PFC Health Care Compliance Services

HEALTH CARE COMPLIANCE PROGRAM SERVICES

Provider Fraud Consultants, Inc. (PFC)

Daniel J. Osborne, M.S., Founder & President

18065 238th Street, Tonganoxie, KS 66086

(913) 669-6987 cccpfc@gmail.com

Compliance services delivered by a recognized compliance authority on-site, off-site and telephonically to employ:

¨ Auditing, Monitoring & Reporting —baseline audit to set program foundation, ongoing systems to proactively discover violations of law;

¨ Overall Compliance Program Oversight —train internal staff on compliance officer (CO) responsibilities. In some cases we serve as C.O.;

¨ Compliance Policies & Procedures —specific to practice (based on audit findings) with compliance program forms;

¨ Education & Training —general and specialty compliance program training, meet government standards on compliance education & training;

¨ Due Care in Delegation Authority —employ ‘trust but verify’ system to ensure discretionary authority is not inappropriately delegated;

¨ Enforcement & Discipline —launch system to hold representatives accountable to follow organizational compliance standards, etc.;

¨ Response & Corrective Action —mechanisms to ensure timely & appropriate remediation...

* Checkout our LINKS page to access ‘key’ sites to enhance compliance efforts; Visit our ARTICLES page to retrieve writings on health care fraud & compliance topics

1. Review compliance program guides and confer with qualified compliance resources.

2. Ensure understand what a compliance program is, what is required and efforts demanded.

3. Consult legal counsel for guidance and direction of baseline practice audit (understand “attorney-client privilege”).

4. Have qualified practice auditor audit practice to detect practice time-bombs & violations with recommendations for remedial actions.

5. Develop, implement and follow through with corrective action plan to address violations identified in baseline audit.

6. Define scope of compliance program, ensure have access to ALL relevant laws, rules & guidelines for which you are expected to comply.

7. Publish compliance policies & procedures tailored to practice to address identified risks and prevent reoccurrence of violations.

8. Empower qualified individual (s) with overall oversight of implementing / administering compliance program.

9. Provide mandatory general training to educate ALL employees on compliance standards, and specialty training for key employees on risk areas. Obtain “certifications” of attendance

10. Use due care not to delegate substantial discretionary authority to those having propensity to engage in illegal and/or inappropriate conduct

11. Ensure compliance standards enforced via case specific discipline, including failure to detect.

12. Employ auditing & monitoring to detect violations, and establish effective lines of communication to facilitate internal reporting.

13. Take necessary corrective action to respond to violations in a responsible and timely manner.

14. Periodically evaluate effectiveness of your compliance program, change as indicated.

15. DOCUMENT (public) compliance efforts in compliance binder, include compliance program in marketing, take pride in your hard work and practice with certainty!

Health Care Compliance Programs, A Closer Look

Some say our Compliance services are too tough & approach too black-&-white.

· We acknowledge being tough when providing Compliance services for clients. Compliance is serious business for clients and we treat it that way! After all, it is not our potential exposure we are attempting to mitigate. Rather, it is our clients’. Our mission is to make our clients experts on self-policing, and to keep them from becoming fraud targets, out of the danger-zone and clear of any administrative, civil and/or criminal exposure — keeping practices from getting crushed by investigations, loss of license, civil judgments, fines &/or prison, and helping practices make more money and keep more of it without having to pay it back or pay legal fees to defend misconduct!

· We do keep things black-&-white and don’t believe that one can think too much in the black-and-white. Undoubtedly, grey-area issues pose both potential and unnecessary exposure for clients. Some consultants may prefer that their clients operate in that grey-area, suggesting that attorneys fight and argue points-of-law if the client is challenged on the activity. Fortunately for our clients, we do not operate that way. We refuse to place our clients in no-win situations. External entities may not see the issue as grey. Legal battles over this type of activity can be costly! Compliance consists of not only meeting the letter-of-the-law but also the spirit-of-the-law. Missteps in handling these grey-areas can result in extreme consequences for health care professionals.

PFC affords HEALTH CARE PROFESSIONALS the who, what

when, where, why & how for employing ‘effective’

Health Care Compliance Programs

Ask for a complimentary copy of implementing health care compliance

“... When I began to have real compliance questions about practical practice applications, who should I, as our practice’s compliance officer, turn to for answers? … Through the course of my research looking for a source of authoritative knowledge on the subject I found (PFC) Dan Osborne. … I was impressed with his depth of experience and extensive qualifications on the subject. Subsequently, I hired (PFC) to help me with compliance in our practice. I couldn’t be more pleased – finally I have the answers to my questions – not just opinions but real answers from someone who is extremely qualified to give those answers. If you are happy with business as usual and don’t see any real need to get serious with your practice’s compliance efforts then don’t change a thing. But if you are ready to practice with assurance and confidence then the best thing you can do for your practice future is give (PFC) a call today. I will be happy to visit with you about my experience with (PFC). Please feel free to call me at (417) 667-3456.” Gary Kurtz, D.C. Read More

“Effective” Compliance Programs offer Preventative Medicine for the Legal & Regulatory Risks faced by Today’s Health Care Professional. Contact PFC for

pre-emptive procedures to grow your effective Self-Policing Systems

Call 913-669-6987 or email cccpfc@gmail.com for a ‘confidential’ Free Consultation

Compliance is SERIOUS BUSINESS, We treat it that way — Saving you

TIME & MONEY!

See ‘A Closer Look’ Below

The government recommends that

ALL health care professionals

implement compliance programs to self-police themselves as a means to ensure compliance with the laws & rules.

For this self-policing, the government allows for penalty mitigation for those having had an “effective” program in place at the time of the violations. (Effective = meet ALL key compliance program components as found in the FSG).

The government warns that because of the false sense of security a compliance program instills, and ability of illegal activity to continue, an ineffective program can be worse than no program at all!

EDUCATION & TRAINING PROGRAMS | PRACTICE AUDITS | COMPLIANCE PROGRAMS | INVESTIGATIVE ASSISTANCE

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