Awareness : Compliance Tips

The New UHealth Patient Transportation Policy

On June 21, 2018, the University of Miami Health System (“UHealth”) approved their newly revised Patient Transportation Policy. This revised policy now includes language from the Office of Inspector General’s (“OIG”) Final Rule, which codified the Local Transportation Safe Harbor to the Anti-Kickback Statute (effective January 6, 2017).

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Regulatory Compliance Tip for August 2018

Which Gifts If Any Are UHealth Employees Allowed to Receive and Give?

In a continuing effort to keep University of Miami Health System (“UHealth”) employees informed of the latest UHealth policies, UHealth Compliance, Office of Regulatory Compliance (“ORC”) recommends that you review the recently enacted Cash and Non-Cash Patient Gift Policy1 , which is now available on PolicyStat.

The purpose of this policy is to comply with all federal and state laws governing gifts that are offered or accepted by UHealth professionals, including the Federal Anti-Kickback Statutes2 and Federal Civil Monetary Penalties Law (“CMP”).

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Regulatory Compliance Tip for July 2018

Regulatory Requirements for Physician Compensation Agreements

Over the last several years, the federal government has continued to focus their efforts on the relationships between hospitals and physicians to ensure they meet regulatory requirements. Compensation agreements between a physician and a hospital must be structured to comply with the Physician Self-Referral Law, also known as the “Stark Law”.

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Regulatory Compliance Tip for June 2018

Caution with Consulting Agreements

On Friday, March 16, 2018, five New York City Doctors were charged with taking Kickbacks from a pharmaceutical company in exchange for prescribing Fentanyl, an opioid that is 50 to 100 times more potent than morphine.

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Regulatory Compliance Tip for May 2018

UHealth’s Approval Process for Policies, Procedures, and Guidelines

As we previously communicated in November 2017, the University of Miami Health System (“UHealth”) partnered with The Greeley Company in a Policy Project to harmonize policies across the health system in order to decrease duplication, increase clarity and promote uniform implementation. The oversight process involved the creation of the Policy Steering Committee with the policy implementation being supported by the Change Management Support Subcommittee.

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Regulatory Compliance Tip for April 2018

Case Study: Why Conflict of Interest Matters

Physician (“Physician”) had several consulting arrangements with various pharmaceutical companies. Physician did not disclose the extent of the relationships to either the physician’s direct supervisor, nor did the physician disclose the relationship via the UDisclose Program; as required by University policy.

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Regulatory Compliance Tip for March 2018

New Year’s resolutions for a compliant workplace

What to do and not to do in the workplace to help us stay compliant

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Regulatory Compliance Tip for February 2018

New Policy Approval Process at UHealth

The University of Miami Health System partnered with The Greeley Company to develop state-of-the-art governance documents for the medical staff.

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Regulatory Compliance Tip for November 2017

What is the difference between a policy, a procedure and a guideline?

What is the difference between a Policy, Procedure and a Guideline?

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Regulatory Compliance Tip for November 2017

Teaching Physician Requirements When Participating in Overlapping Surgeries

Pursuant to CMS regulations, in order to bill Medicare for two overlapping surgeries, the teaching physician must be 1) present during the critical or key portions of the procedure, and 2) be immediately available to furnish services during the entire procedure. The critical or key portions of each surgery may not take place at the same time.

Conflict of Interest – Interactions with Vendors

A topic in the health care industry that continues to be of interest amongst the regulators and media is conflicts of interest – particularly with vendor relations.
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Regulatory Compliance Tip for September 2017

Stark Law and Anti-Kickback Statute

The Stark Law also known as the “Physician Self-Referral Statute”, prohibits a physician from making referrals for certain designated health services.
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Regulatory Compliance Tip for August 2017

The Emergency Medical Treatment and Labor Act (EMTALA)

The Emergency Medical Treatment and Labor Act (EMTALA) was enacted by Congress in 1986 to ensure public access to emergency services, regardless of a patient’s ability to pay.
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Regulatory Compliance Tip for July 2017

If a Patient Signs a Written Consent Form, Have the Requirements for Informed Consent Been Met?

Not necessarily. Often times, healthcare providers believe that if a patient signs a written consent form, adequate informed consent has been provided. However, a signed consent form by itself is NOT conclusive, it is just another piece of evidence that informed consent might have been given.
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Regulatory Compliance Tip for June 2017