The Best of the 2022 HCCA Compliance Institute

Gathering together again in person, at last! Finally, the healthcare compliance community met face-to-face again for the HCCA’s 26th Annual Compliance Institute. And, of course, attending virtually was also an option that many took advantage of—the very best of both worlds.

Whether folks participated in person or virtually, they could take advantage of an enormous amount of outstanding compliance information.

Highlights From HCCA’s 26th Annual Compliance Institute

HHS Inspector General Christi Grimm

The U.S. Senate recently confirmed Christi Grimm as the newest HHS Inspector General (IG). She has been serving as deputy, but now it is official, she is the IG.

She shared a brief summary of the feedback the OIG has received as a part of its Modernization efforts (see Healthicity’s recent webinar on this topic). She summarized the three biggest takeaways thus far:

• • First, OIG’s publicly available resources are valued by the compliance community.
  • Second, we would like more ways to connect the dots. It’s not enough to have the most recent audit or corporate integrity agreement (CIA). We want more information about how it fits with other OIG work.
  • Third, we would benefit from better, more searchable data and interactive tools that help put more information at our fingertips faster.

She then shared stories and examples of four core values for HHS OIG. The four values are:

1. 1. People-Focused Results
   2. Pragmatism
   3. Preparedness
   4. Transparency

The OIG has shared both a video of her speech as well as a transcript.

Chronic Care Management Services

Chronic Care Management (CCM) Services have been a hot ticket item for OIG and DOJ attention in the last few years. The presenters, who serve as advisors to some of those under scrutiny, believe it is likely that this same level of enforcement will continue. They shared best practices in avoiding the trouble they have seen others experience. Specifically, they taught:

• CMS requirements for delivery and reimbursement of chronic care management services, including conditions of payment and program integrity enforcement trends.
• Key CCM compliance, revenue integrity, quality, and risk management considerations, as well as the financial and quality implications of incorporating CCM as a means of practice improvement.
• CCM operations strategies that satisfy risk management and achieve revenue integrity objectives.
  
  

MD Anderson Cancer Center’s Successful Legal Battle With HHS OCR

There were three separate events: a stolen laptop, a lost thumb drive, and another missing thumb drive. These events led to HHS OCR fining MD Anderson $4.3 million. MD Anderson legally fought the fines and ultimately won the legal battle resulting in $0 paid to OCR. This was a fascinating inside look at the years-long battle. Presenters were Allyson Kinzel, MD Anderson’s current SVP of Legal and Regulatory Affairs, and Scott McBride, MD Anderson’s outside counsel.

OIG Developments Presented by Officials From the HHS-OIG

It is always helpful to hear where the OIG focuses its enforcement efforts. Some of the areas they highlighted include:

• Trends in Genetic Tests Provided Under Medicare Part B Indicate Areas of Possible Concern
• OIG Nursing Home Strategy
• Telehealth
• Behavioral Health
• Home Health
• Inpatient Rehabilitation Facilities
• Laboratories
• Medicare Advantage Audits
  
  

Updates from Washington, DC

Kim Brandt did not disappoint. She shared the scoop on what actions in DC will mean for the healthcare industry. There was so much information! Reviewing her session and/or handout multiple times might be necessary. Here are just some of the highlights she shared:

• On March 1, 2022, President Biden announced a comprehensive mental health initiative that will include a renewed commitment to mental health parity. Bidenʹs fiscal 2023 budget, expected later this month, will strengthen insurance network adequacy standards to enhance access to behavioral health professionals.
• Nursing Home Reform---President Biden also announced comprehensive nursing home reform measures.
• Current Public Health Emergency (PHE) extended for an additional 90 days, effective January 16, 2022, ending April 15, 2022. Beginning to be discussions about the end of the PHE as early as July 15, assuming the current PHE is extended another 90 days. It is improbable to end before then, but the administration may choose to end it to signal that the pandemic is moving into the endemic stage.
  
  

Cybersecurity by Mark Lanterman

Mark Lanterman presented the concluding general session at the end of the day on Wednesday. Who thought a presentation on cybersecurity woes could be so humorous? Mr. Lanterman was funny and kept the crowd engaged as he told stories of high and low-profile cybersecurity cases, explaining their causes and, in the process, teaching attendees what to do to avoid similar outcomes. As technology and the internet of things move forward, we all should have cybersecurity on our minds.

60 More Days of Compliance Learning

There is not enough space to cover every session available at the conference. And actually, there’s no need because the HCCA is offering 60 days of availability for the recordings of all the sessions for attendees. This is one of the best features of the conference in my opinion because there are so many sessions scheduled at the same time it is impossible to be in more than one place at the same time (even though I wished it). What was your favorite session?

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