Compliance Connection
August 2017

Compliance Resource Center is dedicated to keeping you informed on what’s new in the healthcare compliance industry and our suite of solutions. Below you will find important updates, relevant articles, and more.

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Hotline Service Center

Our ethics hotline service improves reporting for both members of your workforce who were already expressing concerns and for others who may have been unsure of how to share their reports. Workforce members may know that HR representatives and compliance officers are available to discuss complaints, but our ethics and compliance hotline provides a secure and anonymous way to communicate concerns that some may not feel comfortable discussing in person. With our service, more individuals will be reporting overall, which leads to a better compliance program and improves the functionality of your organization.

We also offer special capabilities through the Hotline Service Center’s online module for the client to organize and review all cases. The module provides you with detailed final reports that include all activities related to the investigation of the potential violation. Instead of having to consult with multiple individuals on what a workforce member reported, we developed this feature to centralize all reports, making it easier for you to manage.

To read more about how HR, compliance officers, and compliance hotlines can work together, check out this article.

For more information about the Hotline Service Center, or to learn how you can better manage your hotline reports, please contact CRC Support at 703.683.9600, ext. 492 |

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Sanction Screening Services

The DOJ and HHS recently announced the largest Medicare Fraud Strike Force (MFSF) sweep to date. The fraud enforcement action resulted in charges against 412 individuals for nearly $1.3 billion in false billings. HHS has also initiated suspension and exclusion actions against 295 healthcare providers including doctors, nurses and pharmacists. HHS has had a particular focus on the unlawful distribution of opioids and other prescription narcotics for several years. The 295 individuals who received exclusion notices in the wake of the take down were involved in conduct related to opioid diversion and abuse including doctors operating pill mills and technicians stealing pills. However, of all the providers who received notices, nurses had the most new exclusions with 162 individuals.

Remaining aware of and tracking compliance violations among what could be thousands of employees, physicians, and other business entities can be difficult for any healthcare organization. As more instances of fraud continue without proper action by compliance officers and other authorities, the severity of these situations will only grow exponentially. Healthcare organizations should be able to stay on top of the state and federal databases of excluded individuals and entities to avoid initial and long-term consequences. This is where CRC can help.

Whether you choose to screen your organization’s names or outsource the screening to us, both approaches will help you identify possible and/or confirmed matches to names on excluded databases while providing you the ability to better manage your sanctions screening process. Keeping track of sanctioned individuals and entities may seem overwhelming for healthcare organizations of any size, but with our sanctions screening solution you can let our Tool and our reliable services do the work. With our extensive background in compliance policy and regulation, our solutions ensure that we provide organizations with quality services and compliance support.

Click here to read CRC’s write-up about the DOJ and HHS take down.

Monthly Updates

The following federal and state agencies recently updated their sanction and exclusion data:

Federal Databases

  • DEA
  • NPI Registry
  • OIG Waivers

The NPI Registry was updated on July 25, 2017. The OIG Waivers were updated on July 24, 2017. The DEA was updated on July 23, 2017. The GSA SAM was updated on July 18, 2017.The DEA ACAD and OIG LIEE were updated on July 14, 2017. The OFAC SDN was updated on July 11, 2017.

State Databases

  • AK
  • AR
  • CA
  • CT
  • DC
  • FL
  • GA
  • IA
  • ID
  • IL
  • IN
  • KS
  • KY
  • LA
  • MA
  • MD
  • ME
  • MI
  • MN
  • MO
  • MS
  • NC
  • ND
  • NE
  • NJ


  • NV
  • NY
  • OH
  • PA
  • SC
  • TX
  • WA
  • WV
  • WV2


The NC database was updated on August 1, 2017. The MN database was updated on July 31, 2017. The following state databases were updated on July 26, 2017: FL, IL, KY, MS, NE, NV, SC and WA. The following state databases were updated on July 25, 2017: DC, GA, IA, ID, KS, OH, PA and TX. The CA, MO and NY databases were updated on July 24, 2017. The ND and NJ databases were updated on July 23, 2017. The following databases were update on July 22, 2017: LA, MD, MI and WV. The AR database was updated on July 21, 2017. The CT and MA databases were updated on July 14, 2017. The AL, IN and ME databases were updated on July 13, 2017.

Stay aware of additional updates throughout the month by checking What’s New” in the S3 section of our website.

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Compliance Survey Center

Understanding your healthcare organization’s compliance culture is key to making sure that you have a successful compliance program. If your employees are unfamiliar with your program’s operations or not satisfied with the results or processes related to the program, their work ethic may become negatively affected. This may make their work environment less enjoyable and less productive while also possibly discouraging them from following your program’s requirements. Similarly, if you are not aware of how your employees perceive and understand your compliance program, you may not have the most effective operation. In both instances, your compliance program, and the success of your organization, could suffer.

The Compliance Survey Center is an easy and efficient way for you to gauge where your employees may not be fully engaged with your compliance operations while highlighting where you can further develop your program. This solution creates the opportunity for an improved work environment and provides you with a reliable tool to assess your program.

Our Compliance Knowledge Survey measures the effectiveness of a compliance program, and our Compliance Culture Survey assesses employees’ perceptions and attitudes. Both surveys are meant to improve organizations’ overall understanding of how successfully their compliance programs are operating.

For more information about our Compliance Survey Center, contact Jillian Bower at 703.535.1405 |

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Policy Resource Center

The Policy Resource Center continues to offer hundreds of ready-to-use policies, agreements, charters, forms, and compliance audit and monitoring guides. In order to continuously provide our clients with updated templates, we have added the following documents this month:

Claims Development & Submission

  • Off-Label Use of Drugs Policy and Procedure (V 4.0)
  • EMTALA On-Call Physician Coverage Policy (v 4.0)
  • Home Health Claims Submission Policy (V 3.0)
  • Nursing Home Standards of Care Policy and Procedures (V 2.0)
  • Audits of Coding Operations Policy (V 3.0)
  • Billing Code Correction Policy (V 3.0)
  • Coding and Billing Reference Tools for Physician Practices Policy (V 4.0)
  • Resident Wound Care Management Policy (V 3.0)

Clinical Research

  • Department Review of Research Protocols Policy (V 2.0)
  • Properly Allocating Cost Policy (V 5.0)
  • Reporting Financial Research Support from Other Sources Policy (V 5.0)

Compliance Auditing & Monitoring Plans

  • Inpatient and Outpatient Compliance Audit Policy (V 2.0)

Corporate Governance & Compliance

  • Acceptable Encryption Policy and Procedures (V 2.0)

You can find each of these documents under their respective categories or conduct a “Recent Policy” search in the PRC. If you’re looking for a specific document and can’t find it, please submit a request for development to our team at

Log into the PRC today to explore our newest documents and other useful compliance resources.To learn more about the PRC or sign up for a demonstration on how to use this solution, contact CRC.

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Training Center

CRC’s Training Center offers up-to-date materials to conduct comprehensive online compliance training in regulatory compliance, compliance activities, and healthcare business operations. All training material is customized to organizations’ focus areas, allowing easy real-world implementation for every healthcare provider.

Our comprehensive employee training provides a beneficial tool to you and your employees that promotes a widespread understanding of what is included in your compliance program. We also recommend innovative practices that can help improve your program. By implementing our training, you can refresh your employees’ understanding of your specific compliance operations, clarify areas that may be in question, and explain the consequences of misconduct.

Read more about the Charges Filed Against Northern California Physician For Unlawfully Dispensing Oxycodone here.

Schedule a training session today to refine your program’s operations and refresh your organization’s understanding of compliance.

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