This Week in Corporate Compliance


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National Conferences

SCCE 10th Anniversary video

Clinical Practice Compliance Conference
October 12 - 14, 2014
Philadelphia, PA

Register by August 19 and save $300

Compliance Academies

August Basic Compliance Academy
August 4 – 7, 2014
New York, NY

September Basic Compliance Academy

September 29 – October 2, 2014
Nashville, TN

October Basic Compliance Academy
October 20 – 23, 2014
Las Vegas, NV

October Basic Compliance Academy
October 27 – 30, 2014
Chicago, IL

November Basic Compliance Academy
Limited Seats Remain
November 17 – 20, 2014
Lake Buena Vista, FL

December Basic Compliance Academy
December 1 – 4,2014
San Diego, CA

Research Academy

November Research Basic Compliance Academy
November 3 – 6, 2014
Orlando, FL

Privacy Academy

September Health Care Privacy Basic Compliance Academy
September 8 – 11, 2014
San Francisco, CA

November Health Care Privacy Basic Compliance Academy
November 3 – 6, 2014
Orlando, FL

Regional Conferences

2014 Regional Conference Prospectus Available

New England Regional Conference
September 12th, 2014
Boston, MA

Upper Midwest Regional Conference
September 19th, 2014
Minneapolis, MN

Midwest Regional Conference
September 29th, 2014
Overland Park, KS

North Central Regional Conference
October 6,2014
Indianapolis IN

East Central Regional Conference
October 10,2014
Pittsburgh PA

Hawaii Regional Conference
October 16 - 17, 2014
Honolulu HI

Mountain Regional Conference
October 24, 2014
Denver CO

Mid Central Regional Conference
November 7, 2014
Louisville KY

Desert Southwest Regional Conference
November 14, 2014
Scottsdale AZ

South Central Regional Conference
November 21, 2014
Nashville TN

View a Full List of 2014
Regional Conferences

Click Here


Looking for updated HIPAA Training Options?

HCCA HIPAA Training Guide

3rd edition

a brief handbook for frontline healthcare workers Learn more

HIPAA Rules & Compliance

a DVD produced by
Coastal Training/DuPont

Click here to learn more

Research Compliance Professional’s Handbook, Second Edition

This new edition of the handbook offers comprehensive, up-to-date guidance to get you on the right track.
Click here to buy now

The Health Care Compliance Professional’s Manual

The Health Care Compliance Professional's Manual Covers everything you need to plan and execute a customized compliance program that meets federal standards.

Covers everything you need to plan and execute a customized compliance program that meets federal standards. A quarterly update subscription keeps you current. Click here for a brochure and fax order form

The Health Care Privacy Compliance Handbook

This book helps privacy professionals sort through the complex regulatory framework and significant privacy issues that health care organizations face.
Click here to buy now

Compliance and Ethics: An Introduction for Health Care Professionals

Compliance and Ethics: An Introduction for Health Care Professionals

HCCA’s 23-minute video and trainer’s guide provides everything you need to conduct training for new employee orientations and staff refreshers.
Click Here to Buy Now

Web Conferences

Counterfeit Medicine, Careful Compliance
July 29, 2014

"They do the Crime, You do the Time"
August 4, 2014

HIPAA Audits: Are You Ready for the Next Wave?
August 7, 2014

What Compliance Officers Need to Know About Human Research Regulations
August 11, 2014

Are Practices Ready for Cyber Attacks?
August 12, 2014

Biosafety to Bedside: Human Gene Transfer Research Considerations in Healthcare Compliance
August 13, 2014

Inside the Halifax Case: A Discussion with the Government’s Expert Witness
August 19, 2014

Are you ready for an FDA Inspection? Preparing Research & Medical Staff for an FDA visit.
August 20, 2014

Risk Adjustment Data Validation Audit (RADV) Readiness
August 25, 2014

Management and Oversight of Research Compliance at Predominantly Undergraduate Institutions (PUIs)
August 26, 2014

The Latest Stark Law Developments: New Theories, New Risks, New Issues
August 27, 2014

View our List of 2014 Web Conferences Click Here

Order Past HCCA Web Conferences Click Here

This Week’s HCCA Corporate Members

Click here to see more

SAI Global Compliance

ServarusRM provides risk management services with the goal of helping our clients minimize the adverse effects of facility incurred injuries or accidents through the implementation of facility specific risk management strategies.

Providing innovative reimbursement and compliance solutions for 
 the healthcare community.

Vol. XVI, No. 30
July 25, 2014


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HCCAnet, HCCA’s Compliance & Ethics Social Network: What’s Being Talked About

This Week’s Headlines – July 25, 2014

Owner and administrator of Miami home health companies pleads guilty for role in $74 million health care fraud scheme

Court halts $4 billion privacy suit against Sutter Health

Undercover probe finds Obamacare vulnerable to fraud

Alabama hospital system and physician group agree to pay $24.5 million to settle lawsuit

Hopkins agrees to pay $190 million to settle Levy claims

Owner of Virginia MedSpa sentenced for illegally importing non-FDA-approved drugs and using on patients

Three indicted in insurance fraud scheme

Dignity Health agrees to pay $1.55 million in civil penalties to resolve controlled substances act claims

This Week’s Links

Regulatory News

HHS announces availability of $11 million to better integrate HIV services into community health centers

CMS Update

In the Federal Register

CMS Transmittals

From the OIG

Acronym Library

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Owner and administrator of Miami home health companies pleads guilty for role in $74 million health care fraud scheme
On July 23, 2014, Assistant Attorney General Leslie R. Caldwell of the Justice Department’s Criminal Division announced, “A Miami resident who owned a home health care company and was the administrator of another home health care company, pleaded guilty today for her participation in a $74 million Medicare fraud scheme.”

The government press release noted, “According to court documents, Elsa Ruiz was an owner of Professional Home Care Solutions Inc. (Professional Home Care) and an administrator of LTC Professional Consultants Inc. (LTC), Miami home health care agencies that purported to provide home health and therapy services to Medicare beneficiaries.  Ruiz and her co-conspirators operated LTC and Professional Home Care for the purpose of billing the Medicare program for, among other things, expensive physical therapy and home health care services that were not medically necessary and/or were not provided.” For more


Court halts $4 billion privacy suit against Sutter Health

On July 21, 2014, the Sacramento Bee reported, “A state appellate court Monday ordered the dismissal of a lawsuit that could have cost Sutter Health more than $4 billion when it ruled that millions of the health care giant’s patients had no right to sue over the theft of a computer with their personal, medical and insurance records on its hard drive.” For more


Undercover probe finds Obamacare vulnerable to fraud
On July 22, 2014, USA Today reported, “Congressional investigators using fake identities were able to obtain taxpayer-subsidized health insurance under President Obama's law, according to testimony to be delivered Wednesday.” For more | GAO Testimony


Alabama hospital system and physician group agree to pay $24.5 million to settle lawsuit
On July 21, 2014, the U.S. Department of Justice announced, “Mobile, Alabama-based Infirmary Health System Inc. (IHS), two IHS-affiliated clinics and Diagnostic Physicians Group P.C. (DPG) have agreed to pay the United States $24.5 million to resolve a lawsuit alleging that they violated the False Claims Act by paying or receiving financial inducements in connection with claims to the Medicare program.”

According to the government press release, “The government’s suit alleged that two IHS affiliated clinics -- IMC-Diagnostic and Medical Clinic, in Mobile, and IMC-Northside Clinic, in Saraland, Alabama -- had agreements with DPG to pay the group a percentage of Medicare payments for tests and procedures referred by DPG physicians, in violation of the Physician Self-Referral Law (commonly known as the Stark Law) and the Anti-Kickback Statute.  Also named in the lawsuit was Infirmary Medical Clinics P.C. (IMC), an affiliate of IHS that directly owns and operates approximately 30 clinics in the Mobile area, including the two clinics involved in this lawsuit.” For more


Hopkins agrees to pay $190 million to settle Levy claims
On July 21, 2014, The Baltimore Sun reported, “Johns Hopkins Hospital has agreed to pay $190 million in a proposed settlement over claims that gynecologist Dr. Nikita A. Levy surreptitiously recorded patients over the course of several years, the lead attorney in the class-action lawsuit announced.”

According to the newspaper report, “Levy, a doctor in the Johns Hopkins Community Medicine system since 1988, took his life in February 2013 amid an investigation which revealed he was using tiny cameras — concealed in pens and key fobs — to record patients.” For more


Owner of Virginia MedSpa sentenced for illegally importing non-FDA-approved drugs and using on patients
On July 18, 2014, U.S. Attorney for the Eastern District of Virginia Dana J. Boente announced, “Anoushirvan Sarraf, 48, of Rockville, Maryland, the owner and operator of Aphrodite Advanced Esthetic & Skin Care Clinic (Aphrodite) in McLean, Virginia, was sentenced today to 18 months in prison and 2 years of supervised release.” For more


Three indicted in insurance fraud scheme
On July 16, 2014, U.S. Attorney’s Office for the District of Central California announced, “A federal grand jury today indicted three Southern California residents in a scheme to defraud health insurance programs by submitting bills for more than $50 million in medically unnecessary medical procedures performed on insurance beneficiaries who received free or discounted cosmetic surgery.

“The indictment outlines a scheme in which marketers or cappers lured patients to a surgery center in Orange known at various times as Empire Surgical Center, Vista Surgical Center and Princess Cosmetic Surgery. The marketers told patients that they could use their union or PPO health insurance plans to pay for cosmetic surgeries, which are generally not covered by insurance.” For more


Dignity Health agrees to pay $1.55 million in civil penalties to resolve controlled substances act claims
On July 16, 2014, the U.S. Attorney for the Eastern District of California Benjamin Wagner announced, “Dignity Health, California’s largest hospital provider and the country’s fifth largest health system, has agreed to pay the United States $1.55 million to settle claims of deficiencies regarding the handling of controlled substances at its hospitals and clinics.  Dignity Health will pay $1,250,000 immediately, and the remaining $300,000 will be deferred pending Dignity Health’s compliance over the next two years with a detailed action plan.” For more


This Week’s Links

Associated Press: “Head of troubled CDC anthrax lab has resigned” For more

FiercePharma: “Judge refuses to toss off-label Revlimid marketing lawsuit against Celgene” For more

The SFGate: “Court: Whistleblower law doesn't protect interns” For more

FDA: FDA announces voluntary nationwide recall of all non-expired sterile drugs from Unique Pharmaceuticals For more

GAO: Medicaid Payment: Comparisons of Selected Services under Fee-for-Service, Managed Care, and Private Insurance. GAO-14-533, July 15. For more

HCCA Video of the Week: Victoria Herring, Board Member, Board of Trustees, Des Moines University - “Board Oversight” For more


MediRegs is a pioneer in Ethics, Compliance and Regulatory Information Management. With more than 500 organizations using MediRegs already, you can confidently empower your team with our ADVantage ArchitectureSM.This week, MediRegs provided TWCC readers with the following: In the Federal Register, CMS Transmittals, and From the OIG.

Regulatory News

HHS announces availability of $11 million to better integrate HIV services into community health centers
On July 15, 2015, HHS Secretary Sylvia M. Burwell announced in a press release, “the availability of $11 million, through the Affordable Care Act and the Secretary’s Minority AIDS Initiative Fund, to support the integration of high‐quality HIV services into primary care through innovative partnerships between health centers and state health departments in Florida, Massachusetts, Maryland and New York.  This initiative supports the goals of the Administration’s National HIV/AIDS Strategy.” For more


CMS Update

Webinar/Conference Call Session
Wednesday, July 30 – 3-4 pm ET
PERM Cycle 3 Provider Education
CMS is hosting Payment Error Rate Measurement (PERM) provider education webinar/conference calls for Medicare providers who also provide Medicaid and CHIP services. Complete details are available in the webinar announcement.
FYI—Cycle 3: Alaska, Arizona, District of Columbia, Florida, Hawaii, Indiana, Iowa, Louisiana, Maine, Mississippi, Montana, Nevada, New York, Oregon, South Dakota, Texas, and Washington.

Registration is not required, space is limited

Dates & Times of Upcoming National Provider Calls
Registration is now open for the following CMS Calls:

-Tuesday, August 19, 2014; 1:30 PM - 3:00 PM ET - National Partnership to Improve Dementia Care in Nursing Homes: Improved Care Transitions

To register- To receive call-in information, you must register for calls on the CMS Upcoming National Provider Calls registration website. Space may be limited, register early. Registration will close at 12pm on the day of the call or when available space has been filled; no exceptions will be made, so please register early.

The presentation for calls will be posted on the FFS National Provider Calls web page. A link to the slide presentation will be emailed to all registrants on the day of the call.

Visit the Continuing Education Credit Notification web page for continuing education information

Comment Period Has Begun for CY 2015 Physician Fee Schedule Proposed Rule
The 2015 Physician Fee Schedule proposed rule was made available for comment on July 11. This proposed rule includes provisions for Relative Value Units (RVUs) for CY 2015 and other Medicare Part B payment policies to ensure that payment systems are updated to reflect changes in medical practice and the relative value of services.

The proposed rule also includes new provisions and updates, including policies related to:

  • Ambulance fee schedule
  • Physician Compare
  • Physician Quality Reporting System (PQRS)
  • Medicare Shared Savings Program
  • Value-Based Payment Modifier and Physician Feedback Program

PQRS Provisions
The proposed requirements for PQRS focus primarily on the 2017 PQRS payment adjustment, which is based on quality measures reporting data from the reporting period January 1, 2015 to December 31, 2015.

CMS is accepting comments on the proposed rule until 5pm ET on September 2, 2014. Instructions for submitting comments on this proposed rule are available on

Correction to SNF Consolidated Billing Code Lists
Certain Healthcare Common Procedure Coding System (HCPCS) codes were not included in the 2014 annual update to the Skilled Nursing Facility (SNF) consolidated billing code editing lists. A correction to the coding lists will be implemented in October, 2014. The affected HCPCS codes for practitioner billing are Q2050 and the professional component of G0461 and G0462. The affected code for institutional provider billing is Q2050. If you have claims that have been erroneously denied, you should contact your Medicare Administrative Contractor to have the claims re-opened and re-processed

New from MLN

“Internet-based PECOS Contact Information” Fact Sheet — Revised


In the Federal Register

Proposed rule: Medicare and Medicaid Programs: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Physician-Owned Hospitals: Data Sources for Expansion Exception; Physician Certification of Inpatient Hospital Services; Medicare Advantage Organizations and Part D Sponsors: Appeals Process for Overpayments Associated With Submitted Data
As stated by CMS:
"This proposed rule would revise the Medicare hospital outpatient prospective payment system (OPPS) and the Medicare ambulatory surgical center (ASC) payment system for CY 2015 to implement applicable statutory requirements and changes arising from our continuing experience with these systems. In this proposed rule, we describe the proposed changes to the amounts and factors used to determine the payment rates for Medicare services paid under the OPPS and those paid under the ASC payment system."

Proposed Rule: Medicare and Medicaid Programs: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center.. 40915-41083 [2014-15939]


CMS Transmittals

2014 Transmittals and MLN Matters:

Program Integrity (PUB. 100-08)

CMS One-Time Special Notification (PUB. 100-20)


From the OIG

Podcasts, Spotlight Articles, Videos and Related Materials
OIG Videos - Last Updated: 07/18/2014

Audit Report
The University of North Carolina at Chapel Hill Did Not Always Claim Selected Costs Charged Directly to Department of Health and Human Services Awards in Accordance with Federal Requirements (A-04-13-01024) (06/27/2014) (PDF)


Acronym Library

LCL Lowest Charge Levels
LIL Limitation of Liability
LMRP Local Medical Review Policy 

Click here for more from CMS Acronyms


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Contact: Margaret Dragon, Editor, This Week in Corporate Compliance: 781-593-4924

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