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Kusserow’s Corner: Can the Entire Sanction-Screening Process be Outsourced?

This is a question that is frequently asked of me and the answer is yes. Vendors can not only provide an organization with sanction screening tools but some will conduct the screening on behalf of the...

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Kusserow’s Corner: Using Vendors to Supplement the Compliance Program

As the job of Compliance Officers has grown in demands and complexity, it has become increasingly common for them to explore whether it makes sense to outsource elements of the compliance program....

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Kusserow’s Corner: How to Evaluate and Select a Hotline Vendor

By definition, all effective compliance programs should have a hotline.  It is an important avenue of communication between employees and management, in that it permits employees to report sensitive...

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Kusserow’s Corner: Outsourcing the HIPAA Privacy Officer

Under HIPAA, every covered entity, health care provider, health plan, or clearing house must have a Privacy Officer (PO). The duties and responsibilities are formidable and require a wide knowledge and...

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Kusserow on Compliance: Co-Sourcing Series: Compliance in-sourcing,...

There has been considerable discussion and questions raised about approaches taken by health care organizations for the best way to meet the great challenges of maintaining an effective compliance...

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Kusserow on Compliance: Common co-sourced functions used by compliance officers

Co-sourcing has evolved as the preferred method by which Compliance Officers move to meet ever increasing obligations with limited staff resources. It really is a third option between trying to do...

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Kusserow on Compliance: Co-sourcing benefits to compliance officers

More and more compliance officers seek ways to supplement their limited in-house resources and have found co-sourcing as a means to meet the challenges of the program. For many, the additional...

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Kusserow on Compliance: Tips on information security from the FTC

The health care sector is so focused on Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy and Security related issues under the watchful eyes of CMS and the Office of Civil...

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Kusserow on Compliance: Codes of conduct part 1—Meeting the challenge of...

Without question, one of the basic foundations of any effective compliance program is the code of conduct. All compliance guidance from the U.S. Sentencing Commission to the HHS Office of Inspector...

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Kusserow on Compliance: Tips for getting the most from your CIA

This was the title of a section in a presentation by Laura Ellis, HHS Office of Inspector General (OIG) Senior Counsel, at the recent Health Care Compliance Association (HCCA) Compliance Institute,...

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Kusserow on Compliance: Engaging experts to supplement and assist compliance...

Most compliance offices are swamped with work. Sometimes it is a periodic rush to meet some urgency, while at other times there is just too much to be done with too little to meet all challenges in the...

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Kusserow on Compliance: 4 out of 5 organizations under 1,000 employees...

It is estimated that over 80 percent of health care organizations with fewer than 1,000 employees overpay their hotline vendor. The reasons for this vary.  For large scale vendors, higher overhead may...

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Kusserow on Compliance: OIG issues first 2017 Semi-Annual report—1,422...

The OIG released is first semi-annual report for 2017 which included the number of exclusion actions taken. There were a total of 1,422 individuals and entities they excluded from Medicare, Medicaid,...

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Kusserow on Compliance: Effective hotline programs

All healthcare organizations need confidential compliance communication channels. First and foremost among them is a hotline. By definition, all effective compliance programs should have a hotline. It...

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Kusserow on Compliance: Extending and economizing compliance programs—tools,...

Compliance officers are confronted with a host of ever increasing external regulatory and internal demands with most having inadequate resources to meet all the challenges.  Furthermore, it is becoming...

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Kusserow on Compliance: Use of temporary compliance and privacy officers

By now every health care provider is aware of the need for an effective compliance program under direction and management by a compliance officer, as well as a privacy officer to ensure HIPAA...

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Kusserow on Compliance: Using experts to staff gaps in the compliance office

It is becoming increasingly common for changes in compliance programs to lead to “gaps” that can leave an organization without day to day management or support. This can result in serious problems and...

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Kusserow on Compliance: Measuring the compliance culture

The OIG, DOJ, and other oversight agencies believe the compliance program should be a change agent in promoting a culture of compliance that creates an environment less likely to have regulatory or...

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Kusserow on Compliance: Temporary staffing and interim compliance officers

When individuals from a compliance office, including compliance officers, retire, move to new organizations, or are replaced for any reason, it can leave a gap in the day to day management of the...

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Kusserow on Compliance: Using sanction-screening tools vs. outsourcing the...

In order to save time and costs, more and more health care organizations have been moving to outsource functions that are not core business activities. Compliance programs have been part of that trend:...

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