Developing a Plan for the Risk Assessment
HCR 361
The role of the board of the directors in compliance and ethics are setting the scopes for the program of compliance and ethics, gives approval to the key policies and procedures, aligns incentives, and reports on the activities that involve compliance and ethics within the organization (Roach. 2008.). Since the board of directors make a lot of decisions for a company, it makes sense that they set the scopes within a compliance program. Creating important scopes of practice helps with legal, compliance, and ethical issues when it comes to specific roles within a company. For instance, the board of directors will need to research and implement scopes of practice when it comes to, let’s say, a medical assistant. The B.O.D. will implement a compliance and ethical policy that medical assistants cannot perform surgery, however, they are able to assist in handling equipment(s) when it comes to assisting a qualified physician when it comes to a small procedure such as the birth control, Nexplanon.
Lastly, the B.O.D. being responsible for incentives and the approval of the key policies and procedures is vital because, the B.O.D. must review said key policies and procedures to ensure efficient and applicable policies and procedures for the ethical and compliance program of the company. The incentives are to ensure the policies and procedures along with the scope are being followed appropriately. The B.O.D. and the compliance officers also work together as the compliance officer(s) do report to them and meet with them regarding compliance and ethics issues. The ethical and compliance that are also reported involve finance and the billing and coding department. These issues are also reported by the compliance officer and the compliance and ethical board of directors.
Assessments are also a vital part of the role as a Board of Director of the Compliance and Ethics program. When it comes to performing assessments, the risks and risk management are what need to be assessed in order to identify low to high risks (Spain. Pg. 7. 2020.). They will then need to prime the risk by avoiding the risk, mitigate the risk, transfer the risk, and lastly assume the risk (Spain. Pg. 9-10. 2020.). The enterprise risk management (ERM) helps the board and the CEO identify risks faster and more efficiently (Spain. Pg. 11. 2020). The ERM reviews the governance and culture, business strategy, performance, reporting, and review and revision when looking for risks in risk management (Spain. Pg. 11. 2020).
When it comes to being a coding and billing vendor, I would focus on the fraudulent laws such as stark law and the privacy law, HIPAA. Even though the healthcare facility gives the ICD-10 codes for the coding and billing department, the department still has to code them appropriately before submitting claims (The HIPAA Journal. N.d.). There must be a Business Associate Agreement that is in place before any of the patient’s PHI is disclosed from the covered entity such as the medical clinic (The HIPAA Journal. N.d.). You also cannot submit anything dealing with a patient’s SSN to CMS or any other third-party insurance company within a claim.
Resource
· Roach, Daniel, JD. July-August 2008. The Board of Director’s Role in Compliance and Ethics. Retrieved from https://www.chausa.org/publications/health-progress/archive/article/july-august-2008/the-board-of-directors%27-role-in-compliance-ethics
· Judith Spain, JD, CCEP. 2020. Compliance Risk Assessments. Pg. 7-12. Society of Corporate Compliance and Ethics.
· The HIPAA Journal. N.d. HIPAA Compliance and Medical Billing. Retrieved from https://www.hipaajournal.com/hipaa-compliance-and-medical-billing/
