Monthly Strip Topics
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Monthly Cartoon Strip Topics
First 12 Months


  1. Introduction.  Captain Integrity introduces himself and the monthly picture strips.


  2. Reporting Process.  Captain Integrity describes how compliance concerns can be reported for investigation.


  3. HIPAA.  Employees discuss confusion about HIPAA. Captain Integrity explains what HIPAA is and that we are obligated to keep records confidential and secure.


  4. Unfair Employment Evaluation.  Captain Integrity encourages employees to speak to a higher level manager or a Human Resource representative regarding perceived unfair evaluations.


  5. Physician Payments.  Captain Integrity emphasizes that all payments to physicians must be at fair market value.


  6. Compliance is Everyone's Responsibility.  Even though the Organization has a compliance officer, Captain Integrity emphasizes that compliance is everyone's responsibility.


  7. Retaliation.  Captain Integrity emphasizes that employees cannot be retaliated against for raising a compliance concern.


  8. Education.  Captain Integrity tells billing employee that she should seek education if she does not understand billing rules and regulations.


  9. Drug Representatives.  Captain Integrity tells employees that they cannot accept lunches or other gratuities in exchange for business.


  10. Physician Billing.  Captain Integrity tells billing employee not to bill a service higher than as documented in the medical record even though a physician encourages the employee to do so.


  11. Theft.  Captain Integrity encourages employee to report theft by another employee to their supervisor or compliance officer.


  12. Repayment.  Captain Integrity tells employees that all identified overpayments, regardless of the amount, need to be repaid.





Monthly Cartoon Strip Topics
Second 12 Months
  1. Privacy Breach.   An employee reveals confidential patient information. Captain Integrity encourages employees to contact the Privacy Officer and instructs employees that all patient information must remain confidential and secure.


  2. Medical Director Kickback.   A physician is offered a medical directorship in exchange for patient referrals. Captain Integrity states that this arrangement is a clear compliance violation.


  3. Conflict of Interest.   Business with the Board Chairman's company is identified as a potential conflict of interest. Captain Integrity encourages employees to contact the Compliance Officer for investigation.


  4. Billing, Coding and Documentation Responsibility.  Captain Integrity informs employees that everyone is responsible for billing, coding and documentation compliance, not just the business office.


  5. EMTALA.  When an administrator demands that a patient be transferred to another hospital because the patient is uninsured, Captain Integrity informs employees that a medical screening and stabilizing services are required under EMTALA, regardless of a patient's ability to pay.


  6. Real Estate Leasing.  Captain Integrity informs constituents that below market lease rates cannot be offered to physicians.


  7. Destruction of Evidence.  Captain Integrity informs employees that evidence cannot be destroyed after a subpoena has been issued on the organization.


  8. Drug Company Sponsorship.  Captain Integrity informs Constituents that drug companies can sponsor educational events that focus on patient care.


  9. Billing Review.  Captain Integrity informs constituents that a billing review must be performed when an employee believes that a procedure may not have been coded correctly.


  10. Racial Discrimination and Non-Retaliation.  Captain Integrity informs constituents that racial discrimination must be investigated by the Human Resource Department and that employees will not be retaliated against for requesting an investigation.


  11. Personal Cash Gift/Rebates and Discounts.  Captain Integrity tells constituents that personal cash gifts cannot be accepted, and rebates and discounts are permissible in accordance with established guidelines.


  12. Accurate Documentation Impacts Revenue.  Captain Integrity emphasizes that compliance is about being paid accurately for the service provided, not just for detecting overpayments.





Monthly Cartoon Strip Topics
Third 12 Months
  1. Working Hotline.  Responding to an employee's complaint that the hotline number doesn't work, Captain Integrity suggests that the employee contact their compliance officer to validate the hotline number.


  2. Medical Director Services.  Captain Integrity states that organizations can pay medical directors fair market value for actual services rendered.


  3. Coding Accuracy  Captain Integrity cautions against assumption coding emphasizing that all codes selected must accurately reflect the services provided.


  4. Real Estate - Shared Space.  Captain Integrity emphasizes that a contract, at fair market value, must be in place even if a physician uses space only one day each week.


  5. Patient Choice of Providers.  Captain Integrity explains that patients have the right to select their providers, and employees can assist patients in making that selection if the patient asks for recommendations.


  6. Compliance Committee.  Captain Integrity emphasizes that compliance committees must meet and deal with compliance issues in order to have an effective compliance program.


  7. Stark Act - Family Member.  In a fun manner, Captain Integrity informs the reader that you cannot get around the Stark Act by contracting with the physician's spouse instead of the physician directly.


  8. HIPAA - Privacy and Security.  Captain Integrity cautions employees who fax patient information to ensure the accuracy of all fax numbers.


  9. Compliance Program Education.  Captain Integrity reminds employees that training regarding the compliance program, especially how to bring issues to the organization's attention, should occur periodically.


  10. HIPAA - Privacy - Confidential Discussions.  Captain Integrity cautions employees to be very careful when discussing patient information in hallways and elevators.


  11. Retaliation.  Addressing an employee who fears retaliation for reporting a compliance issue, Captain Integrity assures the employee that no retaliation will occur for a good faith report regarding a compliance allegation.


  12. Compliance Education.  Captain Integrity explains that ongoing education is needed so that everyone understands compliance risks due to the complexity of health care rules and regulations.





Monthly Cartoon Strip Topics
Fourth 12 Months
  1. Individual vs. Group Therapy Billing.  Captain Integrity explains that the billing regulations for individual vs. group therapy services have to be followed. Captain Integrity encourages employees to contact their compliance officer for clarification on specific regulations.


  2. Physician Recruitment.  Captain Integrity states that hospitals cannot require a physician to refer patients to their organization as part of a recruitment arrangement between the physician and the hospital.


  3. Physician Gifts and Benefits.  Captain Integrity explains that gifts to physicians have to be tracked and are limited to $373* per physician each year. *Limit increases each year.


  4. Conflict of Interest.  Captain Integrity emphasizes that management cannot use their positions within the organization to reward family and friends with vendor contracts or sales.


  5. Advance Beneficiary Notice ("ABN").  Captain Integrity explains that patients should be asked to sign an ABN if their physician's reason for ordering their test or procedure does not meet medical necessity guidelines.


  6. Co-Pay Waiver.  Captain Integrity emphasizes that health care organizations should not waive co-pays or deductibles unless there is a financial need.


  7. Fraud.  Captain Integrity explains that physicians cannot create false documentation to assist patients in qualifying for Medicare coverage or other benefits they would not otherwise be entitled to receive.


  8. HIPAA.  Captain Integrity confirms that it is not a HIPAA violation for a physician to obtain copies of a patient's medical record if they are using the record in providing treatment to the patient.


  9. Financial Accounting.  Captain Integrity cautions health care organizations to ensure the accuracy of their financial reporting process.


  10. Duplicate Billing.  Captain Integrity confirms that once an overpayment is identified, a review and repayment are required.


  11. Physician Supervision.  Captain Integrity reminds us that physician supervision requirements for health care procedures or services must be followed.


  12. Fair Market Value Documentation.  Captain Integrity encourages health care providers to document why each financial arrangement with referral sources are fair market value.






CAPTAIN INTEGRITY • 100 North Michigan * South Bend, IN • 46601
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