Practice Management Alternatives, LLC (PMA) Compliance Hotline The objective of the compliance hotline and e-mail address is to provide a confidential way for your employees to obtain information about compliance issues and report instances of suspected non-compliance outside the normal chain of command in a manner that preserves confidentiality and assures non-retaliation. Your employees should use the hotline when they are not satisfied with their supervisors' response to a compliance issue, or if they fear retaliation by their supervisors. Under normal circumstances, however, compliance issues should be addressed through normal administrative channels. Examples of activities and operations in which non-compliance may be an issue: Client safety Billing (False Claims) Privacy or Security violations Conflict of interest and ethics policies Computer security IRS regulations Equal Employment Opportunity laws Sexual harassment policies Complaints The compliance hotline is not a complaint hotline. Only matters involving compliance with a policy or procedure, or a federal or state law or regulation, will be forwarded for investigation. Employees with complaints will be advised to pursue normal administrative channels. Supervision of Hotline and E-Mail address The compliance hotline is supervised by professionals. All monitors at PMA are certified in Healthcare Compliance (CHC) by the Health Care Compliance Association (HCCA) and Certified Fraud Examiners (CFE) by the Association of Certified Fraud Examiners. Confidentiality Employees who call the compliance hotline may remain anonymous. If the person requests anonymity, no attempt will be made to identify the employee. Information provided by the employee will be treated as confidential and privileged to the extent permitted by applicable law. Non-retaliation Retaliation against an employee who has called the hotline is strictly prohibited. After placing a hotline call, if an employee perceives that he or she is being retaliated against, the employee will be referred to the appropriate administrative grievance procedure. Accusations of retaliation will be taken very seriously and agitators will face disciplinary action. Employees who intentionally and maliciously use the hotline to make false allegations will be subject to disciplinary action. Records Retention A log will be maintained of all hotline telephone calls by PMA’s Office of Audit and Regulatory Services. Issues that require your attention are immediately forwarded to your organization’s identified contact. Monthly reports are sent to you regardless of activity. Resolution All hotline compliance issues should be resolved as quickly as possible. To that end, PMA’s Office of Audit and Regulatory Services will make recommendations to your organization when issues require your attention. Employees requesting follow-up are given a code number and are asked to call back in two weeks to receive an update on actions taken to date. Your organization can also utilize this mechanism to communicate additional questions to callers who prefer to remain anonymous. Confidential information obtained during the investigation should not be disclosed to the employee. After your organization is satisfied with the resolution of the issue, documents pertaining to the call will not be retained Recap PMA establishes a toll-free telephone number and e-mail address for your employees; Both are monitored 24/7, though callers are urged to leave a message at the telephone number; All calls and e-mails are logged and given a unique identification number; You will receive a monthly accounting of all calls and/or e-mails (see below); If a call is received that our certified compliance contacts feel requires an organizational response we will contact the identified person or persons in your organization. We will also make recommendations for follow-up or other procedures and we will track the issue until it is resolved. PMA conducts a web-based “training of trainers” regarding general compliance issues, use and purpose of the hotline, the false claims act (Federal and state, if applicable) and whistleblower protections. From the 60-minute “training of trainers” a CD is created for your ongoing use. Please note that creation of a hotline requires that your organization and ours enter into a “Compliance Contact” agreement. It is written in the form of a HIPAA-compliant contract that makes PMA a BAA of your organization. The contract format is compliant with OIG Compliance Guidance for compliance contacts.   Pricing   The costs associated with this agreement are a one-time fee of $125 for creating the e-mail and telephone address, as well as the training and CD. The monthly monitoring, reporting and follow-up recommendation fee is $125/mo.   Should you choose to enter into an annual agreement, there is a one-time charge of $1250, representing a $250 discount.   Further, PMA guarantees that all Compliance Contacts can access further consultation at the rate of $125/hr.   All you need to do to get us started is call us at 425-454-7688 or write to contact@pmallp.org. We can get a contract to you immediately and schedule the training ASAP.