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Why Rehab Compliance Matters.

> Now more than ever, the federal government has made it exceedingly clear through increased oversight of Medicare and Medicaid that healthcare employees are expected to be responsible for engaging in appropriate ethical and legal behavior in the work place.
In response to the increase in efforts to reduce fraud, waste, and abuse, there has been an expansion of the RAC program to state Medicaid as well as a pending RAC Medicare Prepay demonstration project. These developments have occurred alongside expansion of the HEAT strike forces to nine cities, new use of predictive modeling technology to identify at risk clams, and an increase in PSC/ZPIC and FI/MAC medical review activity. With these changes to the False Claims Act and the new provisions in PPACA, the risks and potential repercussions of non-compliance are now greater than ever before.

> One of the key provisions of PPACA is found in Section 6102 and states that SNF compliance programs must be implemented by March 2013 and must be effective in preventing and detecting criminal, civil, and administrative violations and in promoting quality of care. Not all contract rehab companies are prepared to serve your mission critical compliance needs. As a leading contract rehab therapy provider, Evergreen Rehabilitation is committed to excellence and integrity in all areas of our business and ensuring to our SNF partners that our corporate rehab compliance program will stand up to an effectiveness assessment based on these key elements: standards and procedures, oversight of the program, training and education, auditing and monitoring, enforcement and discipline, and response and prevention.

> Evergreen Rehabilitation is fully prepared to answer the following questions that all SNFs should ask their in-house or contract therapy department:

1. Do you have a Code of Conduct?

2. Do you have Policies and Procedures specific to Rehab Compliance?

3. Do you have a Rehab Compliance Officer who reports only to the CEO or Board of Directors?

4. Do you provide Rehab Compliance training to all new hires?

5. Do you provide Compliance training annually to all employees?

6. Do you have mechanisms in place to communicate to the field regulatory changes?

7. Do you have an Annual Audit plan?
a. How do you establish your Annual Audit Plan?
b. In addition to your annual audit plan, what other type of monitoring do you perform?

8. Do you benchmark key claims data to identify potential areas of exposure?

9. Do your employees have for an anonymous option for reporting concerns?

10. Do you track compliance complaints/concerns? How?

11. Do you have a Complaint Response Procedure?

12. Do you perform monthly Exclusion/Sanction checks?

13. Do you partner with the SNF in performing Denials Management?

14. Do you have a process for ensuring clean claim submission?

15. Do you have a process for evaluating that Medicare documentation requirements are met?

> Are you interested in rehab compliance and contract rehab companies? Your largest vendor should be able to provide the right answer to all of these questions.

We are a leader among rehab companies!

> Follow this link to our Clinical & Compliance Bulletin Archives or join Evergreen Rehabilitation Director of Compliance, Shawn Halcsik & Evergreen Rehabilitation Vice President of Clinical Services, Liz Barlow at the Health Care Compliance Association's 2012 Compliance Institute being held April 29 - May 2nd - Caesar's Palace, Las Vegas, NV. Together Shawn & Liz will present a breakout session: "SNFs: Is Your Contract Therapy Provider Compliant or Placing You at Risk?" This rehab compliance session will focus on key rehab compliance questions to ask a contract therapy provider and ways to measure Medicare SNF PPS compliance effectiveness.

> To Learn more about Evergreen Rehabilitation contract therapy services for your skilled nursing facilities, assisted living facilities, or full-service continuing care retirement communities or for a compliance assessment of your in-house therapy department, please contact Michael Houlihan, President & CEO, Evergreen Rehabilitation (877) 799-9595

© 2012 Evergreen Rehabilitation, LLC
© 2012 Compliance Partners, LLC

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