About the Medical Necessity Series 

This is the third in our series of articles on medical necessity. In the first, we described the compliance risks associated with submission of claims for medically unnecessary services.   

In the second, we highlighted a case where an organization of long-term care hospitals were alleged to have violated the Federal False Claims Act (FCA) for holding patients in the hospital longer than medically necessary to increase reimbursement from Medicare. 

In this next article, we spotlight another recent example of a healthcare provider entity agreeing to pay a six-figure sum to resolve allegations of submission of claims for medically unnecessary services¹.  This time, the providers consisted of three affiliated skilled nursing facilities (SNF) that were alleged to have submitted claims for medically unnecessary rehabilitation services.   

False Claims Act Metrics Make Significance Clear 

The Department of Justice has reported that False Claims Act settlements and judgments reached $6.8 billion in Fiscal Year 2025. Over $5.7 billion of that total was derived entirely from the healthcare sector. Most of these healthcare recoveries stem from whistleblower lawsuits targeting corporate billing schemes, upcoding, and medically unnecessary services. 

Case Involves SNF Reimbursement Dispute Over Therapy Services 

For the period in question, skilled nursing facilities (SNFs) were reimbursed for therapy services based on a patient’s resource utilization group (RUG). The RUG was determined by the amount of services the patient received, such as: 

•  Physical therapy 
• Occupational therapy  
• Speech pathology services 

In short, the more services provided, the higher the reimbursement.  However, as discussed in our two prior articles, if the services don’t meet medical necessity requirements, they should not have been performed or billed in the first place. 

Whistleblower Lawsuit Triggers Investigation 

As is frequently the case, these allegations were first brought forth through a qui tam, or whistleblower, lawsuit. The whistleblower, or relator, claimed the defendants implemented a five-pronged scheme to fraudulently bill for unnecessary “Ultra High Rehab,” (the most intensive therapy provided by SNFs) and to keep patients in Ultra High Rehab for longer than necessary. 

The five prongs of the alleged scheme were: 

1. Pressure to perform excessive, unnecessary services: The organization’s leadership exerted pressure on therapy staff to administer excessive Ultra High Rehab and to do so for longer than necessary.   

This pressure was exerted not only by administrators who oversaw SNF operations, but also by regional directors of operations who managed the facility administrators. Such pressure was also exerted by directors of rehab (DOR) who managed therapists at each facility, and regional managers who directly managed the DORs.  

In other words, management, from top to bottom, spoke to therapists and staff in one voice: increase Ultra High Rehab, regardless of patient need. 

2. Financial vs. medical reasons to provide care:  Instead of letting therapists determine the appropriate level of therapy needed based on their professional evaluation, leadership insisted that each patient’s level of therapy be at least in part determined by whether the patient qualified for lucrative Medicare Part A benefits. 

3. Care for functional patients: The organizations pressured therapists to continue providing therapy to patients who were fully functional and in no way required intensive therapy. A scheme called “Bridge to Success” was employed which mandated an additional week of Ultra High Rehab be tacked on even after patients were ready for discharge. 

4. Too sick for care: The organizations pressured therapists to provide therapy to patients who were too sick to benefit from therapy and even to patients who were actually harmed by it.  

Since therapy minutes were dictated by management and not assigned based on the professional opinion of evaluating therapists, patients ended up receiving more therapy than they could tolerate, including instances where therapy was forced on patients about to pass away. 

5. Maximizing minutes: The focus on maximizing therapy minutes to hit therapy goals also resulted in leadership encouraging an array of fraudulent billing practices. 

This included: 

• Billing non-therapeutic minutes as therapy  
• Allowing therapists to bill for therapy without actually providing it 
• Encouraging therapists to bill evaluation sessions as therapy. 

Widespread Occurrences Involve $14.6+ Billion in Alleged Intended Losses 

Federal enforcement actions emphasize the commonality of these practices. The 2025 National Health Care Fraud Takedown alone resulted in criminal charges against 324 defendants nationwide, involving over $14.6 billion in alleged intended losses tied to fraudulent billing and medical necessity abuses. 

The most compelling argument for compliance leaders is that medical necessity fraud carries dual liability: 

• Financial Risk: Organizations face mandatory treble damages (three times the government’s actual loss) plus steep statutory penalties for every individual false claim submitted. 
• Human Risk: Unlike administrative billing errors, medical necessity fraud directly compromises patient care. Overutilization exposes vulnerable patients to unnecessary, exhausting or potentially harmful procedures simply to satisfy corporate revenue targets. 

Three Takeaways from Medical Necessity Cases 

Much can be learned from the themes of these allegations, even if your organization isn’t an SNF or doesn’t provide therapy services. Medical necessity requirements are common across most healthcare organizations. 

Key lessons from this case include: 

1. Decisions about billing for medical care provided need to be based on clinical and regulatory requirements, especially coverage requirements from Medicare and Medicaid, for example.   Such requirements often include statutes about: 

• Medicare coverage 
• Medicare manuals 
• National Coverage Determinations  
• Regional Medicare Administrative Contractors’ Local Coverage Determinations (LCD)  

2. Regular, focused compliance coding and billing audits may identify aberrant practices. This is especially true for services whose corresponding medical documentation doesn’t support compliance with coding or billing rules.   
    
   For example, Medicare reimbursement rules state that routine, non-skilled services aren’t separately reimbursable. In this case, it was alleged that one therapy assistant was coached to include in therapy minutes the time it took him to arrive at a patient’s room starting with the moment he left the therapy department. 
    

3. Use data analytics to identify outliers. Most whistleblower cases alleging medically unnecessary services are brought by an individual with knowledge from inside the organization. Many times, the individual is a physician, nurse or other clinician with medical expertise.   
    
   This case was different. It was filed by a private analytics firm using publicly available data. Though rare, these cases do exist. If a private firm using public data could find the alleged aberrations, one would hope the organization’s own compliance professionals would be able to find similar aberrations if given the resources to look.  Additionally, the government is using data analytics to identify cases they want to pursue as well. 

Apply These Takeaways to Your Own Regulatory Compliance Program 

False Claims Act allegations alleging a lack of medical necessity can take many forms. The kind of service or type of provider may also vary, but these key themes appear in many cases. The astute compliance professional will learn from them and apply the principles to the operations and services provided at their own healthcare organization. 

The claims resolved by the settlement are allegations only, and there has been no determination of liability. 

The post Lessons from the Frontlines: A Case Study in Medical Necessity Enforcement  first appeared on YouCompli.

Ensuring medical necessity for services or supplies isn’t just about getting paid. It’s a safeguard against unnecessary or duplicative services that increase the risk of patient harm or medical errors. That’s reason enough for this to be an important topic for compliance leaders. 

This is the first article in a series on medical necessity — an area that many compliance programs struggle with. In this piece, we explain the medical necessity compliance risk in general, while subsequent articles highlight specific examples of enforcement actions experienced by medical providers such as hospitals and health systems. 

Impact of Denial Rates and Medical Necessity on Payer Costs  

Data suggests that medical necessity is becoming a primary way for payers to manage costs, making it even more worthy of leadership attention. The “State of Claims 2025” Report found that 54% of providers agree claim denials are increasing faster than they can appeal. 

A data accuracy gap also contributes to the problem. Roughly 41% of healthcare organizations report at least 1 in 10 claims is denied, often due to “bad data” at intake or lack of clinical justification. 

All of this creates further justification for the need to better understand medical necessity from a compliance standpoint. 

Role of Clinician Review in Determining Medical Necessity 

Medical necessity isn’t an easy compliance risk to tackle, especially when OIG recommendations bump up against front-line reality. Sometimes, clinicians view medical necessity as their bailiwick.   

Of course, their expertise is the basis for medical decision making. Generally speaking, clinicians are making their decisions based on what they believe is medically necessary. They are the clinically trained professionals and should know when something is medically necessary or not, right?  

However, from a compliance standpoint, medical necessity often really means “covered” by a third-party payor. If something is considered “not medically necessary,” it may actually mean it does not meet payor coverage requirements. 

OIG on Clinical Review of Medical Necessity in Claims Audits 

In their General Compliance Program Guidance document (GCPG), the Department of Health and Human Services (HHS) Office of Inspector General (OIG) emphasized the importance of ensuring claims submitted to government payors are medically necessary. 

Specifically, they note:  

“Medicare requires, as a condition of payment, that items and services be medically reasonable and necessary. Therefore, entities should ensure that any claims reviews and audits include a review of the medical necessity of the item or service by an appropriately credentialed clinician. Entities that do not include clinical review of medical necessity in their claims audits may fail to identify important compliance concerns relating to medical necessity.” 

Considerations for Compliance Risks in NCD and LCD 

Other entities have also emphasized medical necessity as coverage criteria. For example, Medicare publishes National Coverage Determinations (NCDs) and Local Coverage Determinations (LCDs). These are, in essence, coverage criteria for a specific service.  

Though generally accepted medical guidelines or medical practice may suggest a certain treatment plan is appropriate, the LCD might not cover the service for a particular condition or diagnosis or might not allow the service at a particular cadence or frequency. 

Example: Meeting LCDs for Pain Injection Procedures 

LCDs addressing pain injection procedures are a good example of this. A Medicare LCD might state that before Medicare considers a spinal injection “medically necessary” (think “covered”), the patient needs to have failed four months of conservative therapy (e.g., lifestyle changes, physical therapy, etc.)   

Or the LCD might state a total of four injections in a twelve-month period is the maximum number of injections they will allow. Additionally, an LCD might require that a patient has a certain condition (represented by an ICD-10 or diagnosis code i.e., diagnosis code) before considering a service covered.   

There is potential compliance risk in all these areas if coverage criteria are not met and documented in the medical record or if codes are reported to ensure coverage, but the medical record does not support the diagnosis code reported. 

Overlap with Patient Safety 

Medical necessity can also overlap with patient safety issues. If a physician exaggerates the severity of a condition to make it look like the services should be covered, a patient could undergo a procedure that was not appropriate or medically necessary to perform in the first place.  

This raises patient safety issues for subjecting a patient to certain risks when the service does not appropriately meet clinical standards or indications for performance. 

How Medical Necessity Compliance Is Enforced 

The government utilizes various tools for enforcing medical necessity compliance.  These include the False Claims Act (FCA), typically used by the U.S. Department of Justice (DOJ), and the Civil Monetary Penalties Law (CMPL) utilized by the OIG. 

The DOJ can investigate allegations of medically unnecessary services when credible information is brought to its attention by whistleblowers (qui tam relators). A qui tam relator is a private individual or entity who files a lawsuit on behalf of the government under the FCA against companies or individuals committing fraud. Or the DOJ can investigate on their own, typically because of data analytics they proactively perform. 

How OIG Pursues Financial Penalties and Program Exclusion 

The OIG is authorized to pursue monetary penalties and exclusion through a variety of civil authorities, most notably the CMPL. Under the CMPL, OIG can seek assessments in lieu of damages, Civil Monetary Penalties (CMP), and exclusion from participation in federal health care programs.   

According to the OIG, one example of conduct that could lead to CMP liability is presenting a claim for a pattern of medical or other items or services that a person knows or should know are not medically necessary. 

Medical Necessity Risk Tied to Clinical Services 

There isn’t a one-size-fits-all risk profile when it comes to medical necessity. Each organization’s risk is going to be tied to the clinical services it offers or orders. Organizations and their compliance programs should undertake risk assessments tailored to their particular situation.  

Via the GCPG document, the OIG recommends that when conducting risk assessments, organizations should “ensure that medical necessity, patient safety, and other quality compliance issues are included in the risk universe.” 

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Coming Articles: Details of Recent Enforcement Actions 

In subsequent articles in this series, we’ll take a closer look at the details of recent enforcement actions involving allegations that submitted claims lacked medical necessity. This information will help compliance leaders stay on top of situations and reduce risks in their own organizations.  

Read Part Two Here

About the Author 

CJ Wolf, MD, M.Ed. is a healthcare compliance professional with over 27 years of experience in healthcare economics, revenue cycle, coding, billing, and healthcare compliance. He has worked for Intermountain Healthcare, the University of Texas MD Anderson Cancer Center, the University of Texas System, an international medical device company and a healthcare compliance software start up. Currently, Dr. Wolf teaches and provides private healthcare compliance and coding consulting services as well as training.   

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The post Medical Necessity: A Guide for Healthcare Compliance Leaders  first appeared on YouCompli.

A good healthcare compliance program is all about reducing risk, both in patient care and in financial reimbursement. This detailed blog by compliance expert, CJ Wolf, will bring you up to date on the compliance risks associated with certain anesthesia services.   

The OIG just published audit results and report (July 31, 2025) outlining the issues in this area. This article is a summary of that report, along with what it might mean for compliance professionals.  

The implications can be huge. For example, OIG concluded that Medicare paid $45.7 million for anesthesia services provided during the SPM procedure sessions that were at risk for noncompliance with Medicare requirements.  

What to Know About Anesthesia, Compliance and the Latest OIG Audit 

The U.S. Department of Health and Human Services Office of Inspector General (OIG) recently released a nationwide audit report highlighting potential improper payments for anesthesia services provided during select spinal injection procedures  

It is only under rare circumstances that Medicare Part B covers the cost of anesthesia during certain spinal pain management (SPM) procedures. In fact, a prior OIG audit found that 27% of billed anesthesia services during SPM procedures did not have supporting medical documentation that would justify the use of anesthesia.  Given these circumstances, the OIG decided to perform the more recent nationwide audit and publish its findings. 

Goal of OIG Audit Regarding Medicare Part B Payments 

The OIG’s goal in the audit was to identify Medicare Part B payments to physicians for anesthesia administered during selected SPM procedures that were at risk for noncompliance with Medicare requirements. 

The specific SPM procedures included in the audit were: 

• Facet-joint injections 
• Facet-joint denervation (aka radiofrequency ablation) 
• Epidural steroid injections 
• Sacroiliac joint injections 

Medicare Coverage Only in Rare Circumstances 

As mentioned, it is only in rare circumstances that Medicare covers the cost of certain anesthesia services provided during SPM procedures. The types of anesthesia services that could potentially be covered under these rare circumstances include: 

• Moderate sedation: Administration of a drug-induced depression of consciousness during which a patient responds purposefully to verbal commands, either alone or accompanied by light tactile stimulation. No interventions are required to maintain the enrollee’s airway, and spontaneous ventilation is adequate. 

• General anesthesia: Administration of a drug-induced loss of consciousness during which a patient is not arousable, even by painful stimulation. The ability to independently maintain breathing is often impaired. The patient often requires assistance in maintaining an open airway that allows for adequate airflow and proper oxygenation of the lungs. Positive pressure ventilation may be required because of depressed spontaneous ventilation or drug-induced depression of neuromuscular function. 

• Monitored anesthesia care: This is a specific anesthesia service for a diagnostic or therapeutic procedure. Indications for monitored anesthesia care include the need for deeper levels of analgesia (i.e., the inability to feel pain) and sedation than can be provided by moderate sedation. Monitored anesthesia care falls between moderate sedation and general anesthesia. 

MAC LCDs Published for Select SPM Procedures 

Medicare Part B claims are adjudicated and paid by Medicare Administrative Contractors (MAC).  MACs are charged with ensuring proper payment of claims.  They are to safeguard Medicare funds against improper medical coding and billing, fraud and abuse. One way they do this is by publishing local coverage determinations (LCDs) which outline when certain services are, or are not, covered. 

The MAC LCDs for the selected SPM procedures explain that the use of moderate sedation, general anesthesia, and monitored anesthesia care is usually unnecessary or rarely indicated for these procedures. However, individual consideration may be given in rare cases when documentation clearly established the need for such anesthesia. 

Audit to Confirm Compliance with Limited Coverage Rules 

The OIG wanted to confirm compliance with these limited coverage rules for anesthesia services billed along with the SPM procedures. To do so, they identified an audit period consisting of claims for SPM procedure dates of service between May 2, 2021, and August 31, 2023, during which Medicare paid for 3.9 million sessions of SPM procedures.   

For this audit period, physicians billed for anesthesia services nearly 18% of the time. The MACs paid $46.2 million for the anesthesia services or 99.5% of the time that anesthesia was billed during the same SPM procedure session. 

Then, the OIG identified and selected a nonstatistical sample of 28 sessions where both anesthesia and the selected SPM procedures were billed. To verify compliance, the OIG obtained the supporting medical documentation for these sessions and had an independent medical reviewer determine whether the anesthesia was medically necessary and met the rare circumstances when Medicare would cover the anesthesia service.  

Medical Records Fail to Document Necessity 

For 20 of the 28 sampled sessions, the medical reviewer determined the supporting medical records did not document a rare circumstance in which administering anesthesia was reasonable or necessary for the specific SPM procedure.   

One such example included a session where a physician administered moderate sedation to a patient during an epidural steroid injection session. The medical records provided by the physician stated that this type of anesthesia was administered because of the patient’s anxiety, which is not a medically necessary indication meeting coverage criteria according to the LCD. The medical records also did not have evidence of failed oral sedation, which could have necessitated moderate sedation. 

The OIG stated they could not provide an overall estimate of improper payments for the entire audit period because the sample they used was a nonstatistical sample. However, they concluded that Medicare paid $45.7 million for anesthesia services provided during the SPM procedure sessions that were at risk for noncompliance with Medicare requirements. 

OIG Recommendations Include Provider Education 

One of the more significant recommendations the OIG made for CMS and the MACs is to  

• Educate providers on the coverage criteria 
• Review claims for improper billing of anesthesia services 

For providers, this means your MAC may begin auditing such claims. 

Compliance Tip for Anesthesia Billing 

Compliance professionals should assess how often their organizations bill anesthesia services at the same time as the SPM procedures and review the medical records to determine if the sessions meet the rare circumstances found in the LCD requirements for coverage of both services. 

More Resources about Compliance Risks 

Continue learning about the complexities of Medicare reimbursement and compliance in these other piece by CJ Wolf. 

Compliance Risks Associated with Outlier Payments 

In some circumstances, payers like Medicare, for example, will reimburse additional amounts beyond the prospective payment rate. These additional payments are called “outlier payments.” Outlier payments provide additional reimbursement for cases of exceptionally costly treatments.   

How to Avoid Compliance Risk in Peripheral Vascular Reimbursement   

Peripheral vascular disease (PVD) reimbursement is fraught with potential compliance pitfalls. This expert-written blog addresses the pressing concern of compliance risks in PVD reimbursement. It provides insights into regulatory trends, recent investigations and best practices. It provides insights into regulatory trends, recent investigations and best practices. 

CJ Wolf, MD, M.Ed. is a healthcare compliance professional with over 22 years of experience in healthcare economics, revenue cycle, coding, billing, and healthcare compliance. He has worked for Intermountain Healthcare, the University of Texas MD Anderson Cancer Center, the University of Texas System, an international medical device company and a healthcare compliance software start up. Currently, Dr. Wolf teaches and provides private healthcare compliance and coding consulting services as well as training.   

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Sign-up for our Weekly Newsletter

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The post Know the Compliance Risk for Certain Anesthesia Services  first appeared on YouCompli.

Nowadays, rarely does a week go by without the Department of Justice announcing another settlement related to allegations of a lack of medical necessity resulting in false claims. It’s a significant black eye for the healthcare compliance industry – one that compliance professionals should constantly be working to avoid.  

As they do so, they should keep the following tips in mind as they assess and monitor the medical necessity of claims. 

Tip #1 – Insurance Coverage 

When speaking with clinicians, make sure to clarify that medical necessity billing risks are not necessarily an attempt to second-guess a clinician’s decision for care, but rather an insurance coverage issue. For example, “the OIG recognizes that physicians should be able to order any tests, including screening tests, they believe are appropriate for the treatment of their patients. However, a physician practice should be aware that Medicare will only pay for services that meet the Medicare definition of reasonable and necessary.”¹ 

Too often, compliance professionals lead the conversation with a statement that “the services were not medically necessary.” Instead, they could say, “the services did not meet Medicare’s definition of medical necessity or coverage.” 

Tip #2 – LCDs and NCDs 

Help revenue cycle professionals and clinicians become aware of the local Medicare Administrative Contractor’s (MAC) local coverage determinations (LCD) and Medicare’s national coverage determinations (NCD). These policies outline coverage criteria for specific services identified by medical codes. In many LCDs, there are narrative descriptions of expectations before Medicare considers the services medically necessary.  For example, one MAC’s LCD for spinal facet joint injections requires documented failure of attempts for conservative therapy to treat the patient’s pain before performing spinal injections. Specifically, it states the medical record of the patient must demonstrate “pain present for minimum of 3 months with documented failure to respond to noninvasive conservative management (as tolerated).” So, clinicians who order or perform facet joint injections run the risk of the claims being “medically unnecessary” or not covered under the LCD. Other LCDs also have similar narrative descriptions outlining expectations for coverage, or for what the local MAC considers to be “medically necessary.” 

Tip #3 – Maximize Clinical Training 

Auditing and monitoring for medical necessity can be a challenge because many compliance programs do not employ individuals with medical training. These people are usually in the best position to determine whether the services meet medical necessity requirements. Most compliance programs do, however, ensure that medical claims submitted to payors are audited and/or monitored by certified medical coders who assess whether the codes reported are supported by the medical documentation.  

Still, most medical coders are not clinically trained, nor do they usually perform medical necessity reviews when they are performing coding audits. With this in mind, compliance programs should involve individuals with at least some clinical training to perform auditing and monitoring with an eye on medical necessity. It does not always need to be a clinical specialist involved at the beginning of an audit or monitoring procedure. Such individuals with basic clinical training can screen claims for medical necessity, and if/when a more formal opinion is needed they can then engage clinicians who have specialized training in a particular treatment or procedure.  

Conclusion 

There is no silver bullet to solving medical necessity risks as they relate to medical claims submitted to payers such as Medicare. That said, these tips can be a starting point for compliance programs who know they need to minimize their compliance risk around medical necessity. 

Download CJ’s tip sheet below

CJ Wolf, MD, M.Ed. is a healthcare compliance professional with over 22 years of experience in healthcare economics, revenue cycle, coding, billing, and healthcare compliance. He has worked for Intermountain Healthcare, the University of Texas MD Anderson Cancer Center, the University of Texas System, an international medical device company and a healthcare compliance software start up. Currently, Dr. Wolf teaches and provides private healthcare compliance and coding consulting services as well as training.  

Qualified compliance professionals do the heavy lifting for you, simplifying regulatory change management   

Our in-house team works tirelessly to monitor U.S. regulators, carefully read the regulations in their entirety, and translate the information into simple regulatory intelligence you can use. We deliver model procedures and expert tools that can be used to fulfill your business requirements. Everything is validated by a third-party law firm. Follow the button below to get a tour of our healthcare compliance software.  

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The post How to Avoid False Claims Related to Medical Necessity   first appeared on YouCompli.

YouCompli, the leading provider of SaaS healthcare compliance solutions, today announced that its flagship platform is now available for use by the payer side of healthcare organizations. YouCompli is the only healthcare compliance solution in the market combining actionable regulatory analysis with a simple SaaS workflow. This one-two punch of intelligence and technology protects the whole organization and puts compliance officers at ease.  

“Compliance functions on the payer side of healthcare organizations remain challenged with increased rulemaking and regulations from state and federal regulators requiring new and innovate ways to proactively and efficiently support managing risk for their organizations,” said Jenny O’Brien, president of BlackBridge Advisors. “Now, with YouCompli, they can intake and aggregate the information they need the most, determine how it affects their organization and easily manage through whatever change and implementation processes are necessary. It ensures consistency around the process, helps promotes revenue generation and ultimately results in more effective and efficient processes to mitigate risk.” 

Despite often having limited resources at their disposal, payer-side compliance teams play a major role in mitigating their organization’s risk of audits, fines, disruptions and reputational damage. They must effectively:  

• Be aware of, and monitor, changes in regulations from a variety of sources  
• Keep track of operational guidance documents, such as HPMS memos from CMS  
• Determine the applicability of new/updated/revised regulations and guidance documents to their organization  
• Decide how operations across the organization need to evolve to comply with those regulatory changes  
• Project manage those organizational change plans, and ensure any necessary system updates occur in a timely fashion  
• Keep records of all actions, so they can prove compliance if/when audited 

These compliance teams have traditionally had to do as much of this work as they could manually. Not anymore. 

“Take it from our rapidly growing customer base – YouCompli creates value and simplifies compliance for providers and payers at healthcare organizations nationwide,” said Jerry Shafran, founder and CEO of YouCompli. “From one pane of glass, users can monitor new or revised regulations, determine their applicability to their organizations, implement legally validated workflows, assign tasks to their colleagues and have a paper trail of everything.” 

About YouCompli 

Founded in 2016, YouCompli offers the only healthcare compliance solution combining actionable, regulatory analysis, and a simple SaaS workflow. Its compliance experts distill the complex regulatory changes issued by every healthcare regulator into straightforward action plans validated by Horty Springer, the nation’s leading healthcare law firm. YouCompli’s solution then guides users through a simple workflow to assign, manage, and track the rollout and completion of regulatory requirements. This one-two punch of intelligence and technology protects the whole organization and puts compliance officers at ease.  

For more information, visit www.youcompli.com.  

Qualified compliance professionals do the heavy lifting for you, simplifying regulatory change management   

Our in-house team works tirelessly to monitor U.S. regulators, carefully read the regulations in their entirety, and translate the information into simple regulatory intelligence you can use. We deliver model procedures and expert tools that can be used to fulfill your business requirements. Everything is validated by a third-party law firm. Follow the button below to get a tour of our healthcare compliance software.  

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Never miss an article from YouCompli. Sign up for YouCompli’s weekly email if you haven’t already.   

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27 Ungated Resources for Compliance Leaders and Teams 

Compliance professionals sometimes feel undervalued in comparison to other functions in their organization. They think leaders and colleagues don’t really understand what they do.  

These resources will help. Packed with ideas, tips and recommendations, these pieces were written by professionals with many years of compliance experience. 

You can quickly skim for articles that relate to your needs and interests. Bookmark this page as a reference for future questions or projects.

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The post YouCompli Brings Unique Value-Creating Compliance Technology to Healthcare Payers  first appeared on YouCompli.

As compliance officers, we talk a lot about the factors that directly influence a culture of compliance in our organizations. Of course, things like tone-at-the-top and engaged leaders are some of the most prevalent and impactful. But we don’t spend nearly as much time on elements that affect compliance culture more indirectly.  

Some of these indirect factors were highlighted during a December 2022 roundtable sponsored by the Massachusetts Health and Hospital Association (recapped in this YouCompli article). During the discussion, Timothy C. Hogan, senior vice president and chief compliance officer at Boston Children’s Hospital, advanced a theory that social determinants of health (i.e., non-medical factors that influence patients’ health outcomes) can influence compliance rates. These elements, which Hogan labeled “social determinants of compliance,” included workforce burnout, short-staffing, and upgrades to clinical data systems – factors mostly out of compliance officers’ control. Hogan later said that improving his organization’s compliance rates depended on being aware of and sensitive to the workload his colleagues already faced.

So, how can compliance officers identify and understand these social determinants of compliance? Also, how can they work with healthcare leaders to manage them and improve the organization’s overall compliance culture?  

Know the Business Side of Your Organization  

For any healthcare organization, there are two agendas: the compliance program agenda and the business agenda. Since the former is self-explanatory, let’s move on to the latter.   

Generally speaking, the business agenda relates to the operational and financial goals of the organization. For example: what new service lines does the organization want to capture in its market? What does its patient volume look like? What is its payer mix? Are we competitive in the market in terms of patient care and attracting the right talent? These are just some of the aspects of a healthcare provider’s business agenda. The answers to these questions, and other aspects of a business agenda, represent the basis of most (if not all) of the decisions that healthcare leaders make every day.   

So how do we better empathize with our healthcare leaders and learn the business side of your organization?   

• Be curious. There are many questions that can help shed light on an organization’s business agenda, such as: where is the organization positioned in the market? Who are its business partners and competitors? How does it make money? How does it manage its finances? How does it recruit and retain staff? What is its employee turnover rate? How does each department carry out its processes?
• Observe discussions happening around you. In meetings, or the meeting after the meeting, pay attention to what’s being talked about related to the services your organization offers and what’s happening in the marketplace.  
• Know how business decisions are made. For example, if you are working on an issue that has a financial component to it, your CEO likely will not make a decision unless the issue has been vetted first by the CFO.     

By studying and learning the business side of your organization, you’ll be in a better position to help your organization’s leaders navigate their challenges. You’ll also naturally identify other potential social determinants of compliance that you may need to overcome.   

Understand Your Leaders’ Perspectives  

Another way to identify and measure social determinants of compliance is to understand your leaders’ particular point-of-view (POV). In other words, you need to think like a healthcare leader, not a compliance officer. Listen to what they tell you, and approach your work from their perspective, not yours. For example, if you are rehab department director, what operational goals do you have for the department? What obstacles or challenges do you face? What motivates you in the performance of your role? These are just some of the questions you need to be thinking about if you want to better understand your leaders’ POV.  

By being aware of how your leaders think, you will uncover social determinants of compliance and understand their potential impact on the organization. You can then respond and assist accordingly, or remove barriers to successful compliance deliverables (e.g., completion of mandatory training).   

Know Your Leaders’ Positions and Interests  

Understanding a leader’s POV also means appreciating both their position on and interest in a topic or situation. Here’s a way to identify and distinguish them: a position is what a person says they want, while a person’s interest is the why behind whatever it is they say they want.

Let’s assume I’ve done an audit of medical necessity documentation for high-dollar imaging procedures like an MRI or CT scan. Let’s further assume that, after the audit, one of the recommended corrective action items is to conduct routine monitoring of how the imaging department documents medical necessity and billing for the procedures that were audited. Finally, let’s assume the imaging director’s name is “Sharon.”   

If Sharon says to me, “We cannot conduct routine monitoring for these exams right now,” that is her position. If I asked Sharon why, she might say, “Because I am currently down five techs – three due to budget cuts and two others because of medical leave. I am stretched so thin as it is.” The fact that Sharon is short-staffed, and feeling like her staff cannot take on the additional work, is her interest. When it comes to empathizing with healthcare leaders and identifying social determinants of compliance, identifying interests will be valuable information to you.  

Other examples of leadership interests may include budget limitations, software capability or capability challenges, and time—or lack thereof.  

While positions are often communicated publicly, identifying interests may not be – so they can be more challenging to identify and understand. A leader may not publicly disclose his or her interest, either out of concern that it is viewed as an excuse or because he or she is managing communications on a confidential topic. That said, you could have an offline discussion with that leader, in case they are more comfortable speaking freely if they feel they won’t incur judgment from others.   

It’s important to be mindful of the factors that directly affect your organization’s overall performance and compliance culture – as well as indirect ones like social determinants of compliance. With a complete set of input, you’ll be in a much better position to empathize with your leaders, help them navigate challenges and ensure all organizational compliance needs are met. Even better – you’ll probably deliver better patient care and health outcomes in the process.   

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Jay Anstine

Jay Anstine is a compliance professional and consultant in Colorado. He is a healthcare lawyer with significant industry knowledge of the U.S. healthcare market. Over the past 20 years, he has worked for large for-profit and non-profit health systems and small physician-owned entities. In tackling the countless regulatory and operational issues for these diverse organization types, he has developed a deep understanding of the business of healthcare and the regulations governing the industry. In 2018, Jay became an adjunct faculty member with the University of Southern California Gould School of Law, designing and teaching healthcare compliance courses. 

 Jay obtained his law degree from the University of South Dakota, where he focused on healthcare law. From 2012-2016, he served on the Board of a non-profit organization serving the medically underserved in Colorado (ClinicNET). He is also a member of the Health Care Compliance Association (HCCA), serving on the planning committee for the Mountain Regional Conference since 2008.  

The post How Social Determinants of Health Influence Compliance Culture   first appeared on YouCompli.

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

Build relationships with key clinical and operational areas 

Sharon Parsley, JD, MBA, CHC, CHRC contributes a monthly post on compliance officer effectiveness for the YouCompli blog. In this article she looks at specific ways to engage and communicate with Nursing, Physicians, Sales & Marketing, Revenue Cycle, and IT.

Many people in our discipline love the slogan “compliance is everybody’s business.” As a practical matter though, how do we make that a reality within our organizations? With limited budgets, perpetual resource constraints, and a constant need to “prove” our value to the enterprise, one way to maximize our reach and influence is by building strong relationships with key clinical and operational areas of our organizations. 

Nursing and Healthcare Compliance

Nursing represents the largest team in many healthcare organizations, so we must build strong relationships here. In an inpatient setting, nursing is going to be a 24×7 business. That means you have to find ways to raise compliance awareness for nursing teams who work 7pm to 7am weekend shifts, not just those who work during business hours.  Consider scheduling periodic weekend rounding on different units. You could also publish a weekend open forum or office hours schedule and encourage your nursing team to stop by for a quick coffee. Given the intensity of nurses’ workday, keeping your messaging concise, specific, and relevant is imperative. 

Meet regularly with nursing leadership. This will help you understand the key issues facing them. I find that the more time I spend with colleagues during times of relative calm, the better our work together goes when an issue does arise. If a policy change results in a need to alter nursing processes or procedures, work closely with nursing leaders to develop communication plans and methods to monitor adherence to the process change at issue. 

Physicians and Healthcare Compliance

I’ve seen a very broad spectrum of relationships with physicians and licensed independent practitioners (LIPs) over the past 20 years. I bet you have too. For me, that spectrum has ranged from positions of trust and mutual respect, to begrudging acceptance, to a few that bordered on being openly hostile. Nonetheless, we have to work together. And in contentious relationships, it is usually on me to find a way to smooth things out.  

The practice of medicine has, largely, become more business than science, but few physicians really enjoy being told what to do or how to practice. Who can blame them? How can we get them to comply without being perceived as adding to their administrative burden? That answer will vary depending on the nature and size of your organization but try starting small. Finding just one physician who is willing to truly champion compliance to his or her peer group can be pivotal to the success of your compliance reach into your physician and LIP ranks. 

Related: Investing time with clinical and operational colleagues improves relationships

For me, that has sometimes been the Chief Medical Officer or a physician CEO who really understood what I was trying to do. On other occasions, though, it has been practitioners who have stepped over a line or cut a few corners which resulted in a compliance issue. In several of those circumstances, once an issue was brought forward that practitioner collaborated with me to prospectively modify the behavior in question. In the process, they became compliance champions. 

 Seize every opportunity to demonstrate that compliance is not the police. We are trained professionals tasked with protecting the organization from risk and supporting the mission of providing excellent patient care. Yes, a big part of that is preventing, detecting, and remedying misconduct. But we also identify opportunities to improve processes based on regulatory guidance and we can help protect revenue and income. Help your physicians and LIPs understand your mission and how it can complement their oath to do no harm. 

Sales and Marketing Healthcare Compliance

Sales and marketing in healthcare is, as we all know, unique. In most industries, treating a prospect to a nice evening meal, hosting him or her for a round of golf at your country club, or inviting the prospect to a local sporting event is not only permissible, but common. In healthcare, however, those same activities can potentially run afoul of federal and state laws. 

If you are in the medical device or pharmaceutical space, your industry groups have published codes of ethics that create some boundaries for what sales and marketing can and cannot do. For most of the rest of us, we usually attempt to distill the applicable law and regulation into policies. Understanding and articulating the Stark law and its exceptions and the Anti-kickback law and its safe harbors is tricky. Your sales and marketing teams are not likely to be well versed on these regulatory issues and how they may limit certain activities. 

Meet with them regularly and offer an onboarding tailored to new sales and marketing department personnel. As much as possible, offer specific examples of what is ok, what is not, and the “why” behind each category. Can your sales team provide lunch for everyone working in a community physician’s office? If so, does some portion of that then need to be included in a Stark non-monetary compensation tracking tool? Does the answer change if it is a lunch-and-learn? Can your marketing team sponsor a mall walker program? If so, can they provide a step counter to enrollees in the program? Can marketing give holiday gifts to physicians? If so, is it non-monetary comp that must be tracked, a medical staff incidental benefit or neither? Providing specific examples tailored to your enterprise helps raise awareness. 

Revenue Cycle and Healthcare Compliance

Nurturing a strong partnership with your revenue cycle team is imperative. Governmental and commercial payers have developed extremely sophisticated data mining programs that often identify coding and billing aberrations even before we find them internally. Understanding how to distinguish coding-specific payment denials from medical necessity denials is an important skill. Those issues can help with early identification of localized and more systemic issues. 

Everyone in our discipline is likely aware of the possibility of “reverse false claims” liability. Here, any overpayment from a governmental payer source must be returned within 60 days of its identification. If it is not, the organization can be assessed penalties and be responsible for treble damages. Establish a regularly scheduled meeting among compliance and revenue cycle to discuss areas of vulnerability, patterns of denials, and emerging areas of revenue integrity risk. 

Information Technology and Security

Information technology and information security departments are instrumental in protecting the organization’s data assets. Ransomware, phishing, and cyberattacks are in the news frequently now that hackers have targeted the healthcare community. Virtually all healthcare companies deal with some subset of data which contains protected health information or PHI. Here is one major area where compliance and IT functions may overlap. As your IT group develops strategies to mitigate cyber risk, your privacy function should be involved to ensure that all applicable federal and state privacy laws and regulations are considered. If your organization maintains student health records, you may also need to ensure that FERPA regulations are understood and heeded. If credit card data is used and stored, there are likely PCI requirements that need to also be incorporated into these tactics and strategies. 

IT often recommends the adoption of certain tools and technologies that impact your electronic medical records. Compliance needs to be part of the evaluation committee for new products to ensure that PHI is properly identified and safeguarded. If your organization conducts an annual risk assessment, this is one area for close collaboration between Compliance and IT. Risk assessment processes vary greatly from one organization to another. Understand new and emerging areas of cyber risk and what issues are “top of mind” for your IT and data security teams.  Based on those risks, you can develop targeted training and education and build auditing and monitoring activities to identify potential issues and mitigate risks.   

The more you can help your colleagues across departments see how you help them achieve their goals, the more invested they will be in compliance. The investment of time and collaborative energy on your part will pay off in a more effective compliance program, better overall patient experience, and revenue protection for the organization.  

How YouCompli can help

Use YouCompli to give yourself time back to focus on relationships and listening. Build a scalable, repeatable change management process to enable your team and colleagues to focus on their expertise rather than the minutia of monitoring and reading regs.  

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Sharon Parsley, JD, MBA, CHC, CHRC, is a health law attorney, compliance officer, author, speaker, investigator, and problem solver. She currently serves as the president and managing director of Quest Advisory Group, LLC. She has nearly 20 years of healthcare compliance and legal leadership experience, and she believes that mentorship and on-the-job training are critical to compliance professional success.  

The post Healthcare Compliance is Everybody’s Business: Clinical, Revenue Cycle, IT, Sales and Marketing first appeared on YouCompli.

Don’t let processes overwhelm clinical colleagues

Helping our clinical colleagues feel the urgency of compliance monitoring can be a huge challenge. They’re busy seeing patients and doing the best they can to deliver care the best way they know how.  

Sometimes payers have specific requirements for care, though. And the Compliance team simply doesn’t have the clinical expertise to own the monitoring of these requirements. That’s why we work so hard to simplify and streamline regulatory change management: we have to take the busy work out of compliance so that our clinical colleagues can apply their subject matter expertise to compliance, rather than getting overwhelmed with process. 

Let’s now look at a real scenario that I encountered as a Compliance Officer that supports having Clinical leadership perform monitoring, document the monitoring, and report out the results.  

The net of it is this: Our Compliance Department performed a compliance audit related to sleep studies that resulted in a significant payback to the federal government that could have been avoided if monitoring was being performed by the Sleep Center Clinical leadership.  

Million-Dollar Payback 

In June 2019, the Office of the Inspector General (OIG) released findings and recommendations from a review of polysomnography [sleep] studies. The review found providers often did not meet the Medicare billing requirements – a whopping 83 of 200 were in error.

That’s a 41% error rate with an extrapolated overpayment of $269 million.  

The majority of the errors were due to: 

• Incomplete medical record documentation. The records did not contain face-to-face evaluations, attending physician orders and/or the technician’s report.  
• Technologist or technician lacked the required credentials or training certifications.  

In response to this report, my Compliance department initiated a statistical sample of sleep study claims to ensure the claims met the required billing rules and regulations. The initial results of the review were very good. The claims submitted had the required documentation to support the claim and the system received payment for the claims submitted.  

All good? Well, not exactly. While preparing for the audit, the compliance auditor researched not only the required billing rules and regulations, she also checked the National Coverage Determinations (NCDs) and Local Coverage Determinations (LCDs). The auditor found an LCD that addressed polysomnography services.  

Armed with the LCD requirements, the auditor re-visited our sample of claims and found that 95% of the claims in the sample did not include the LCD requirements. As a result, the system initiated the required paybacks and we expanded our statistical sample to determine if prior claims failed to meet the LCD requirements.  

The results were similar, and when we extrapolated the error rate to our population, we arrived at a payback in excess of $1 million. We took immediate corrective action to ensure this would not occur in the future. Included in the corrective action plan was the establishment of an NCD/LCD subgroup. The subgroup included Clinical Leadership, Finance, Health Information Management and Compliance. The charge of the subgroup was to ensure the Clinical Departments were aware of NCDs and LCDs affecting their specific area and establishing a process to ensure they received the most up to date NCDs and LCDs.  

Painful LCD Monitoring Lessons Learned: 

This was a painful experience for the organization and the leadership. It definitely taught us some lessons. In the future, we made sure to: 

1. Ensure that clinical leaders are accountable for knowing the specific billing rules and regulations (including NCDs/LCDs) that impact their area. Much to our surprise the clinical leadership of the Sleep Study department was not aware of NCDs/LCDs. 

2. Ensure that clinical leadership conducts monitoring and can demonstrate that their monitoring encompasses all billing rules and regulations including NCDs/LCDs. Also, the results of their monitoring should be included in department metrics reported to their leadership and the Compliance department.  

3. Establish an NCD/LCD subgroup to aid Clinical departments in ensuring they have reviewed all applicable billing rules and regulations. Our subgroup shifted to quarterly meetings that the clinical department leaders actually look forward to attending.  

4. Conduct compliance audits of high-risk areas identified in the OIG’s Work Plan. The OIG now updates the work plan monthly. I recommend you sign up to receive the updates.  

5. Review the OIG Office of Audit Services final reports. They provide a wealth of information on findings for high-risk areas and how the OIG conducted their audit. It is a good roadmap to ensure your system targets the highest risk areas so if the OIG comes calling you can demonstrate the action your system has taken to be in compliance.  

Support Clinical Leadership Compliance Responsibilities 

You may run into resistance when you try to bring clinical leadership into an active compliance role.

Remember this: The Compliance, Finance, and Legal departments are not experts on the services that are rendered in a clinical area. Yes, you and these other departments can assist if there are questions about interpreting a regulation.

However, Clinical Leaders must take responsibility for  

• Keeping current with changes in rules, regulations, and laws appliable to their operational areas 
• Developing internal controls, policies, and procedures to comply with them 
• Training their staff on the written guidance  
• Actively monitoring and verifying the guidance is being followed.  

The best way you can help with this is to provide a scalable, repeatable process that takes the drudgery and busy work out of these responsibilities. From there, you can serve as a sounding board and thought partner, rather than trying to carry the clinical burden of compliance all by yourself. 

Where to Start Advising Clinical Teams 

The next time you’re meeting with a clinical team, ask how they approach monitoring. (Be mindful, they may not be calling it “monitoring.”) If you aren’t regularly meeting with clinical colleagues, I’d suggest finding a way to get closer to them before launching into a monitoring discussion. (Read Ken Zeko’s 12 key metrics for compliance officers looking to move their culture forward for tips on meeting with operational and clinical colleagues.) 

Start small. Choose a Clinical Department and ask the leaders how they receive specific information related to billing requirements. Be sure to include their awareness of NCDs/LCDs. If they ask you what an NCD/LCD is, you know where to start.  

Learn from the OIG. The OIG’s Office of Audit Services reports include the findings of their auditing of high-risk areas, and they provide a good roadmap on their sampling methods. You can use this to lay out your own steps for auditing and monitoring.  

Sampling. The Clinical Department can select a small sample on a random basis. If the sample results reveal a potential issue, expand the sample. In these situations, I would recommend involving your Compliance department. 

Survey to Expand. Consider developing a survey to find out how your clinical colleagues learn what documentation is needed to support a clean claim. This insight can help you determine how diligent your colleagues are about monitoring. 

As you move through this inquiry, you will start to embed yourself as an advisor to your clinical colleagues as they work to ensure clean operations. You can help them stay proactive by reviewing the OIG Work Plan with them regularly. Let them know if they are in a high-risk area as identified by the OIG and offer to help them with process and content to ensure clean claims.  

Your clinical colleagues may feel overwhelmed with this responsibility, especially if they haven’t been accountable for it before. Show them they are not on an island by giving them process support that helps them focus on applying their clinical expertise to compliance. 

YouCompli tackles regulatory change management with a one-two punch: qualified people to make sense of regulatory changes plus simple software to manage the rollout.  

Brian W. Kozik, CHC, CCEP, CHCP is a 25-year veteran of healthcare compliance and an expert in compliance monitoring and auditing. Most recently he served as Chief Compliance Officer at a major health system in Southern Florida. He is the author of The Healthcare Auditor’s Handbook and Ready, Set, Comply!: Compliance Games, Activities, And Tools to Train Your Staff. 

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The post A million-dollar healthcare compliance monitoring mistake  first appeared on YouCompli.