Dear Providers and Staff,
FY 2023 is ramping up with some exciting activities in the Yale Medicine (YM) Compliance Department. The team recently completed a detailed risk assessment and risk analysis to develop the FY 2023 compliance workplan. The workplan has been approved by the Medical Billing Compliance Committee and topics are outlined later in this newsletter. The YM compliance risk assessment and planning process is ongoing and dynamic. Accordingly, new objectives will be added to the workplan over the course of the year, and the focus and timing of objectives articulated in the workplan may be altered in response to new developments, new risks, and shifting priorities.
For general awareness, the workplan is based on a qualitative assessment of medical billing compliance risks facing YM, and took into consideration the following factors:
- Priority items included in the Office of the Inspector General for the U.S. Department of Health and Human Services (OIG) Workplan;
- Review of external audit activities related to RACS, SMRC, CERTS (government-related audits) and also other commercial payors;
- Details of recent Centers for Medicare and Medicaid Services (CMS) settlement agreements with health care providers;
- Recent regulatory changes and new regulatory guidance;
- Recent YM Compliance monitoring and auditing results;
- Trends and issues identified through questions, concerns, and complaints raised to YM Compliance;
- Other identified risks through internal discussion and need (e.g. chaperone use);
- Patterns of unusual billing activity identified by YM Compliance’s outlier analysis software (Nektar); and
- Analysis of lead administrator/senior director and Compliance liaison responses to a Risk Assessment Questionnaire.
The Compliance Department is dedicating additional resources to improve compliance-related education for our providers. This includes enhancing education activities targeting new providers and hiring additional support for broader compliance and documentation education across existing providers.
We are dedicated to enhancing the YM Compliance program so that it is structured in a manner that effectively detects, corrects, and prevents compliance-related risks. Our goal is to create a compliance program that is collaborative andsupportive to our providers and staff. We believe that together we can both meet the requirements for compliant activities and support our clinicians in providing the best possible care to the patients they serve.
Andrea TenBrink, CHC, CHPC, MHA
Senior Director Compliance