on RCHC’s website:
http://www.refuahchc.org/compliance/
• Includes all PPS approved policies
• Check often for new policies added and/or
revisions to made to existing policies
12
Designation of Chief Compliance
Officer
• RCHC has designated a Chief Compliance Officer charged
with the day to day operations and monitoring of the
Compliance Program.
• RCHC’s Chief Compliance Officer is Azizza Graziul, Esq. She
can be reached at 845-354-9300 x 1257 or by email at
[email protected]
13
Standards of Conduct
• Sets forth principles of ethical and professional behavior that RCHC Personnel, PPS
Providers, and those that perform DSRIP Program-related activities are expected
to follow
General Standards:
• Standards place affirmative duty on all personnel to report actual or
perceived violations
• Personnel are expected to be familiar with and abide by RCHC’s Compliance
Program and policies and procedures.
• No employment, engagement, or payment to excluded entities or persons:
• In order to receive federal funds under DSRIP, a partner must not be an
excluded entity. Monthly exclusion checks are performed.
• Personnel must appropriately and accurately record and report DSRIP-related
information, transactions and activities, including records related to patients
and their care.
14
Standards of Conduct
Confidentiality- Patient Information:
• All personnel must abide by HIPAA privacy and security standards
regarding protected health information
• Patient information must be treated with utmost confidentiality
Confidentiality- Business Information:
• Personnel may gain access to confidential information by virtue of his/her
participation in or position within their respective organization.
• Personnel may not communicate confidential information about its
organization, partners, or any patients covered by the DSRIP program as it
pertains to RCHC, including information of or about another RCHC
participating entity or its patients, to anyone and may not be used as a
basis for personal or family gain
15
Who Do I Contact with DSRIP
Related Compliance Concerns?
• Speak with your supervisor or manager
• Contact RCHC’s Chief Compliance Officer, Azizza
Graziul, Esq., directly at 845-354-9300 x 1257 or
[email protected]
• You may report any potential instances of noncompliance anonymously through the Compliance
Hotline:
• By Phone: (844) 280-0009
• By Email: [email protected] (must mention RCHC in
subject line when reporting)
• Hotline is open 24/7/365
16
Training and Education
• Partners are expected to disseminate all trainings
and education to their organization from RCHC
• Partner will attest to the dissemination of all
trainings to RCHC
• “Targeted” trainings provided to individual partners
engaged in RCHC projects
17