We are pleased to announce that Alyssa Cunningham has been appointed to the role of Assistant Vice President for Healthcare Compliance and Privacy. Alyssa is an experienced lawyer with 14 years of concentrated health care law, compliance and privacy experience, who joined UConn Health’s Office of the General Counsel in 2017. With the health care regulatory environment constantly changing, Alyssa’s legal experience, knowledge of UConn Health, and expertise in the areas of health care compliance and privacy will prove extremely valuable.

Alyssa will lead both the Office of Healthcare Compliance and the Office of Privacy Protection and Management.

As a reminder, the Office of Healthcare Compliance works to ensure compliance with federal and state laws and regulations as well as University policies. Healthcare compliance at UConn Health encompasses patient care, billing and reimbursement practices and employee and student education. The Office of Privacy Protection and Management at UConn Health serves as a central resource for healthcare privacy-related matters and assists with navigating applicable rules and best practices to protect the privacy rights of our patients and other constituents.

 

Open Payments, also known as The Sunshine Act, is a national disclosure program that promotes a more transparent and accountable health care system by making the financial relationships between applicable manufacturers and group purchasing organizations (GPOs) and health care providers (physicians and teaching hospitals) available to the public.

CMS is aware that the COVID-19 pandemic is greatly impacting the healthcare community as a whole and understands the tireless work of its healthcare providers this time. However, due to statutory limitations, CMS does not have the authority to postpone the review and dispute period of April 1-May 15, 2020.

The review and dispute period for physicians and teaching hospitals remains April 1-May 15, 2020. In order to complete the review and dispute process, covered recipients must register in the Open Payments system.

Covered Recipients have until December 31, 2020 to initiate disputes of data published in 2020. If a new dispute is initiated after the 45-day review and dispute window (April 1-May 15), it will be published as original attested-to data in the initial data publication.

A comprehensive list of frequently asked questions about the Open Payments program is provided on the CMS website. These FAQs are reviewed and revised as needed in order to support the implementation of the program.

 

Today the regulatory landscape in healthcare is changing in response to the unique circumstances of the COVID-19 public health crisis. In addition, UConn Health has had to quickly adapt how it provides patient care in order to protect both our staff and patients. One of these areas of changing regulations and adaption is providing care through virtual medicine formats such as eVisits and telehealth. So what is the difference between an eVisits and telehealth?

Q: What is an eVisit?

A: eVisits are patient initiated communications with their provider through an online patient portal such as MyChart. eVisits require evaluation, assessment, and management of the patient.

Q: What is telehealth?

A: Telehealth consists of a real time communication between the provider and patient using an interactive audio and video telecommunications system which the provider initiates.

Other forms of virtual medicine include telephone or audio only communications, remote image evaluations and virtual check-ins. All types of virtual encounters let the patient communicate with their provider without having to come into the office. Although these encounters are not done onsite, the same documentation principles remain. 

Guidance on reimbursement and/or payment for these services is changing rapidly. Staff at UConn Health are working hard to make sure that these changes are being addressed behind the scenes to ensure the least amount of disruption for our providers. Providers who have documentation and coding questions can email codinghelp@uchc.edu for assistance.

As a recipient of financial reimbursement from the federal and state government for medical services provided to Medicare and Medicare patients, UConn Health is subject to the many laws that govern the Medicare and Medicaid programs. To help our employees navigate through these rules, the Office of Healthcare Compliance launched a healthcare specific training on December 20, 2019. This training is in addition to the University Compliance training, which focuses on institution-wide compliance topics, like the Code of Conduct and the State Code of Ethics. The Healthcare Compliance training includes an overview of the prevention of fraud, waste and abuse, financial conflicts of interest in healthcare and other top healthcare compliance topics.

Because Uconn Health is a diverse environment not every topic in the training will apply to all. However, all employees should be aware of certain healthcare compliance topics to be sure that the institution supports a culture of compliance.

If you have not yet competed the training, log into the Saba Online Learning Center and access “My Learning”. The Healthcare Compliance trainings are titled:

• 2019 Annual Healthcare Compliance Training
• 2019 Compliance Risks and Strategies

The training’s deadline for completion is March 19, 2020. Failure to complete the training by the deadline could result in disciplinary action, up to and including dismissal.

The Privacy Office and the Office of IT Security annual trainings share the deadline of March 19 for training completion. Please be sure to also complete:

• 2019 Security Awareness Training
• 2019 HIPAA Privacy Training

Academic medical centers operate in a complex and highly regulated environment governed by a plethora of federal and state laws and regulations. As such, the establishment of an effective compliance and ethics program is necessary to adequately and responsibly safeguard institutions and carry out their various ethical, legal and fiduciary responsibilities. As a condition of participation, many federal programs, such as Medicare and Medicaid, mandate comprehensive compliance and ethics programs.

In addition to meeting its legal requirements of having an effective compliance and ethics program, the Office of Healthcare Compliance and the Office of University Compliance work together to prevent and detect compliance violations, mitigate damaging and costly risks, and promote a culture of compliance and ethics across all the University’s campuses.

Summarized herein, are some of the foundational elements of an effective compliance program, which are based on Chapter 8 of the Federal Sentencing Guidelines for Organizations.

1. Standards, Policies, and Procedures – Establish standards and procedures to prevent and detect criminal conduct and facilitate compliance.

2. Oversight and Accountability – Ensure high level personnel exercise reasonable oversight with respect to the implementation and effectiveness of the compliance and ethics program, and are knowledgeable about the content and operation of the program. Specific individual(s) within high-level personnel (e.g., Chief Compliance Officer) shall be assigned overall responsibility for the compliance and ethics program.

3. Performance of Due Diligence – Use reasonable efforts not to include any individual who the organization knew or should have known (through due diligence) to be engaged in illegal activities or conduct inconsistent with an effective compliance and ethics program.

4. Education and Communication – Establish effective training and education programs and take reasonable steps to communicate standards, procedures, roles and responsibilities, as well as other aspects of the program to members of the institution, including the governing authority, high level personnel, substantial authority personnel, organization employees, and the organization’s agents (as appropriate).

5. Internal Monitoring and Auditing – Take reasonable steps to ensure the compliance and ethics program is followed by monitoring and auditing to detect criminal activity, non-compliance, and program effectiveness, as well as establish and publicize a mechanism that allows for anonymous and confidential reporting without fear of retaliation.

6. Incentives and Enforcement – Consistently promote and enforce standards through appropriate incentives, as well as disciplinary measures for engaging in criminal conduct and/or failing to take reasonable steps to prevent or detect criminal conduct.

7. Response to Incidents – Take reasonable steps to appropriately respond to criminal conduct/non-compliance, and to prevent further similar conduct from occurring in the future, including any modifications to the organizations compliance and ethics program.