The healthcare regulatory environment is ever evolving and perennially complex. Whether the client’s need is proactive or reactive, VantagePoint offers expert solutions focused on helping healthcare organizations of any type meet their compliance obligations.
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Provider Coding and Clinical Documentation Compliance Audits
Proactive coding and clinical documentation audits are an essential element of any healthcare organization’s compliance work plan. Coding and clinical documentation audits performed by a qualified outside entity also contribute to revenue integrity. VantagePoint’s core expert team of nurses and certified coders is available to conduct periodic or ongoing coding and documentation audits to identify up-coded or down-coded claims, ICD-10 coding accuracy, appearance of copy/paste or cloning and the contribution of EHR templates to documentation related audit findings.
Integrity Agreement Monitoring (IRO) Services
Healthcare Organizations entering into Corporate Integrity Agreements (CIA) with the HHS OIG are often required to engage an Independent Review Organization (IRO). VantagePoint is an experienced IRO, serving in this role for a diverse array of healthcare provider types, including behavioral health, substance use disorder treatment providers, home health, hospital, and independent physicians. We utilize the OIG-approved RAT-STATS statistical sampling software, have in-house expertise to conduct audits per CIA Appendix specifications, and we provide well-written reports that meet OIG expectations. Beyond satisfying the specific requirements of the CIA, a qualified and independent entity like VantagePoint can provide an objective assessment of internal processes and actional recommendations for improvement as part of an annual or quarterly claims or arrangement review report requirement.
Healthcare Mergers and Acquisitions Compliance Due Diligence
When conducted at an early stage, VantagePoint’s compliance-focused due diligence review allows the investors and buy side team to make informed adjustments to the terms of the transaction. Our healthcare compliance subject-matter expertise can be leveraged to review the effectiveness of the seller’s compliance program, claim audit risks, financial relationships with physicians, and applicability of Stark Law exceptions and anti-kickback safe harbors. Other common compliance due diligence concerns can be explored in greater detail through targeted billing and coding reviews, HIPAA security risk assessments, penetration testing, and vulnerability scans.
Compliance Program Development
The Federal Sentencing Guidelines outline the 7 elements of a compliance program. VantagePoint supports healthcare providers and organizations of any size or specialty in developing an appropriately scaled, sustainable compliance program based on the 7 elements and grounded in healthcare specialty and organization specific risks.
Compliance Program Effectiveness Assessment
VantagePoint’s Compliance Program Effectiveness Assessments are differentiated by our collaborative approach. Our expert consultants work with both compliance and operational leadership to perform an independent assessment against the 7 elements of an effective program. We examine program design, operational applications, and whether a program as documented actually works in practice. VantagePoint’s Compliance Effectiveness Assessments include comprehensive documentation review, on-site verification and interviews, a formal final report including an executive summary, detailed findings and observations; and operational action plan. Implementation support is an optional and popular add-on service.
Virtual Compliance, HIPAA Privacy and Security Officer Services
VantagePoint expert general healthcare compliance and HIPAA privacy and security resource personnel are available for healthcare providers and organizations requiring interim or on-going remote support.
HIPAA Privacy and Security Compliance Services
As a compliance-focused healthcare consultancy with over 25-years of experience, HIPAA compliance services have been a core VantagePoint offering since the implementation of the Privacy and Security rules. Any HIPAA related compliance service needed by a Covered Entity or Business Associate to comply with the HIPAA Privacy, Security and Breach Notification Rules is within VantagePoint’s wheelhouse. Whether the need is as simple as new hire and annual staff HIPAA training programs or policy and procedure development; or as complex as a security risk analysis or managing the response to a significant reportable breach, VantagePoint has a solution.
Business Associate Agreement (BAA) Audits
Larger and complex healthcare organizations are often challenged to keep track of even the most basic, high level BAA oversight. Lack of BAA management introduces notable risks when a security breach involving ePHI occurs. BAA audits are a time consuming, but necessary element of a robust HIPAA compliance program. Given most healthcare organizations do not have the internal resources or expertise to take on a BAA audit project internally, VantagePoint Healthcare Advisors offers a full array of BAA services, including basic, enhanced and full support options for analyzing, remediating, and auditing any covered entity or business associate’s inventory of BAAs.
Physician Arrangement Reviews
Arrangements with physicians are among the highest compliance risk areas for healthcare organizations. VantagePoint expert compliance consultants are adept at performing physician arrangement reviews for Stark and Anti-kickback (AKS) compliance, physician payment reconciliation reviews, and medical director arrangement/documentation reviews for existing arrangements. VantagePoint can also assist organizations seeking to implement an arrangements tracking system, as well as a process to log gifts and other non-monetary compensation to physicians in compliance with the Stark law.
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