Innovation is Hot at HCCA Compliance Institute

The hot topic this year at the Health Care Compliance Association’s Compliance Institute, is innovation. Speakers who begin talking about anything from ethics and culture to the latest news, all seem to make their way to the role innovation plays at every level. And we agree.

Compliance Best Practices Include Finding Innovative Solutions

In fact, we couldn’t agree more. In this digital age, we find our day to day workload lightened by innovative solutions. Why shouldn’t our compliance practices? It’s invigorating. It’s just 2 days in, but we’re thrilled to be here and hope to meet other colleagues who share this point of view.

When we founded youCompli, we set out to make the entire process — from keeping up with regulation changes to implementing them — as easy as possible. We take pride in our innovative approach and have been delighted with our fellow compliance professionals’ response.

We all Share a Passion for Taking Care of People

Of course it’s always so good to be able to discuss the common values that drive us all — helping people! If we haven’t met yet, please stop by Booth #322. And if you’re not attending HCCA CI, let’s meet virtually – just request your 10-minute demo and we’ll look forward to meeting you and answering your questions, virtually.

youCompli makes complying with regulatory changes EasierFaster and Reliable

#chaostoconfidence #stopreadingregs #patientcare

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How to Align Physician Satisfaction and Compliance

Fraud is still a very real issue across the relationships
between physicians and hospitals

Is it possible to align physician satisfaction and compliance? According to Gail Peace, President of Ludi Inc., “Regardless of the physician being independent or employed by a hospital, there are a myriad of regulations to navigate in these relationships.” She goes on to explain how the dynamic between physician groups and hospitals can be tense and complicated. And yet, fraud continues to be a very real issue for them both. In fact, she says, while fraud overall is down in other industries, it’s not the case in health care. In a recent post, from Insights from Ludi, Gail emphasizes out how devastating financial settlements can be. Health care fraud cases make up 90% of the OIG settlements. Kickbacks, it turns out, are the leading cause of hospital violations.

Further, as the number of regulations continues to rise, these tensions and complexities can become even greater between hospitals and physician groups. The Office of Inspector General (OIG) has offered good guidance for physicians. And so, with these factors in play, it’s worth reviewing the OIG’s 7 components for physician groups:

7 Components for Creating a Voluntary Compliance Program

Establishing and following a program like this, the OIG says, will help physicians a lot. In fact, the OIG says hat a well-designed compliance program can:

  1. Speed and optimize proper payment of claims
  2. Minimize billing mistakes
  3. Reduce the chances that an audit will be conducted by HCFA or the OIG; and
  4. Avoid conflicts with the self-referral and anti-kickback statutes

Here are the OIG’s seven components to create a voluntary compliance program:

  1. Conduct internal monitoring and auditing.
  2. Implement compliance and practice standards.
  3. Designate a compliance officer or contact.
  4. Conduct appropriate training and education.
  5. Respond appropriately to detected offenses and develop corrective action.
  6. Develop open lines of communication with employees.
  7. Enforce disciplinary standards through well-publicized guidelines.

Surely, we all agree these are important components. But what else can physician groups and hospitals be doing?

Can’t We All Just Get Along?

Gail and co-leaders, Kelly Walenda, Sr VP Legal Services and Chief Privacy Officer, Jefferson Health; and Eugene McMahon, Senior VP and Chief Medical Officer, Capital Health System, are leading an intriguing session at HCCA’s Compliance Institute. They plan to get to the heart of this issue. The premise is simple: compliance can feel big brother to physicians. On Tuesday, April 9, we’ll be looking forward to hearing more in the session: Can’t We All Just Get Along? Physician Satisfaction and Compliance Are Not Mutually Exclusive In Physician Arrangements. They will be presenting case studies, strategies and best practices to manage arrangements that align priorities. They will also share their paths for engaging physicians and how to dialog with physicians about work performed to drive clinical agenda. We look forward to hearing these ideas and we’ll be sure to share our impressions, too.

Likewise, it will be good to discuss how youCompli’s distinctive features and benefits may prove quite helpful. At its core, youCompli ensures compliance and increases efficiency. These are the priorities we all share.
We are looking forward discussing this and more at HCCA CI. Not going to CI? Let’s meet virtually – just request your 10-minute demo.

youCompli makes complying with regulatory changes EasierFaster and Reliable

#chaostoconfidence #stopreadingregs #patientcare

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youCompli Team Heads to Compliance Institute

The youCompli team is looking forward to heading to Boston for the HCAA’s Compliance Institute from April 7-10. The HCAA calls this event the single most comprehensive healthcare compliance conference. That’s why we think it’s a terrific chance to learn more from our colleagues in specialties such as Healthcare Reform, Hospital Physician Alignment, and Compliance Effectiveness.

Why Go to Compliance Institute?

Diana Nyad

Two of the discussion tracks we anticipate exploring include  “Culture is King: Strategies for Developing and Maintaining a Culture of Ethics and Compliance” and “Can’t We All Just Get Along? Physician Satisfaction and Compliance Are Not Mutually Exclusive In Physician Arrangements.” We’ll be blogging about our impressions of these discussions and other observations at the conference as well. Stay tuned.

In addition, we can’t wait to hear from the incredible lineup of speakers, including, Diana Nyad the first person to swim from Cuba to Florida without the aid of a shark cage, swimming 111 miles in fifty-three hours from Havana to Key West.

Renee Baine


We also envision learning so much from Renee Baine, with Shriner’s Hospital for Children, who supports many areas, such as research, revenue cycle, and the business associate programs for Shriners Hospital for Children’s twenty-two facilities.

Scott Eblin


Scott Eblin actually wrote a book, Overworked and Overwhelmed, which we’re sure a encapsulates how many of our customers and potential customers feel about their day to day workload. We can’t wait to hear Scott’s advice and message as well.

So you can see why we are excited to listen, learn and showcase how we can help.

Are you planning to attend, too? Let’s meet. We’ll be scheduling 10-minute in-person demo’s of our software at the conference. You can click here to schedule yours, right now.

With youCompli, you and your team can ensure compliance and increase efficiency, so patient care stays front and center, always, no matter how many reg changes come your way. Isn’t this the key reason why we choose to work in healthcare in the first place?

youCompli makes complying with regulatory changes Easier, Faster and Reliable

#chaostoconfidence #stopreadingregs #patientcare

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78 Pages. 1 Regulation. Analyzed by Experts in Days.

Compliance Experts

Final rule 42 CFR Part 59 is 78 pages long. Have you read it yet? How about your team? How long will it take? And then, will you feel confident in what actions you may take? Or is there another process you’ll undertake to make sure?

At youCompli, it took us just a few days to read these 78 pages, analyze them and determine how and what our customers will need to do to comply. Here’s why:
At youCompli, We’re Fast Because We’re Compliance Experts 

We analyzed 78 pages faster because it’s what we do every day on behalf of our clients. youCompli’s Expert Compliance Professionals (ECPs) have been working for years in the healthcare compliance industry. As seasoned professionals, we offer a unique perspective in how we read, analyze and develop guidance for organizations to prove compliance. But we don’t stop there.

Once we develop a set of protocols to recommend to our customers, we review them with the nationally-renown law firm, Horty Springer, and collaborate, so that the tools are easy to understand, easy to implement, and even easier to manage, via our innovative youCompli software.

We make it look easy, we’re fast, but you can trust us, because we leverage years of experience to make compliance reliable. We know how difficult, confusing and overwhelming healthcare compliance can be. That’s because we came from the healthcare compliance sector, too.

Here’s How youCompli Works:
  • We track, read, analyze and interpret new regulations and changes, daily.
  • Then we create the tasks and tools for our customers to comply, in collaboration with our partners at Horty and Springer, so our customers can instantly decide if and what they need to do to comply.
  • Finally, we provide all of this via our signature, innovative and intuitive software, that empowers our customers to manage their compliance.

Feel like you’re spending too much time and money trying to manage compliance? Overwhelmed by long regulation changes, like 42 CFR Part 59? Let’s meet.

With youCompli you can trust us, because we’re experts, and we can help you and your team go from Compliance Chaos to Compliance Confidence.

youCompli. The only regulatory change management solution that makes compliance
Easier, Faster and Reliable

#chaostoconfidence #stopreadingregs #trusttheexperts

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How I Became a Confident Compliance Officer

As the sole compliance professional in my hospital, my role preceded me. When clinicians saw me rounding a corner, they seemed to avert their eyes and look at the floor. Department heads? The same.

I understood why. I brought extra work: go to websites, read regulations and print things off; re-invent policies; re-evaluate codes, and the list goes on.

I distracted them from doing what they loved… delivering patient care.

Then youCompli changed all that. It revolutionized our regulatory processes and helped ensure our compliance. It was exactly what I wished for – an empowering solution to manage the ever-growing number of healthcare regulation changes.

youCompli Changed My Life. Ok, even I admit this sounds dramatic. But it’s kind of true.

Since bringing on youCompli, I have become a regulatory change management heroine. Now I approach my colleagues with a crowd-pleasing ice breaker: “You don’t have to read regulations anymore.”

With youCompli, it’s like getting a team of experts, all wrapped up in easy-to-use software. youCompli lets me:

  • Instantly decide if a new reg matters to me
  • Understand what needs to be done to complete our compliance
  • Make specific, written policies & procedures changes

Having a hard time making eye contact with your peers? Check out Better yet, schedule a demo and learn more.

Request 10-Minute Demo

youCompli. The only regulatory change management solution that makes compliance
Easier, Faster and Reliable.


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74 Federal Healthcare Regulatory Changes in January 2019 Alone

Yes, 74! 

Are you surprised?

In recent months, we’ve noticed two themes that challenge everyone managing regulatory changes:

First, regulatory changes are flooding into your organization in lots of different ways, to lots of different people; daily subscriptions, hospital associations, clinical associations, law firms, etc. This can be very chaotic. A compliance officer recently joked that she was often the last person to know when a regulatory change occurred. 

The comment we hear most often is, “It’s troubling… I don’t know what I don’t know.”

Even with what seems to be a sound process in place, many compliance officers recognize that their current way of working is not robust enough to encompass all of the organization’s actual needs.

Second, there is a simple misunderstanding about how often regulations change. One of the questions we get most often is “How many regulations would you send to us monthly?” The answer always catches them off guard.  

In January alone we processed 74 Federal healthcare regulations:

– First, our talented team of Expert Compliance Professionals (ECPs) tracked, read, analyzed and interpreted those regulations
– Then they created the tasks and tools for our customers to comply
– We shared this guidance to empower our customers to take action as needed

With youCompli, you and your team can stop the chaos of tracking and reading regulations and feel confident you have what you need to comply.

youCompli. The only regulatory change management solution that makes compliance
Easier, Faster and Reliable.

Request 10-Minute Demo

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Highlights from OIG’s Semi-Annual Report to Congress

Late last week, the HHS OIG made available its semi-annual report to Congress summarizing OIG activities occurring from October 1, 2017 to March 31, 2018. As one might expect, OIG continues to commit resources to enforcement-related activities and to improve its data analytics capabilities. A few of the “headlines” from an enforcement perspective include:

  • Criminal actions brought against 424 individuals and entities allegedly engaged in crimes against HHS programs;
  • Exclusion from participation in Federal health care programs of 1,588 individuals and entities;
  • Civil actions brought against 349 individual and entities; and
  • Anticipated recoveries exceeding $1.4 billion from investigations

Many familiar themes and issues were examined by the OIG Office of Audit Services during the six-month period in question. Findings from select audits were that:

  • On an extrapolated basis, one MAC was found to have paid as much as $42.3 million in improper payments to 73 providers for hyperbaric oxygen therapy services which did not comply with all requirements.
  • An error rate of 100% was observed within a sample of 296 claims paid to 210 hospitals for the handling of manufacturer credits for recalled and failed cardiac medical devices.
  • An extrapolation from a small sample of audited outpatient physical therapy claims suggested that $367 million in improper Medicare payments were made during the six-month period for services and associated medical records which did not comply with medical necessity, coding or documentation requirements.
  • All but one of 2,145 inpatient claims for a diagnosis code 260 for Kwashiorkor were found to have been inaccurate.
  • A total of $66.3 million was calculated to have been erroneously paid for specimen validity tests billed simultaneously with certain urine drug screens.

If your organization provides any of these services to Medicare beneficiaries, it is an opportune time to look at your adherence to applicable requirements for clinical documentation, medical necessity and billing within these areas.
A link to the detailed report is available here.

By Sharon Parsley, Director of Content Development

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To Bundle Or Not To Bundle?

In August of 2017, CMS announced the cancellation of a proposed Cardiac Care Bundled Payment model as well as reversing course on a proposal to expand the Comprehensive Joint Replacement Bundled Payment model. Participation in both payment models would have been mandatory for certain providers in specified markets.

In January 2018, to considerable fanfare, CMS announced the creation of “Bundled Payments for Care Improvement Advanced” (BPCI Advanced). As of the publication date of this article, CMS will be distributing pricing to BPCI Advanced program applicants and, per the model program timeline, will move to execute participation agreements by the end of August 2018. This voluntary model is proposed to go live on October 1, 2018, with the first determination date for program payments on March 31, 2019. BPCI Advanced will be treated as an Advanced Alternate Payment Model under the CMS Quality Payment Program. The following is an introduction to some of the key components of BPCI Advanced.

First, acute care hospitals and physician groups may participate as “covener” or “non-covener” participants. The former will agree to coordinate care among patients throughout a 90-day “clinical episode,” which commences on the date of inpatient discharge or on the date of a covered outpatient procedure. Coveners will also assume some financial risk for the entire episode of care, whereas a non-covener participant bears no financial risk for care provided by other providers. Providers other than acute care hospitals and physician groups will be permitted to participate only as non-coveners.

Secondly, BPCI Advanced includes 29 distinct inpatient Medicare Severity-Diagnosis Related Group (MS-DRG) codes and three types of outpatient surgical encounters. A BPCI Advanced clinical episode is triggered by submission of a Medicare fee-for-service program claim by an “episode initiator.”

Thirdly, subject to certain exclusions, the clinical episode will generally include all physician services; inpatient, outpatient, long-term care, and inpatient rehab hospital services; hospital readmissions; skilled nursing; home health; clinical lab services; durable medical equipment; Part B drugs; and hospice services relating to the MS-DRG or the event that triggered the outpatient surgery.

Lastly, the payment reconciliation model is extremely complex, but is largely predicated on performance against select process-and-outcome quality measures and by comparing the aggregate costs of care provided during a clinical episode against an established target.

As an interesting backdrop, the Trump administration under former HHS Secretary Price, has taken aim at rolling back mandatory bundled payment initiatives, whereas Alex Azar, confirmed in January to fill that important role, has expressed support for alternate and bundled payment models. So, to bundle or not to bundle? Stay tuned for further developments.

Sharon Parsley

Director of Content Development

“Compliance Magic”


Determine If Any New Regulation Matters To You, Without Reading It!

During a demo, a prospect referred to a part of our system as “Compliance Magic”.  I asked her what she meant…she answered; “I can decide if a regulation matters to me (or not) without having to read it; it’s like magic”, I grinned like a Cheshire cat.

Pennsylvania’s “Right To Try Law provides a great opportunity for us to provide an example of this “magic”.

Without youCompli (if you’re not sure it’s relevant) you’re probably printing the new Regulation grabbing a yellow pad and starting to read.

Step 1: Is it Relevant To Me? (You my know this..or you may not)

When you read it, you’re looking for the parameters in the law that will help you decide if the regulation is relevant to you.

youCompli provides the parameters for you (we call these Relevance Questions). Here’s the Relevance Questions for Right to Try.

These questions seem pretty straightforward, but to answer the first one accurately you need to know what a “licensed health care facility” is in the Commonwealth of Pennsylvania.  youCompli provided it; we call this a “Tip”.

OK, now you’re ready to make your decision; Relevant or Irrelevant.

As I mentioned this example is straightforward, but as you know these relevance questions can get pretty complex.  Simple or complex we do this on every new healthcare regulation.

This info is provided to you (at no cost) on every new regulation.  You may not need it, you may already know that Right To Try applies to you.  But if you don’t, this would sure save you a lot of time.

Want to see this “magic”, drop me a note to arrange a demo


Step 2: OK, it’s relevant to me.  What am I required to do to comply (STAY TUNED)


Do You Have the 4 Core Elements of an Emergency Preparedness Program? by Jay Anstine, JD

4 Core Elements of an Emergency Preparedness Program by Jay Anstine reminds us of the motto of the Boy Scouts, Be Prepared

Be Prepared

The motto of the Boy Scouts is Be Prepared.

On September 16, 2016 the Centers for Medicare and Medicaid Services (CMS) made Be Prepared a law. CMS published a final rule relating to new federal emergency preparedness requirements. This rule impacts seventeen different types of Medicare participating providers and suppliers.  The new regulation requires adequate planning and establishing of a more consistent response by providers and suppliers.

Under this new CMS rule, you must develop and maintain an “Emergency Preparedness Program.” This program needs to contain four core elements:

  1. Emergency Plan: Develop an emergency plan, updated at least annually, that is based on certain risk assessments and utilizes an “all hazards approach”. The emergency plan must also include strategies for addressing emergency events identified by the risk assessment, factor in patient population and capabilities to serve, and include a process for cooperation with local, tribal, regional, State, and Federal emergency preparedness officials.
  1. Communication Plan: Develop a communication plan, updated at least annually, that complies with Federal, State, and local laws and includes, among other items, the names and contact information for Federal, State, tribal, regional, and local emergency preparedness staff and methods for sharing medical and other information.
  1. Policies and Procedures: Policies and procedures must also be developed that are based on the emergency plan, the risk assessment, and communication plan. The policies and procedures must be reviewed and updated at least annually and address, among other items, subsistence needs for staff and patients (e.g., food, water, medical supplies), a system for tracking the location of on-duty staff and sheltered patients, emergency staffing strategies, and arrangements to transfer patients.
  1. Training and Testing Program. Develop and maintain a training and testing program based on the emergency plan, the risk assessment, the communication plan, and the policies and procedures. The training program requirements address topics such as who needs to be trained, the frequency of training, assessing knowledge, and documenting the training conducted.  The testing requirements address topics such as conducting full scale exercises, conducting additional testing, and the format of each testing type.

The exact CMS emergency preparedness program requirements will vary based on the characteristics of each provider and supplier type.  For example, there are additional requirements pertaining to emergency systems applicable to Hospitals, Long-Term Care Facilities, and Critical Access Hospitals.

This new regulation went into effect on November 16, 2016. Participating providers and suppliers have until November 16, 2017 to implement all regulations.

The seventeen provider and supplier types include:

  1. Hospitals
  2. Religious Nonmedical Health Care Institutions (RNHCIs)
  3. Ambulatory Surgical Centers (ASCs)
  4. Hospices
  5. Psychiatric Residential Treatment Facilities (PRTFs)
  6. All-Inclusive Care for the Elderly (PACE)
  7. Transplant Centers
  8. Long-Term Care (LTC) Facilities
  9. Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF/IID)
  10. Home Health Agencies (HHAs)
  11. Comprehensive Outpatient Rehabilitation Facilities (CORFs)
  12. Critical Access Hospitals (CAHs)
  13. Clinics, Rehabilitation Agencies, and Public Health Agencies as Providers of Outpatient Physical Therapy and Speech-Language Pathology Services
  14. Community Mental Health Centers (CMHCs)
  15. Organ Procurement Organizations (OPOs)Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs)
  16. End-Stage Renal Disease (ESRD) Facilities
youCompli. The only regulatory change management solution that makes compliance
Easier, Faster and Reliable

#chaostoconfidence #stopreadingregs #trusttheexperts

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