DRAFT: This module has unpublished changes.

My Work

 

 

Week 10 Individual Assignment

Risk Assessments, Work Plans, and Compliance Programs

You have just graduated from the George Washington University Milken Institute School of Public Health with a Master of Health Administration degree and have accepted a position as management and compliance professional with Health R Us Hospital System (“System”). You will be the first compliance professional for the System, a large for-profit health system that owns and operates acute care hospitals in 33 states and Puerto Rico. Most recently, the System’s General Counsel, Mr. James Dean, has been “responsible” for compliance issues. There is no formal or informal compliance program in place. Although the System CEO, Mr. Joe Felony, thinks compliance programs are a waste of time, energy and money, the System’s recent receipt of a subpoena from the U.S. Department of Health and Human Services Office of Inspector General (“OIG”), has Mr. Felony reconsidering his position. Based on a quick read, Mr. Felony senses the OIG is interested in the System’s relationships with its physicians, particularly some recruiting and lease arrangements, and billing processes. On your first day at the System’s home office (in Las Vegas, Nevada), Mr. Felony and Mr. Dean inform you that your main task will be to develop and implement a compliance program that will placate the OIG without being overly burdensome for the System (financially or otherwise).

 

 

Week 1 & 2  Individual Assignment:

Final Rule Summary, Purpose & Differences between the NPRM & Final Rule. 

 

 

 

Group Assignment Module 7 Week 8

Federal Anti-Kickback Statute
Your group is to assume that you are members of the compliance department in a large hospital system. Working in your groups, develop a checklist for either the Federal Anti-Kickback Statute or the Stark Law (as assigned below) that you could use to review certain arrangements for potential violations. In your checklists, focus on the elements referenced below.

 

DRAFT: This module has unpublished changes.