BOARD OF DIRECTORS. Corporate Compliance Report. September 28, 2018
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1 BOARD OF DIRECTORS Corporate Compliance Report September 28, 2018
2 Meeting Objectives Metrics o CCHHS Provider o CountyCare Health Plan Appendix: Updated Corporate Compliance Mission & Vision Statements Board Review and Approve 2 Audit & Compliance Committee of the Board I September 28, 2018
3 Other 11% Reg/Policy 10% Provider Metrics: Issue Breakdown by Category December 2017 May 2018 (County Fiscal Year 2018) Total Issues = 384 HIPAA % HR 95 25% Reg/Policy 57 15% Other 48 12% Contract 29 8% Accurate Books 29 8% COI 10 2% Reactive Issues = 283 or 74% Notification or allegation of an issue that impacts compliance, requiring investigation. Contract 11% HIPAA 30% Contract 16% month Volume 384 FY 2017 FY 2018 Proactive Issues = 101 or 26% Requesting guidance prior to engaging in or undertaking an activity that could impact compliance, requiring research. HIPAA 31% 3 Human Resources 33% HC Fraud 2% Accurate Books COI 8% 1% Reg/Policy 30% Other 10% Human Resources 1% COI 7% Accurate Books 5%
4 Fraud, Waste and Abuse Metrics CountyCare Fraud, Waste and Abuse (FWA) metrics are tracked by State Fiscal Year (S-FY) not County Fiscal Year S-FY 2018 is July 1, 2017 June 30, 2018 Member Allegations S-FY17 S-FY18 Q1 S-FY18 Q2 S-FY18 Q3 S-FY18 Q4 Total Member Allegations Provider Allegations S-FY17 S-FY18 Q1 S-FY18 Q2 S-FY18 Q3 S-FY18 Q4 Total Provider Allegations Grand Total FWA Issues Received Per 1,000 members.09/1000.1/ / / /1000 In S-FY 2018, CountyCare referred 14 cases to the HFS OIG for possible fraud, waste or financial misconduct. SIU Algorithms as of S-FY18 Q4 Providers Members Medically Unlikely Edits 39 1,714 DRG Duplications 7 11 Multiple E&M Paid Same Day 59 2,176 Hospital Transfer Billed as Discharge New Pt CPT Paid After Prof Service 87 5,480 Professional vs. Surgical Cross-Code Payments for Add-on No Base Code 61 1,184 Age Related Codes 7 27 Prof Global Charge Member in Facility 79 9,275 Inpatient Only Procedures Procedure to Procedure 5 48 Grand Total ,623 4 Audit & Compliance Committee of the Board I September 28, 2018
5 Appendix: Updated Corporate Compliance Mission & Vision 5 Audit & Compliance Committee of the Board I September 28, 2018
6 CCHHS Corporate Compliance Mission Statement The Office of Corporate Compliance upholds the mission, vision, and core values of Cook County Health & Hospitals System (CCHHS) by Developing standards to guide everyone affiliated with CCHHS to Do the Right Thing Increasing compliance awareness through education and training Promoting collaboration, honest behavior, mutual respect, and professional responsibility to support compliance with applicable laws, regulations, and systemwide policies. 6 6 Audit & Compliance Committee of the Board I September 28, 2018
7 CCHHS Corporate Compliance Vision Statement To ensure safeguards are in place for our patients, health plan members, health plan providers, the residents of the county of Cook, and our workforce members, staff, and the public at large, the Corporate Compliance Program will be a resource to everyone affiliated 1 with and cared for by Cook County Health & Hospitals System. 1 For the purposes of this statement, affiliated is defined as all patients, health plan members, health plan providers, the residents of the county of Cook, and workforce members that include employees, medical staff, house staff, Board members, volunteers, students, partners, consultants, agency personnel, and vendors. 7 7 Audit & Compliance Committee of the Board I September 28, 2018
8 Request to Approve Updated Corporate Compliance Mission & Vision 8 Audit & Compliance Committee of the Board I September 28, 2018
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