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Corporate
Compliance
Solutions
Enhancing Your
Compliance Initiatives
2
Mastering the Dynamics of Change
Every day, the senior executives and board members of more than
4,000 healthcare organizations turn to PricewaterhouseCoopers for
support in enhancing performance, building financial strength and
protecting their reputations.
PricewaterhouseCoopers healthcare practice draws on the
experience of an international organization that includes clinical
and business leaders—and more physicians than any other Big
Five firm. Because we’re committed to healthcare, we continually
invest in our people and knowledge. In addition to physicians, our
healthcare practice includes nurses, information system specialists,
management consultants, health policy analysts, actuaries,
financial advisors and data analysts, who provide our clients with
unmatched industry expertise.
Our Healthcare Regulatory Group is the world’s largest regulatory
practice serving integrated delivery systems, hospitals, physician
practices, managed care organizations, ambulatory care sites,
home health agencies and long-term care providers. Around the
world, more than 2,000 professionals in the group work together
to deliver six integrated lines of service that are critical to a
healthcare organization’s success.
Across the spectrum of healthcare delivery, we help organizations
improve performance, preserve revenues, reduce costs, address
compliance issues and create collaborative business approaches
that build competitive advantage.
We offer unparalleled thought leadership through such programs
as the annual Thought Leadership Forum, held in conjunction
with the Harvard School of Public Health faculty, an endowed
directorship for continuing professional education at Harvard, and
frequent publications on emerging industry issues. We also
publish HealthCast 2010: Smaller World, Bigger Expectations, a
prospective view of healthcare in the next decade.
PricewaterhouseCoopers provides you the benefit of deep client
relationships that bring real-life value to our engagements. We
bring you intellectual capital from around the world to develop
solutions. Our consultants monitor Capitol Hill, state houses, Wall
Street and local managed care markets to help you understand the
issues and make decisions that enhance your organization’s
mission, reputation and financial strength.
Healthcare Regulatory Group
Six Lines of Service:
Compliance
Litigation Support
Revenue Preservation
Operations Improvement
Corporate Integrity
Mergers and Acquisitions
3
Unmatched Expertise in a Complex
Regulatory Environment
Healthcare providers and payors are facing intensifying scrutiny
by federal and state governments for possible fraud and abuse
violations. Regulatory and accreditation bodies have also
tightened operational requirements. This scrutiny has lead to the
realization that an integrated, comprehensive compliance program
is no longer a luxury.
At PricewaterhouseCoopers, we specialize in the healthcare
industry and we understand the complex regulatory issues that you
face daily. That’s why we incorporate those issues into our
consulting and operational improvement services. During a
corporate compliance engagement, we provide a dedicated group
of healthcare regulatory professionals with in-depth skill sets that
will put their expertise to work for you. They can tell you where
and how to assess your risks at the operational level. Our
specialists will also show you how to structure your compliance
program to monitor, audit and mitigate those risks. Additional
services include employee training and education, daily advice and
council with our Compliance Office™ management tool, as well
as fraud and abuse investigative services by specific segments.
Our experienced, multidisciplinary teams can provide a more
thorough situation analysis in a shorter period than you could
possibly achieve alone. And a quick response can significantly
reduce your exposure if a non-compliance issue should surface.
We have spent years building and nurturing working relationships
with all relevant regulatory and accreditation agencies. This
means that the reputation and the integrity of our services can
bring a stabilizing influence to any investigative process as well as
enhance your organization’s credibility.
4
The Benefits of Compliance
We believe there are two phases to the development and
implementation of a compliance program: developing the overall
program structure and operationalizing the program.
Many organizations have been developing their overall
compliance program structure, including creating the compliance
office. Resources exist in the industry including the Office of the
Inspector General’s (OIG) model compliance program, to provide
guidance on the program structure.
The more difficult and challenging aspect of developing and
implementing a compliance program comes when an organization
tries to operationalize the program. We believe that an
organization will only be able to demonstrate their compliance
program is effective when the program has been integrated into
the day-to-day operations of every department.
We believe an effective program creates an environment that
reinforces your commitment to compliance while providing a
framework to identify and correct potential issues of non-
compliance.
We also believe that the compliance program should not impede
or replace the organizational processes currently in place, but
rather, complement and enhance them in order to create a more
effective and efficient operation.
Our experience is that effective compliance programs deliver real
benefits to any organization, including:
Development of an integrated framework to manage
compliance with laws and regulations
Increased understanding of the operating risks applicable to
the organization
Strengthened operational consistency and coordination
between departments
Improved efficiency of response to government
investigations and inquiries that often arise without notice
Enhanced organizational control of the overall operations.
5
Fraud and Abuse Investigative Services: Our consultants
have extensive experience assisting clients and their counsel
during federal and state investigations or through Qui Tam
actions. Our consultants’ investigative skills are combined
with financial and economic acumen to support counsel in
pre-litigation, arbitration and mediation, accurate intelligence
and admissible evidence.
At PricewaterhouseCoopers, we have drawn on our vast
global resources to provide successful customized corporate
compliance solutions for numerous healthcare entities over a
number of years. And we stand ready to provide the same
services for your organization.
Corporate Compliance Solutions
PricewaterhouseCoopers offers comprehensive, customized
solutions to your corporate compliance challenges. They can
work together or stand alone.
Payor Compliance Expertise: We understand that payors have
their own compliance regulations, issues and concerns. Only
PricewaterhouseCoopers can offer an in-depth evaluation of these
issues within any payor organization including third-party
administrators. Our highly qualified specialists average 10 to 15
years of experience in their respective operational areas.
Provider Compliance Expertise: Provider’s compliance
regulations, issues and concerns are no less unique. Only
PricewaterhouseCoopers can offer a comprehensive evaluation of
compliance issues and all aspects of any provider organization.
We have experienced consultants with 10 to 15 years of
experience in managing all areas of provider operations.
Compliance Office™: PricewaterhouseCoopers is proud to
offer this innovative, proprietary management system. This ever-
evolving software enhances risk management activities by directly
linking business risks to specific control procedures, oversight
responsibilities and performance monitoring. We believe there is
no other healthcare compliance tool on the market that is as
comprehensive, functional and flexible.
6
Compliance Services
Our flexible approach is what sets up apart from firms that treat
compliance issues with a rigid “one size fits all” approach. We
believe in building compliance directly into your existing
processes and systems.
PricewaterhouseCoopers professionals can provide assistance in
one or many aspects of your compliance program development
and implementation:
Policies and Procedures: While organizations have some
policies and procedures in place to mitigate compliance risks, our
experience is that most organizations do not have all the necessary
processes in place. We can review your existing polices and
procedures to identify additional processes necessary to mitigate
compliance risks in your organization. We can provide assistance
in developing and implementing the additional policies and
procedures.
Training and Education: Training may be needed to increase
the knowledge of your managers, employees and medical staff of
compliance related risks for your organization. We have
conducted training sessions at all levels within healthcare
organizations, including “train the trainer” sessions.
PricewaterhouseCoopers can conduct training and education
sessions or provide materials for your team to use in conducting
training and education sessions.
7
Monitoring: Controls are needed to ensure your
organization continues to comply with applicable laws and
regulations and identify issues of non-compliance
immediately for resolution. We can provide assistance in
identifying existing monitoring activities and build new
monitoring controls to address any “gaps” identified.
Auditing: As organizations implement their compliance
program, we have seen Boards ask whether the program is
operating effectively. PricewaterhouseCoopers can help you
address this question through an independent evaluation of
your program. We can also perform audit services to
independently evaluate your billing and coding practices or
provide additional resources to supplement your audit
resources.
Fraud and Abuse Prevention Services: Even though you
may be doing “the right thing,” you may be subjected to an
investigation by a federal agency. PricewaterhouseCoopers
can provide you with one of the strongest and most
experienced crisis response teams.
We have helped many of our clients and their attorneys
successfully defend themselves in a government investigation.
Additionally, we can provide assistance to your organization
if you have identified a compliance issue internally and you
are considering self disclosure.
8
PricewaterhouseCoopers—Value-added
Services
PricewaterhouseCoopers professionals have served hospitals,
third-party administrators, health systems, academic medical
centers, managed care organizations, home health agencies,
Medicare and Medicaid contractors, independent and hospital
based clinical laboratories, renal dialysis facilities and other
healthcare providers, payors and industry regulators in the
following principal areas:
Operational controls and process improvement
Revenue cycle improvement
Reimbursement and compliance
Health information management
Financial management
Financial and business analysis
Due-diligence reviews
Strategic planning
Audit services
Internal audit outsourcing
Payor specific tax services
Provider specific tax services
Dispute resolution services
Mergers and acquisitions
Human resource advisory services
Internet-based physician training
9
PricewaterhouseCoopers—Committed
to Your Success
PricewaterhouseCoopers is the world's leading professional
services organization. Drawing on the knowledge and skills
of 155,000 people in 150 countries, we help our clients solve
complex business problems and measurably enhance their
ability to build value, manage risk and improve performance.
PricewaterhouseCoopers refers to the U.S. firm of
PricewaterhouseCoopers LLP and other members of the
worldwide PricewaterhouseCoopers organization.
You can learn more about our services and contact us on the
World Wide Web at www.pwcglobal.com/healthcare.
Rated #1 in Client Satisfaction
In a recent independent survey by the Emerson Research
Company, the Healthcare Practice of PricewaterhouseCoopers
was rated number one in the delivery of overall client
satisfaction.* The Practice had a leadership position (first or
second) in more subcategories of satisfaction than any
competitor—a leader in 12 of 14 areas measured.
PricewaterhouseCoopers is also a leader in the key driver that
determines client satisfaction: understanding client needs and
expectations.
Our Practice received more Five Star ratings than any other
competitor, including:
Partner responsiveness
Knowledge of client’s business
Contribution to client’s Industry
PricewaterhouseCoopers is committed to the healthcare industry.
We are grateful to our clients for recognizing efforts. At the same
time, we will continue striving toward best practices that meet
and exceed their expectations.
* 99/00 Emerson Big Five Healthcare Industry Client Satisfaction Survey Study.
Note: PricewaterhouseCoopers was one of two firms to tie for overall client satisfaction
leadership.
The vessel is a symbol for people from many different worlds working together and sharing knowledge. The
shape of each vessel is formed by the classic optical illusion of two facing profiles. Their diversity reflects the
many worlds in which PricewaterhouseCoopers people and our clients work together and share knowledge.
Those worlds are the fundamentals underpinning our organization.
Your worlds Our people
© 2000 PricewaterhouseCoopers. PricewaterhouseCoopers refers to U.S. firm of PricewaterhouseCoopers LLP and
other members of the PricewaterhouseCoopers organization. All rights reserved.
1/2000

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Enhance Compliance Initiatives with Corporate Compliance Solutions

  • 2. 2 Mastering the Dynamics of Change Every day, the senior executives and board members of more than 4,000 healthcare organizations turn to PricewaterhouseCoopers for support in enhancing performance, building financial strength and protecting their reputations. PricewaterhouseCoopers healthcare practice draws on the experience of an international organization that includes clinical and business leaders—and more physicians than any other Big Five firm. Because we’re committed to healthcare, we continually invest in our people and knowledge. In addition to physicians, our healthcare practice includes nurses, information system specialists, management consultants, health policy analysts, actuaries, financial advisors and data analysts, who provide our clients with unmatched industry expertise. Our Healthcare Regulatory Group is the world’s largest regulatory practice serving integrated delivery systems, hospitals, physician practices, managed care organizations, ambulatory care sites, home health agencies and long-term care providers. Around the world, more than 2,000 professionals in the group work together to deliver six integrated lines of service that are critical to a healthcare organization’s success. Across the spectrum of healthcare delivery, we help organizations improve performance, preserve revenues, reduce costs, address compliance issues and create collaborative business approaches that build competitive advantage. We offer unparalleled thought leadership through such programs as the annual Thought Leadership Forum, held in conjunction with the Harvard School of Public Health faculty, an endowed directorship for continuing professional education at Harvard, and frequent publications on emerging industry issues. We also publish HealthCast 2010: Smaller World, Bigger Expectations, a prospective view of healthcare in the next decade. PricewaterhouseCoopers provides you the benefit of deep client relationships that bring real-life value to our engagements. We bring you intellectual capital from around the world to develop solutions. Our consultants monitor Capitol Hill, state houses, Wall Street and local managed care markets to help you understand the issues and make decisions that enhance your organization’s mission, reputation and financial strength. Healthcare Regulatory Group Six Lines of Service: Compliance Litigation Support Revenue Preservation Operations Improvement Corporate Integrity Mergers and Acquisitions
  • 3. 3 Unmatched Expertise in a Complex Regulatory Environment Healthcare providers and payors are facing intensifying scrutiny by federal and state governments for possible fraud and abuse violations. Regulatory and accreditation bodies have also tightened operational requirements. This scrutiny has lead to the realization that an integrated, comprehensive compliance program is no longer a luxury. At PricewaterhouseCoopers, we specialize in the healthcare industry and we understand the complex regulatory issues that you face daily. That’s why we incorporate those issues into our consulting and operational improvement services. During a corporate compliance engagement, we provide a dedicated group of healthcare regulatory professionals with in-depth skill sets that will put their expertise to work for you. They can tell you where and how to assess your risks at the operational level. Our specialists will also show you how to structure your compliance program to monitor, audit and mitigate those risks. Additional services include employee training and education, daily advice and council with our Compliance Office™ management tool, as well as fraud and abuse investigative services by specific segments. Our experienced, multidisciplinary teams can provide a more thorough situation analysis in a shorter period than you could possibly achieve alone. And a quick response can significantly reduce your exposure if a non-compliance issue should surface. We have spent years building and nurturing working relationships with all relevant regulatory and accreditation agencies. This means that the reputation and the integrity of our services can bring a stabilizing influence to any investigative process as well as enhance your organization’s credibility.
  • 4. 4 The Benefits of Compliance We believe there are two phases to the development and implementation of a compliance program: developing the overall program structure and operationalizing the program. Many organizations have been developing their overall compliance program structure, including creating the compliance office. Resources exist in the industry including the Office of the Inspector General’s (OIG) model compliance program, to provide guidance on the program structure. The more difficult and challenging aspect of developing and implementing a compliance program comes when an organization tries to operationalize the program. We believe that an organization will only be able to demonstrate their compliance program is effective when the program has been integrated into the day-to-day operations of every department. We believe an effective program creates an environment that reinforces your commitment to compliance while providing a framework to identify and correct potential issues of non- compliance. We also believe that the compliance program should not impede or replace the organizational processes currently in place, but rather, complement and enhance them in order to create a more effective and efficient operation. Our experience is that effective compliance programs deliver real benefits to any organization, including: Development of an integrated framework to manage compliance with laws and regulations Increased understanding of the operating risks applicable to the organization Strengthened operational consistency and coordination between departments Improved efficiency of response to government investigations and inquiries that often arise without notice Enhanced organizational control of the overall operations.
  • 5. 5 Fraud and Abuse Investigative Services: Our consultants have extensive experience assisting clients and their counsel during federal and state investigations or through Qui Tam actions. Our consultants’ investigative skills are combined with financial and economic acumen to support counsel in pre-litigation, arbitration and mediation, accurate intelligence and admissible evidence. At PricewaterhouseCoopers, we have drawn on our vast global resources to provide successful customized corporate compliance solutions for numerous healthcare entities over a number of years. And we stand ready to provide the same services for your organization. Corporate Compliance Solutions PricewaterhouseCoopers offers comprehensive, customized solutions to your corporate compliance challenges. They can work together or stand alone. Payor Compliance Expertise: We understand that payors have their own compliance regulations, issues and concerns. Only PricewaterhouseCoopers can offer an in-depth evaluation of these issues within any payor organization including third-party administrators. Our highly qualified specialists average 10 to 15 years of experience in their respective operational areas. Provider Compliance Expertise: Provider’s compliance regulations, issues and concerns are no less unique. Only PricewaterhouseCoopers can offer a comprehensive evaluation of compliance issues and all aspects of any provider organization. We have experienced consultants with 10 to 15 years of experience in managing all areas of provider operations. Compliance Office™: PricewaterhouseCoopers is proud to offer this innovative, proprietary management system. This ever- evolving software enhances risk management activities by directly linking business risks to specific control procedures, oversight responsibilities and performance monitoring. We believe there is no other healthcare compliance tool on the market that is as comprehensive, functional and flexible.
  • 6. 6 Compliance Services Our flexible approach is what sets up apart from firms that treat compliance issues with a rigid “one size fits all” approach. We believe in building compliance directly into your existing processes and systems. PricewaterhouseCoopers professionals can provide assistance in one or many aspects of your compliance program development and implementation: Policies and Procedures: While organizations have some policies and procedures in place to mitigate compliance risks, our experience is that most organizations do not have all the necessary processes in place. We can review your existing polices and procedures to identify additional processes necessary to mitigate compliance risks in your organization. We can provide assistance in developing and implementing the additional policies and procedures. Training and Education: Training may be needed to increase the knowledge of your managers, employees and medical staff of compliance related risks for your organization. We have conducted training sessions at all levels within healthcare organizations, including “train the trainer” sessions. PricewaterhouseCoopers can conduct training and education sessions or provide materials for your team to use in conducting training and education sessions.
  • 7. 7 Monitoring: Controls are needed to ensure your organization continues to comply with applicable laws and regulations and identify issues of non-compliance immediately for resolution. We can provide assistance in identifying existing monitoring activities and build new monitoring controls to address any “gaps” identified. Auditing: As organizations implement their compliance program, we have seen Boards ask whether the program is operating effectively. PricewaterhouseCoopers can help you address this question through an independent evaluation of your program. We can also perform audit services to independently evaluate your billing and coding practices or provide additional resources to supplement your audit resources. Fraud and Abuse Prevention Services: Even though you may be doing “the right thing,” you may be subjected to an investigation by a federal agency. PricewaterhouseCoopers can provide you with one of the strongest and most experienced crisis response teams. We have helped many of our clients and their attorneys successfully defend themselves in a government investigation. Additionally, we can provide assistance to your organization if you have identified a compliance issue internally and you are considering self disclosure.
  • 8. 8 PricewaterhouseCoopers—Value-added Services PricewaterhouseCoopers professionals have served hospitals, third-party administrators, health systems, academic medical centers, managed care organizations, home health agencies, Medicare and Medicaid contractors, independent and hospital based clinical laboratories, renal dialysis facilities and other healthcare providers, payors and industry regulators in the following principal areas: Operational controls and process improvement Revenue cycle improvement Reimbursement and compliance Health information management Financial management Financial and business analysis Due-diligence reviews Strategic planning Audit services Internal audit outsourcing Payor specific tax services Provider specific tax services Dispute resolution services Mergers and acquisitions Human resource advisory services Internet-based physician training
  • 9. 9 PricewaterhouseCoopers—Committed to Your Success PricewaterhouseCoopers is the world's leading professional services organization. Drawing on the knowledge and skills of 155,000 people in 150 countries, we help our clients solve complex business problems and measurably enhance their ability to build value, manage risk and improve performance. PricewaterhouseCoopers refers to the U.S. firm of PricewaterhouseCoopers LLP and other members of the worldwide PricewaterhouseCoopers organization. You can learn more about our services and contact us on the World Wide Web at www.pwcglobal.com/healthcare. Rated #1 in Client Satisfaction In a recent independent survey by the Emerson Research Company, the Healthcare Practice of PricewaterhouseCoopers was rated number one in the delivery of overall client satisfaction.* The Practice had a leadership position (first or second) in more subcategories of satisfaction than any competitor—a leader in 12 of 14 areas measured. PricewaterhouseCoopers is also a leader in the key driver that determines client satisfaction: understanding client needs and expectations. Our Practice received more Five Star ratings than any other competitor, including: Partner responsiveness Knowledge of client’s business Contribution to client’s Industry PricewaterhouseCoopers is committed to the healthcare industry. We are grateful to our clients for recognizing efforts. At the same time, we will continue striving toward best practices that meet and exceed their expectations. * 99/00 Emerson Big Five Healthcare Industry Client Satisfaction Survey Study. Note: PricewaterhouseCoopers was one of two firms to tie for overall client satisfaction leadership.
  • 10. The vessel is a symbol for people from many different worlds working together and sharing knowledge. The shape of each vessel is formed by the classic optical illusion of two facing profiles. Their diversity reflects the many worlds in which PricewaterhouseCoopers people and our clients work together and share knowledge. Those worlds are the fundamentals underpinning our organization. Your worlds Our people © 2000 PricewaterhouseCoopers. PricewaterhouseCoopers refers to U.S. firm of PricewaterhouseCoopers LLP and other members of the PricewaterhouseCoopers organization. All rights reserved. 1/2000