Compliance

"Do the Right Thing each and every time!"

The Department of Compliance and Ethics ("DCE") is dedicated to promoting the highest standards of compliant and ethical behavior throughout Broward Health. The DCE strives to ensure compliance with laws and regulations, "always doing the right thing," and generally promotes a culture of integrity throughout Broward Health.

The DCE initiatives presented include:

• General Compliance Program Requirements: The DCE initiatives reflect the Office of Inspector General's (OIG) seven elements of an effective compliance program.
• Coding Program: The DCE has adopted a risk-based approach for all monitoring and auditing activities. To implement this, from a coding perspective, the Department of Compliance and Ethics has conducted a Coding Risk Assessment to identify high risk codes by value and volume.
• Billing Program: The following audits are planned to be performed quarterly:
  Denials – Assessment of claims denied by payer. The assessment will include interview analysis; process review; types of denials; reasons for denials; volume; resubmissions; timeliness; and gap analysis. [CBO, Best choice Plus/ TCA].
  Claims Modifications – Assessment of processes and modification types for Medicare and Medicaid claims. The assessment will include interviews; volumes; inpatient & outpatient modifications; reasons for changes; percentage of each change type; flow chart process; and documentation. [CBO, Best choice Plus/ TCA].
  Assessment of sponsored research billing – Assessment will include reviews of process; flow chart process; billing insurance for standard of care & the study; review of billing of ancillary services; hospital overhead reimbursement; timeliness; and gap analysis. [CBO]
• Ancillary / Regulatory: The DCE has addressed compliance with Federal and State requirements including, but not limited to the Anti-Kickback Statute and Stark Laws. We have done audit reviews with our Broward Health Ancillary services such as Home Health, Hospice, and Laboratory.
• HIPAA Compliance: The DCE also oversees initiatives to ensure compliance with the Health Insurance Portability and Accountability Act (HIPAA) Privacy and Security Standards. Information Services, Total Claims Administration, the Central Business Office, and Regional Medical Staff Offices have been instrumental in ensuring compliance with the National Identifier Standards.