Hospital General Counsel Panel at the Massachusetts Health and Hospital Association 2022  

Featured speakers: Joshua Abrams Senior Attorney, Mass. General Brigham; Meg Cosgrove, Senior Associate General Counsel, Beth Israel Lahey Health; and Dianne Yacovone, Associate General Counsel, Boston Medical Center 

Abrams, Cosgrove, and Yacavone addressed the Massachusetts Health and Hospital Association’s Healthcare Legal Compliance forum in December 2022. This recap of their remarks looks at current challenges in patient discharge rules and practices given the shortage of nursing facilities and challenging patient situations.  

Patient Discharge Challenges 

While some patients delayed getting care during the pandemic others face new medical situations because of it, creating shortages in some healthcare settings.

• What is a reasonable, safe discharge plan when there’s a bed shortage?
• How do you handle disputes between family members and the hospital?
• How do you balance the needs of the patient in the bed against the person who needs the bed next?
• What happens when patients don’t have a decision maker?  

A panel of healthcare general counsel tackled these questions and more at the Massachusetts Health and Hospital Association’s Healthcare Legal Compliance forum in December 2022.  

Discharge Planning Starts at Intake 

Cosgrove noted that people are presenting to the hospital much sicker than they would have previously. The explosion of Covid and flu cases emergency departments in late 2022 has made ERs even more crowded. There has been a collapse in outpatient and community-based supports for a lot of people, she said, and staffing shortage at nursing facilities continue. She said it was bad before the pandemic, and it’s worse now. Add to that: emergency departments are over capacity, so they end of admitting people to the hospital they wouldn’t typically. There simply isn’t a better option. 

One way to limit discharge issues is to be sure to admit only people who truly need to be admitted, according to Abrams. This starts with the ER triage process, where patients who don’t need to be seen in the emergency room are given guidance on other options. From there, his colleagues try to resolve health concerns in the ER rather than admitting. It’s important to resolve the emergency and move people out.

“Once you decide to admit someone, you have the overlay of Medicare requirements that impact the ability to discharge the patient.”  – Joshua Abrams

Safe, Appropriate, and Achievable Discharge Plans 

While the standard for discharge plans is “safe and appropriate,” Abrams also adds “achievable.”  Yacavone noted that while there is always a “best” option, sometimes you have to also look at what can actually happen upon discharge. This is especially true when the patient doesn’t have a surrogate decision maker or lacks the capacity to apply for state aid.  

Her team works to secure conservatorship for patients like this – either for a family member or the hospital. That way the hospital can discharge the patient to a skilled nursing facility (SNF) or other more appropriate setting. She works with a cross-functional team to streamline the process of identifying cases, working with outside counsel, and moving the process along.  

Providing this support is helpful when family members aren’t engaged, when they don’t know how the process works and avoid the discharge conversation all together. 

When the Patient Rejects the Discharge Plan 

When a hospital finds a bed in an SNF and the patient or a conservator is able to approve it, there can be another challenge. The patient or surrogate may not like the available SNF. Abrams and Cosgrove both talked about issues surrounding sign-off. The patient or family may have a specific SNF in mind, or they may not like the reputation of the one that’s available.  Staffing shortages and longer SNF stays make it harder for people to get the facility they want. And it means hospitals have to make really hard calls, because they have sick patients in the ER who need the beds.  

Cosgrove suggested reminding people of the risks of staying in the hospital, especially infection. She also suggested that the care team rely on any preferred providers the family has responded well to. They may be more receptive to the discharge plan if it comes from someone they trust. Be mindful of cultural or language barriers, and remember the patient’s right to make his or her own discharge decision, even if it’s a bad one. 

Behavioral Health Discharge Planning 

Cosgrove noted that behavioral health patients have additional discharge challenges because of the lack of beds in behavioral health facilities. She offered these six tips for inpatient discharge planning, based on her experience with a daily cross-functional planning meeting: 

1. The best mechanism is to start treatment as soon as possible in the ER. That might mean shoring up your ER’s clinical capacity for behavioral health. If the ER can serve as a mini mental health crisis stabilization center, patients can be stabilized without being admitted.  

2. Work your relationships in advance. Cosgrove ran a pilot with the SNFs, group homes, schools, and residential placements that send the most people to her ER. The pilot looked at why they were sending so many patients and sought ways to support the patients in place. That might mean telehealth or some wraparound support to try to treat the patient in place and avoid a trip to the ER. 

3. Pediatric behavioral health patients have a very hard time finding placements in residential treatment, especially those with autism. She tries to work with the school district, the health plan, and state agencies to find placements or some support for the child living at home, since the wait for a bed can be six months to a year. 

4. For other difficult conditions, like traumatic brain injury, eating disorders, and autism, Cosgrove’s planning team casts a wider net, sometimes looking at out-of-state arrangements. She is working with the state to make it easier for patients admitted to the state hospital for civil commitments. This is the best option because SNFs often won’t take these patients. 

5. If you can’t discharge the patients, make sure you can at least get paid for them. Talk to the payor about a single case agreement.  

With staffing shortages across healthcare not likely to ease anytime soon, it’s important to be proactive and intentional about discharge planning. This starts the moment patients arrive in the ER and goes through all conversations with families and the care team.  

YouCompli sponsored MHA’s 2022 Healthcare Legal Compliance Forum. To access the full session recording, please contact the Massachusetts Health and Hospital Association.     

Recaps From The 2022 Massachusetts Health and Hospital Association’s Healthcare Legal Compliance Forum

• Federal and State Agencies Preview 2023 Enforcement Trends
• Compliance Officer Roundtable Looks at Burnout, Empathy, and Connecting Compliance to Patient Care

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Featured speakers: Eric Gold, Chief, Massachusetts Attorney General’s Office Healthcare Division; Jennifer Goldstein, Managing Attorney, Medicaid Fraud Division, Massachusetts Attorney General’s Office; and Steven Sharobem, Assistant US Attorney, District of Massachusetts. Moderated by David S. Schumacher, Healthcare Partner, Hooper, Lundy & Bookman. 

Gold, Goldstein, and Sharobem addressed the Massachusetts Health and Hospital Association’s Healthcare Legal Compliance forum in December 2022. This recap of their remarks looks at current enforcement priorities, their view on good faith efforts, opioids, and privacy. To access the full session recording, please contact the Massachusetts Health and Hospital Association.  

Focus Areas for the US Attorney’s Office in Massachusetts 

Sharobem said that two types of issues his team is actively investigating now are Stark Law violations and Turbocharging. 

He reminded the audience that Stark is strict liability and that intent isn’t considered.  

“Did it happen or did it not happen.”- Steven Sharobem, Assistant US Attorney, District of Massachusetts 

Physician compensation plans get looked at in this context. High volume and high value bonuses get extra scrutiny. He said this doesn’t mean something is actually incorrect, but they look more closely when the bonus is dependent on volume or hitting a certain operating margin.  

Good faith efforts can still help an organization in strict liability cases like Stark Law violations. There is an opportunity to work with the Office of the Investigator General (OIG) to determine how to resolve the matter sensibly. This is especially true when Covid has affected diligence in administration. His office considers and evaluates the circumstances when an organization cooperates.  

Turbocharging

Sharobem says his office is seeing more turbocharging recently. Turbocharging is the practice of increasing the costs they list on your charge masters to account for inflation. The government is watching these adjustments to make sure they are appropriate for federally reimbursed services. He suggests looking at your outlier payments to be sure they are warranted, and returning the money if they are not warranted.  

Finally, his office is giving more attention to 340b programs to ensure this low-income benefit is being used appropriately. They are also looking at speaker programs from drug makers to be sure there aren’t any antikickback violations. 

Priorities for Massachusetts’s Medicaid Fraud Division  

Goldstein and her team focus on provider fraud, waste and abuse allegations and claims of abuse and neglect in nursing facilities and home health setting. They also handle national whistleblower cases. 

One significant trend she has noticed is the illegal prescribing of opioids. Her office is investigating and prosecuting physicians who are overprescribing opioids and controlled substance without a legitimate medical purpose. Her team sees diversion of drugs in exchange money. One red flag is when a physician repeatedly writes a high volume of opioids despite major red flags for addiction and overdose risk.  

Goldstein’s office is also working to be sure nursing facilities are protecting residents from Covid. In one example, the team brought a civil complaint against Seaview Retreat for failing to implement basic Covid procedures. That includes failing to train staff, conduct surveillance testing, or to put residents in cohorts based on their Covid status. These failures resulted in patients contracting and in one instance dying of Covid-19.   

She echoed Sharobem in saying that cooperation and good faith efforts factor into her analysis of the severity of a matter- particularly in the midst of a once-in-a-lifetime event like a pandemic.  

Enforcement Priorities for Massachusetts Attorney General’s Office 

Gold leads an office of 20 staff, working on enforcement, policy, consumer advocacy, and assistance. He offers voluntary mediation to consumers, providers, and payers that have concerns about their bills. 

The office also provides community benefits and healthcare cost trend examinations. Their reports help hospitals and HMOs to plan for unmet needs in the community.  

In terms of law enforcement, he says he is charged with enforcing consumer protection law in the healthcare arena. If a healthcare provider or other entity is suspected of unfair practices, his office handles that. He doesn’t overlap with the other agencies on the panel or in the AG’s office, but he may work with them.  

For instance, he works with Massachusetts’ new Data Privacy and Security Division on healthcare data privacy cases. They investigated a home health company that was subject to repeated phishing attacks. Emails came to the employees asking them to click on links and provide information. Some employees complied, and hackers got a lot of patient information. Four thousand Massachusetts residents had their data comprised.  He said the company was aware that its cybersecurity needed improvement but hadn’t taken proper steps to secure its data. It didn’t have good enough training, it didn’t use multifactor authentication, and its systems failed to meet the standard for security. The institution paid a fine and was required to fix its cybersecurity protocols. 

YouCompli sponsored MHA’s 2022 Healthcare Legal Compliance Forum. Please contact the Massachusetts Health and Hospital Association to access the full session recording.

Recaps From The 2022 Massachusetts Health and Hospital Association’s Healthcare Legal Compliance Forum

• Critical Challenges in Discharging Patients
• Compliance Officer Roundtable Looks at Burnout, Empathy, and Connecting Compliance to Patient Care

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Subscribe to the YouCompli blog for enforcement updates and real-world insight on compliance officer effectiveness, regulatory change management, and the value compliance brings to an organization.    

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The post Federal and State Agencies Preview 2023 Enforcement Trends first appeared on YouCompli.

YouCompli is conducting research on how healthcare Compliance functions support the overall wellbeing of their organizations. As a seasoned healthcare compliance professional, your input will be invaluable in helping shape YouCompli’s inaugural report on the ways Compliance helps lessen organizational risk with exceptional regulatory change management. 

Take the survey 

The survey contains six multiple choice questions and some optional demographic information. It typically takes less than five minutes to complete. For every survey response received by March 7, 2022, we will donate $10 to the American Nurses Foundation’s Coronavirus Response Fund for Nurses. (So be sure to encourage your compliance colleagues to fill it out, too!) 

We will release the survey results at the 2022 HCCA Compliance Institute, where we are presenting the panel discussion, Reducing Healthcare Risk with Strong Reg Change Management. If you’d like to receive the survey results report, all you have to do is let us know in the survey. 

Thank you for providing your data and perspective. The YouCompli team appreciates your time and looks forward to sharing rich industry insight later this spring. 

Find out more about the American Nurses Foundation’s Coronavirus Response Fund for Nurses. We will donate $10 per response up to $2,000 for responses received by March 7, 2022. 

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Martie Ross, Office Managing Principal, PYA  

Ross addressed the Massachusetts Health and Hospital Association’s Healthcare Legal Compliance Forum in December 2021.  

Ross covered federal vaccine mandates, unwinding regulatory flexibilities, and Provider Relief Fund audits and enforcement. Her detailed slides are available from PYA here. They provide great insight for Compliance practitioners. 

Other things to watch in 2022: 

• Cybersecurity  
• Price Transparency  
• No Surprises Act (Related blog posts) 
• Information Blocking (Related blog posts) 
• HIPAA Privacy Rule updates  
• Health Care Fraud Self-Disclosure Protocol  
• Diagnosis coding  
• Physician compensation arrangements (Related blog posts) 
• E/M changes  
• Opioid prescribing practices 
• Compliance program operations 

While we don’t know when the public health emergency will end, it’s critical to have a plan in place to operate without the flexibilities that came with it. This includes:  

• Expanded capacity 
• Burden Relief 
• Provider enrollment relief 
• Stark Law waivers 
• HIPAA enforcement discretion 
• Patient inducement enforcement discretion 
• DEA waivers 
• Expanded telehealth coverage 

Ross recommends that you review and track changes to internal policies and practices, and establish a process to completely unwind. “As a compliance officer, it’s time to go back through your compliance documentation over the past two years and think about how you’re going to unwind from these changes,” she said. 

YouCompli sponsored MHA’s 2021 Healthcare Legal Compliance Forum in 2021. Current and former law enforcement officials, healthcare compliance practitioners, attorneys and consultants gave a broad view of the priorities, challenges and opportunities facing the Compliance profession. Read a summary of all the sessions. We provide a complete solution to help healthcare compliance organizations manage regulatory change. Find out more about YouCompli.  

Subscribe to get the latest articles about healthcare regulatory changes.

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Featured speakers: Marcus Hughes, Associate General Counsel, UMass Memorial Health; Meg Cosgrove, Associate General Counsel, Beth Israel Lahey Health. Moderated by Jeremy Sherer, Healthcare Attorney, Hooper, Lundy, & Bookman 

Hughes and Cosgrove addressed the Massachusetts Health and Hospital Association’s Healthcare Legal Compliance Forum in December 2021. This recap of their remarks looks at how they worked with providers to stay in compliance as demand for telehealth surged with the Pandemic. It also looks at how they are preparing for the regulatory changes that will come with the end of the public health emergency.  

Interstate licensing for telehealth

Hughes said his advice on interstate licensing for telehealth has evolved as states rescinded their waivers. “As we move toward the late stage of the pandemic, we’re more cautious and want providers to follow pre-pandemic rules. This might mean that they need a license in the states where the patients are located.” He asks providers to work with Compliance and the General Counsel’s office to assess the risk.  

“We’re now more informed by the risk we’re seeing in enforcement and compliance actions,” Cosgrove said. Her providers care for a lot of college students and snowbirds who look to them for prescription refills and ongoing care when they’re away from home. “This is such a cultural shift for our providers- they want to be responsive to long-established patients, and things they might have done in the past need to be looked at more closely now.” She noted that there is a difference in risk between refilling a blood sugar medication for a long-established patient who’s in Florida for four weeks versus giving the same medication to a new patient who’s away for six months and has a new blood sugar concern. The challenge is providing clear guidance: “Doctors want clean lines, but as a legal practitioner it’s very difficult to provide that because so much depends on the situation,” she said. 

Resource constraints and bright lines

Ultimately, Cosgrove’s organization drew a bright line around specific states. “We support out of state telehealth in Florida and New Hampshire because that’s what we can sustain and do effectively, and it’s where many of our patients go.” 

It was a huge shift for the providers, but the key to making it work was involving providers in the decision making. “We had amazing medical directors and clinicians who could inform our approach,” she said. “They helped us look at highly clinical scenarios and draw the bright lines.”  

Hughes also has to help providers balance their desire to help their patients with the realities of interstate licensing. “It’s a huge risk to a provider to be found to be practicing across state lines unauthorized. They risk their license as well as their medical staff appointment at the hospital and other affiliations.”  

He noted that there is a common belief that there is a national framework for remote care, but there isn’t. “Now that we’re in the late stage of the pandemic, we have to educate our staff to dispel some of the myths that are out there. And we have to make sure they know that the COIVD waivers are coming to an end.”  

Going forward

Cosgrove noted that it difficult to settle on a long-term strategy because we still have the flexibility that comes with the federal PHE. Still, she’s dealing with evolving state waivers while the federal PHE is still in effect. She’s also getting ready for enforcement actions with audits. And her organization is working to influence Massachusetts to join the interstate medical licensing and nursing compacts.  

“I’m glad we can keep audio only telehealth, so we don’t exacerbate equity and access issues,” she said. Still, the reimbursement landscape will affect their offerings long term. “Where does telehealth fit into our model if Medicare is reimbursing only 50 percent or less for the telehealth visit?” 

Still, Hughes’s biggest takeaway from the past two years is that “whatever states we’re in now, telehealth is not going away.” Whether for outpatient monitoring, behavioral health or specialist follow ups, he expects to see telehealth continuing to grow.  

YouCompli sponsored MHA’s 2021 Healthcare Legal Compliance Forum in 2021. Current and former law enforcement officials, healthcare compliance practitioners, attorneys and consultants gave a broad view of the priorities, challenges and opportunities facing the Compliance profession. Read a summary of all the sessions. To access the full session recording, please contact the Massachusetts Health and Hospital Association. 

Find out more about YouCompli.  

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The post Healthcare GCs look at telehealth compliance in the Pandemic and beyond first appeared on YouCompli.

Featured speakers: Craig Bennett, Vice President and Chief Compliance Officer, Boston Medical Center; Rachel Lerner, Esq., General Counsel & Chief Compliance Officer, Director, Center for the Prevention of Elder Abuse and Neglect, Hebrew SeniorLife; Maria Palumbo, Chief Compliance & Privacy Officer, Lawrence General Hospital. Moderated by Larry Vernaglia 

Bennett, Lerner and Palumbo addressed the Massachusetts Health and Hospital Association’s Healthcare Legal Compliance Forum in December 2021. (Read a summary.) This recap of their remarks looks at how their Compliance teams responded to COVID and have continued to partner with their organizations to manage regulatory change. It also looks at regulatory changes they are planning for in 2022. To access the full session recording, please contact the Massachusetts Health and Hospital Association.  

Initial COVID response

The panel reflected on their organizations’ initial response to COVID. “All of us had to pivot on a dime,” said Bennett. “We hadn’t had an opportunity to plan for it. Instead, we worked daily that first quarter to make sure we were as compliant as we could possibly be.” He was part of a team that looked at various waivers, platform security, privacy and other issues affected by the public health emergency to provide care safely.  

Lerner had a similar experience. “We immediately convened interdisciplinary committee so we could make changes quickly. Telehealth was really new territory for us, and we had to look at our outpatient medical practice, and home- and community-based care,” she said. “Tracking COVID 19 waivers was a team sport between Legal and Compliance. We broke down some silos, and that may be one good lasting benefit of this experience.”  

Palumbo and her colleagues focused on creating templates and consistency for documentation to make things as straightforward as possible for clinicians. That included having them track their patient contact time in minutes rather than defaulting to 20-minute increments. “We’re auditing these processes now to be sure we’re prepared when it gets looked at externally.”  

Accessibility concerns and solutions

Palumbo illustrated how healthcare organizations had to respond to the specific needs of their communities. “Our population tends not to have computers or printers at home,” she said. It wasn’t enough to deliver COVID test results to the portal, because people needed printed results to return to work or school. Without a printer, they were stuck. “We were like the take-out line at a restaurant – we not only have to contract with the state to provide nine-lane testing, we also have a multiline drive up for picking up your covid test results because people need that hard paper.”  

Building a culture of compliance

Bennett reflected on the tremendous amount of change and adaptation healthcare staff managed over the past two years. “I have to commend all hospital staff in being able to pivot and not missing a beat,” he said. His organization paused or reprioritized certain issues, but they maintained a focus on complying with regulations. That meant checking in with people regularly. That helped him assess whether people were getting the support and resources they needed related to their work. He expects to continue looking for ways to support staff. “We’ll continue to try to add flexibility to meet the needs of our staff and the needs of our patients and organization.” 

Palumbo, too, is working to meet people where they are at. She recently “camped out in the cafeteria,” she said. “I couldn’t believe the results: About 350 people came to talk to me, including residents, physicians, surgeons, nurses, case managers, and housekeeping staff.” They asked about patient privacy and other compliance issues. “So much came up during COVID but we didn’t stop to work through everything or stop to talk to each other. I’ll try to do that at least once a quarter.”  

New compliance issues

Palumbo walked through some upcoming regulatory changes she’s watching. This included the Medicare Final Physician Fee Schedule and noted that the Appropriate Use Criteria changes are delayed until the January first that follows the end of the pandemic. She encouraged everyone to understand the documentation requirements for using nurse practitioners for some portion of care as well as the changes to billing for surgeon and ICU provider time.  

New rules also allow audio-only telehealth visits for behavioral health as long as the patient wants it and the physician documents it properly.  

Balancing privacy, efficiency, safety, and cybersecurity

Lerner continues to address privacy concerns related to COVID testing and contact tracing. “We were working so hard to limit the spread of the disease in our senior living facilities,” she said. “It was hard to navigate contact tracing and privacy.” Now she is addressing cybersecurity insurance requirements, for her own organization and making sure vendors have sufficient insurance. “Moving to remote workforces and telehealth, the cybersecurity exposure is higher than it’s ever been,” she said. “For instance, people working from home might want to print documents, but we have to keep them from printing PHI at home or mailing things insecurely when someone can’t come pick it up.”  

Managing regulatory change

Lerner said she spends a lot of time looking at regulatory changes to understand their implications to her organization. “It can take us a long time to decide ‘does this apply to us?’ And then figure out what to do with it. Then we have to figure out what to do with that information in bits and pieces. It is certainly a complex, ever-changing universe on that front.” She spoke of Compliance’s key role in knitting together all that information to help the organization act on it and integrate it into daily processes.  

YouCompli sponsored MHA’s 2021 Healthcare Legal Compliance Forum. We provide a complete solution to help healthcare compliance organizations manage regulatory change. Find out more about YouCompli.  

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The Massachusetts Health and Hospital Association recently convened its Healthcare Legal Compliance Forum to update members on key areas of regulatory change, compliance and enforcement in this late COVID era. 

Current and former law enforcement officials, healthcare compliance practitioners, attorneys and consultants gave a broad view of the priorities, challenges and opportunities facing the Compliance profession.  

Federal and State Enforcement Update 

Featured speakers: Toby R. Unger, Chief of Medicaid Fraud Division, Office of the Massachusetts Attorney General; and Patrick Callahan, Healthcare Fraud Unit, US Attorney’s Office. Moderated by David Schumacher, Partner, Hooper, Lundy & Bookman. 

Unger and Callahan noted that the pandemic shifted the makeup of their case load. It reduced the rate of whistleblower and other fraud complaints, and for Unger at least, abuse cases increased.  

They talked about how health organizations can effectively partner with law enforcement. They generally see the best outcomes when Compliance and Legal teams bring issues to them or work quickly with them to find data and resolve issues. 

And they shared their take on effective Compliance functions. A good Compliance department doesn’t need to be huge with a lot of people and formal processes,” Callahan said. “A good department is one that has a real effect when they ask leadership to make a change. They have a voice that gets leadership’s attention, and they can have questionable practices stopped during an investigation. When they ask to press pause, they are listened to.”  

Read More: State and Federal enforcement agencies anticipating more complex investigations as COVID-era practices emerge

Compliance Officer Roundtable  

Featured speakers:  Craig Bennett, Vice President and Chief Compliance Officer, Boston Medical Center; Rachel Lerner, Esq., General Counsel & Chief Compliance Officer, Director, Center for the Prevention of Elder Abuse and Neglect, Hebrew SeniorLife; Maria Palumbo, Chief Compliance & Privacy Officer, Lawrence General Hospital. Moderated by Larry Vernaglia. 

Bennett, Lerner, and Palumbo shared their experience over nearly two years of pandemic-influenced healthcare compliance. They talked about how they collaborated to manage regulatory change and reinforce their culture of compliance. They also talked about the regulatory changes they are planning for in 2022.  

Lerner said she spends a lot of time looking at regulatory changes to understand their implications to her organization. “It can take us a long time to decide ‘does this apply to us?’ And then figure out what to do with it. Then we have to figure out what to do with that information in bits and pieces. It is certainly a complex, ever-changing universe on that front.” She spoke of Compliance’s key role in knitting together all that information to help the organization act correctly and then integrate it into daily processes. 

Read More: Compliance officers reflect on COVID pivots and preparing for the end of the public health emergency

Telehealth in the Pandemic and Beyond  

Featured speakers: Marcus Hughes, Associate General Counsel, UMass Memorial Health; Meg Cosgrove, Associate General Counsel, Beth Israel Lahey Health. And moderated by Jeremy Sherer, Healthcare Attorney, Hooper, Lundy, & Bookman. 

Hughes and Cosgrove discussed interstate telehealth compliance issues. They talked about the hard adjustments providers have to make as demand for telehealth surges and scrutiny of out-of-state practice increases. They shared ways they are preparing for the regulatory changes that will come with the end of the public health emergency.  

As waivers expire, Compliance officers have to increase their efforts at making sure providers understand licensing requirements and the risk of non-compliance. 

Hughes noted that there is a common belief that there is a national framework for remote care, but actually there isn’t. “Now that we’re in the late stage of the pandemic, we have to educate our staff to dispel some of the myths that are out there. And we have to make sure they know that the COIVD waivers are coming to an end.”  

Read More: Healthcare GCs look at telehealth compliance in the Pandemic and beyond

COVID-19 Hot Compliance Topics  

Featured speaker: Martie Ross, Office Managing Principal, PYA  

Ross covered federal vaccine mandates. unwinding regulatory flexibilities, and provider relief fund audits and enforcement. Her detailed slides are available from PYA here. They provide great insight for Compliance practitioners. 

Ross recommends that you review and track changes to internal policies and practices and establish a process to completely unwind. “As a compliance officer, it’s time to back through your compliance documentation over the past two years and think about how you’re going to unwind from these changes,” she said. 

Read More: Compliance expert Martie Ross explains critical regulatory change management issues facing healthcare in 2022

YouCompli sponsored MHA’s 2021 Healthcare Legal Compliance Forum. We provide a complete solution to help healthcare compliance organizations manage regulatory change. Find out more about YouCompli.  

Subscribe to get the latest articles about healthcare regulatory changes.

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