COMPLIANCE PROGRAM OF KALAMAZOO EMERGENCY ASSOCIATES, P.L.C.
1535 GULL ROAD, MSB 015
KALAMAZOO, MICHIGAN 49048
Compliance Officers: Travis McClintock, M.D. has been designated as the KEA Compliance Officer. He will oversee and monitor KEA’s Compliance Program and is responsible for the following:
- Review, revise and establish where needed written policies and procedures to improve KEA’s efficiency and quality of services and to reduce KEA’s vulnerability to fraud, abuse and waste.
- Periodically revise the program to reflect changes in circumstances and application of the law and rules.
- Develop, coordinate and participate in educational and training programs to ensure that all Employees are knowledgeable of and comply with Federal and State laws and regulations.
- Ensure that independent contractors, vendors and agents who furnish services to KEA are aware of the requirements of KEA’s Compliance Program and sign KEA’s Pledge with respect to compliance, especially in coding, billing and marketing.
- Coordinate personnel issues with the administrators of KEA to ensure that the National Practitioner Databank and Cumulative Sanction Report have been checked with respect to all Employees, medical staff and independent contractors and that each Employee has been provided with and completed a questionnaire eliciting information about prior illegal activity.
- Assist KEA’s financial management in coordinating internal compliance review and monitoring activities including annual or periodic reviews of departments.
- Independently investigate, respond and report suspected violations, recommend appropriate corrective action, and document that such corrective action has been taken.
- Develop policies and programs that encourage Employees to report suspected fraud and other improprieties without fear of retaliation.
Training and Education
The proper education and training of Employees and the retraining of current personnel at all levels are significant elements of an effective Compliance Program. Training and education will include sessions highlighting KEA’s Compliance Program and Code of Conduct, summarizing fraud and abuse laws, coding requirements, claim development and submission process and marketing practices that reflect current legal and ethical standards. Additional training and education will focus on electronic billing of emergency room practice-related treatment and diagnostic charges. In addition to the specific areas identified above all employees are required to attend training and education on topics such as:
- Government and private payor reimbursement principles;
- General prohibitions on paying or receiving remuneration to induce referrals;
- Proper confirmation of diagnosis;
- Submitting a claim for physician services when rendered by a non-physician;
- Signing a form for a physician without the physician’s authorization;
- Alterations to medical records;
- Prescribing medications and procedures without proper authorization;
- Proper documentation of services rendered; and Duty to report misconduct.
Each employee will be required to attend one hour of education per year as part of their employment responsibilities. Attendance and participation in the training and education programs will be made a condition of continued employment with KEA and failure to comply with the training and education requirements may result in disciplinary action including possible termination. Training and education of an Employee will begin within three months of the Employee’s hiring date. Adherence to the provisions of the Compliance Program such as training and education requirements will be a factor in each employee’s annual evaluation. KEA may retain adequate records of its training and education of employees including attendance logs and materials distributed at training sessions.
Open Line of Communication. KEA will provide an open line of communication with the Compliance Officer. Confidentiality will be honored and there will be no retaliation against any Employee for communicating and reporting incidents of potential fraud, abuse and waste. The Compliance Officer will not divert or disclose to an Employee’s supervisor or other personnel the reporting of incidents of potential fraud, abuse and waste by any Employee.
Employees may report incidents of potential fraud, abuse and waste anonymously. KEA may assign a specific telephone number for receipt of anonymous information on noncompliance.
Disciplinary Accountability and Consequences. KEA has formulated guidelines regarding the consequences and disciplinary action for Employees who have failed to comply with KEA’s policies and procedures, Federal and State laws or this Compliance Program. The disciplinary measures will vary depending upon the severity of the transgression. If the noncompliance or transgressions are intentional or reckless, then the consequences will be severe. If the transgressions or noncompliance are negligent in nature, then the disciplinary consequences may be less severe. Sanctions could range from oral warnings to suspension, termination or financial penalties as appropriate. The disciplinary actions will be recommended by the Compliance Officer for action by the KEA President.
Disciplinary actions will be taken in a fair, equitable, appropriate and consistent manner. All levels of Employees will be subject to the same disciplinary action for the commission of similar offenses.
Auditing, Monitoring and Evaluation. An ongoing evaluation process is critical to this Compliance Program. The Compliance Officer or independent outside analysts and reviewers will perform the following tasks:
- On-site visits;
- Interviews with personnel involved in management operations, coding, claim development and submission, patient care and other related activities
- Reviews of medical and financial records and other source documents that support claims for reimbursement and Medicare cost reports; and
- Trend analysis or longitudinal studies that seek deviations positive or negative in specific areas over a given period.
The reviewers associated with KEA will be:
1. Independent of physicians and line management;
2. Have access to existing audit and healthcare resources, relevant personnel and all relevant areas of operation;
3. Present written evaluative reports on compliance activities; and
4. Specifically identify areas where corrective actions are needed.
- The Compliance Officer will document efforts to comply with applicable statutes, regulations and federal healthcare program requirements.
Response to Detected Offenses and Corrective Action Initiatives. Reports or reasonable indications of suspected noncompliance will result in KEA Compliance Officer taking prompt action to investigate the conduct in question and determine whether a material violation of law or the requirements of the Compliance Program has occurred. Such actions may include immediate referral to criminal and/or civil law enforcement authorities, a report to the government and the submission of any over-payments, if applicable. Advice from KEA’s attorneys may be sought to determine the extent of KEA’s liability and to plan an appropriate course of action.
This Compliance Program has the full support of the owners, board of directors, officers and employees of Kalamazoo Emergency Associates, P.L.C.
Signature on File
Eric Blackwell, President