Tag: Compliance

Let’s Talk about Primary Source Data

What is a Primary Source?

A Primary Source is the original source repository or the source that legally issue licenses, discipline, education, training, or examination. A couple of examples of this in our industry are:

California Board of Registered Nursing
Office of Inspector General, U.S. Department of Health and Human Services (OIG)
Pharmacy Technician Certification Board (PTCB)
Centers for Medicare and Medicaid Services (CMS)

What is a Primary Source Data?

Primary Source Data is the license, certification, or disciplinary data directly from the original source. This means the data we collect is directly from the primary source. This data includes exclusion information, opt-out affidavits, license issuance, and disciplinary records. Another caveat to primary source data is we do not change, adjust, or modify the record found at the primary source.

Why is Primary Source Data Important?

Primary source data is important to your company as a way to confirm that your employee can be authorized to work for your facility.

The OIG has the authority to exclude individuals and entities from participation in federal healthcare programs. Any organization or individual who hires excluded parties may be subject to civil monetary penalties (CMP). To avoid these penalties, the LEIE recommends (as a part of the Updated Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs) that you check their database upon hire, and on an ongoing monthly basis.

Primary Source data is not only important to us, it’s important to accrediting bodies (i.e. The Joint Commission, URAC) and exclusion bodies (i.e. OIG, GSA).

Typhoon Data is Certified by the NCQA

Typhoon Data, a healthcare data solution provider, announced today it has received certification from the National Committee for Quality Assurance (NCQA), a private, non-profit organization dedicated to improving healthcare quality, for the following credentials verifications services;

License to Practice
DEA Registration
Medical Board Sanctions
Ongoing Monitoring
Medicaid/Medicare Sanctions

This credential verifies Typhoon Data’s use of industry best practices and demonstrates its commitment to quality improvement, increased performance measures, and better compliance data. Typhoon Data was built from the ground up applying knowledge gained from years of industry experience to provide the most effective and accurate solution available. Verification services designed to comply with NCQA credentialing standards demonstrates that Typhoon Data has the systems, process and personnel in place to thoroughly and accurately verify providers’ credentials and help health plan clients meet their accreditation goals.

Recognizing the critical nature of the services they provide, Typhoon Data determined that obtaining certification was a key business strategy. Typhoon Data was built with the customer in mind, and offers integration or turnkey solutions, customization, exclusion data, and verification services. Typhoon Data has revolutionized the method for continuously monitoring compliance data. Typhoon Data is positioned to move the industry forward through innovation and by leveraging technology.

As a bootstrapped startup Typhoon Data has worked to establish sound policies and procedures, and to become an expert in credentialing and compliance. The management and operations teams have created systems that ensure complete, accurate, and timely data gathering and verification. Certification includes rigorous on-site evaluations conducted by a team of health care professionals and certified credentialing specialists. A national oversight committee of physicians analyzes the team’s finding and determines certification based on the CVO’s compliance with NCQA standards.

About Typhoon Data

Typhoon Data is transforming the data industry through automation and partnerships. We make it possible to search for license, exclusion, and board action data in a more efficient and cost effective way. Because our processes are based in the future, we have the ability to offer better products than our competitors at a fraction of the price and in a standardized way that brings new meaning to Compliance Monitoring.

We efficiently handle monthly batching or quarterly reviews, we are constantly monitoring, making it possible for you to truly get the complete picture on your health care staff.

About the National Committee for Quality Assurance (NCQA)

NCQA is a private, non-profit organization dedicated to improving healthcare quality. NCQA accredits and certifies a wide range of healthcare organizations. It also recognizes clinicians and practices in key areas of performance. NCQA’s Web site (http://www.ncqa.org) contains information to help consumers, employers and others make more informed health care choices.

For the original version on PRWeb visit: http://www.prweb.com/releases/2017/01/prweb13989788.htm

It’s a new year…

complianceHappy New Year!!!

Once those words are uttered at 12:01 a.m. on January 1st, we’re all promised improvement. We promise it to ourselves with resolutions and we’re promised it from the people around us. Most resolutions boil down to a single idea: trimming the fat.

Usually, we mean this literally. Whether we’re talking about losing a couple pounds from the holidays, or losing a couple handfuls of pounds. We all want to trim the fat from the previous year. Read More It’s a new year…

Multi-State Licenses and Board Actions

I recently read an article on ProPublica (Read article here) about nurses who skip from state to state after receiving disciplinary actions. This has been and continues to be a huge weakness in the compliance industry.

When Craig Peske was fired from his nursing position in his home state in Wisconsin, and subsequently received an action against his license as well as six felony counts of narcotic possession, he used his “multi-state license” to get a job as a traveling nurse in North Carolina.

His license in North Carolina didn’t have an action against it, it was active and clear. It even surprised him when he checked on it. But, because his license was active, he had the ability to work as a nurse in North Carolina.

His license being clear in North Carolina could have been due to a lag time in getting the discipline on his record. Or because it’s possible that even with a multi-state license, the boards of separate states don’t communicate.

While I’m sure the hospital in North Carolina did their due diligence in searching his North Carolina license to confirm he was active. I believe they probably also searched for him in SAM and OIG to confirm he had no federal actions against him. What was missed, though, was that they clearly didn’t check into his Wisconsin license. The reason for this could range from Craig Peske not releasing the information that he did in fact have a license in another state. Or that their only requirement for employment is to have a free and clear license in the state of the employment.

There are many reasons why licenses for a practitioner can and will stay active when the practitioner shouldn’t be working in the healthcare industry anymore. Employing a nurse that has stolen painkillers at another facility creates a weak spot in your facility. It can open your facility up to being sanctioned or fined. It can put your patients in jeopardy as well.

And, although, most employers ask for every practitioner to disclose their actions, organizations can’t always trust employees to do so. As healthcare organizations, we need to gather as much knowledge about our practitioners as we can to protect our patients and our organization from fraud. I believe we owe this to the people out there trusting us to provide them with quality medical care.

That’s why TyphoonDATA’s product is so invaluable. With each new employee that is hired, you can search TyphoonDATA’s comprehensive database and see if there has been an action against them from a multitude of different sources. Or you can select one of our monitoring products, so with each refresh of the data, your employees are searched against the database. If a new record that matches your employee is found, you will be notified and TyphoonDATA does a verification to confirm or deny whether or not your employee is free and clear. It gives facilities and organizations just a little more comfort in knowing their employees are sanction free.

TyphoonDATA has packages that range from Basic Exclusion (searches against the OIG database) to Standard Plus (Searches against our entire database, including board actions, federal and state exclusions, and medicare opt-outs) to Premium Exclusion searches (Includes everything in Standard Plus, with a license check as well, to guarantee that their license is active and clear). All of our products are available as just a stand alone search, or with verification, or as a monitoring product.

Take a look at our products here.

SAM.gov Exclusions – What Are They, and Where do They Come From?

SAM.gov publishes an exclusion file used by many organizations for screening and/or compliance purposes. This exclusion file replaces the former EPLS files as of November, 2012. The SAM exclusion file receives regular updates and contains the collective exclusion reporting of over 80 different federal agencies totaling to approximately 130,000 exclusion records. An exclusion record from SAM.gov indicates that the individual or organization listed is disqualified from receiving any federal government contracts. S.A.M. stands for System for Award Management. This system is used for any party seeking to be awarded a federal government contract and become a federal vendor or supplier.

Let’s take a look at the break-down of the SAM.gov exclusions to see where most of the information comes from. As seen in the chart below, almost 1/2 of the SAM.gov exclusion records come from the Department of Health and Human Services’ OIG LEIE exclusion list. The top 6 contributors to the SAM.gov file makeup over 90% of its total records. The chart below only shows the top 27 federal agencies that report to SAM, there are many more which have made small record contributions.

Each agency that reports to the SAM exclusion system is responsible for the accuracy of its records and the information they contain. Exclusions records have a “type” and a “termination date”. The types are generally “Prohibition/Restriction” or “Ineligible”. In some cases the type may indicate “Proceedings Pending” or “Proceedings Completed”. These types give a little insight into the status of the investigation resulting in exclusion. The termination date in the record indicates the shelf-life of the exclusion. In some cases, a future date is present. This means that once that date is reached, the party on record is no longer excluded. In many cases, the word “Indefinite” is seen in the termination date. An indefinite exclusion never expires and can only be removed at the digression of the reporting agency. If specific conditions or criteria are met, the excluding agency may remove the exclusion. SAM does not publish a reinstatement list, non-excluded parties are simply removed from the updated file. Some reporting agencies (such as the OIG) do maintain their own reinstatement lists.

 

SAM Pie3

TyphoonDATA offers data and compliance solutions that include the SAM.gov exclusions file and much more.

To speak with TyphoonDATA directly, please contact:

Richard Rupert, VP Compliance Solutions
Office: 800.780.5901 extension 705
rrupert@typhoondata.com

Slipping Through the Cracks in the Process

More and more public watchdog groups, press and user groups are finding holes in the system that may be of concern to those who are hiring or credentialing medical providers.  The article dated June 30, 2014 from NPR demonstrates the complexities and timing issues.  Some providers are able to circumvent the billing process and continue to receive payment for years after being acted upon by the various state medical boards. http://www.npr.org/blogs/health/2014/06/20/323889329/sanctions-common-against-doctors-with-odd-medicare-billing?ft=1&f=1001

Credit Reporting Agencies focusing on hiring, compliance groups and credentialing organizations have the mission to surface issues beyond just the exclusion data repositories like the Office of the Inspector General (OIG) or one of the many Federal sites that track violators.  As you know, being excluded from the Federal Medicare process is only one element of the wider net that is needed to get all the data to make a hiring, risk or just plain due diligence decision.

The problem is often just timing.  A scenario might be a provider is arrested for a crime and adjudication begins.  Maybe a state medical board reviews the incident and takes action.  The various states may jump into action and exclude the provider from receiving Medicaid payments which is administered from the states even though the money comes primarily from the Federal tax dollars.  The license may be affected at the board level and it make take time to get into the exclusion process.  Hearings have to be set and conclusions reviewed.

It is the due process that takes time and we all appreciate the need for it.  But if you are a hiring entity or compliance group you may get caught in the cracks.  The key is to check the various Federal, State and board actions that will blanket the whole process.

It is possible to get an accurate, up to date picture and TyphoonDATA has a solution with will cast a wide net, verify the false positives and close the cracks into a simple to use click process.

If you would like to discuss, call us at 800.780.5901 or email us at RRupert@typhoondata.com or SSkyhawk@typhoondata.com .  We would love to help you with your mission.

 

Lean Thinking and the Art of Creating Value in the Screening Industry

By Kim M. Kerr, CEO, TyphoonDATA

I am a firm believer and activist for Lean Thinking in any business I have worked in since the day I heard of the simple, commonsense approach to the workplace improvement process.  This includes the Screening and Data businesses.  Finding or creating a value stream for customers or clients has become a passion for me.  I had the opportunity to work with some great companies in the data and screening world that have embraced this approach to management and have seen dramatic improvements in the work environment, culture, and top and bottom lines of businesses of all shapes and sizes.  This process is an integral part of the culture at my current company.

I came from an investigative and event security background working for AT&T for many years performing internal investigations, event security including the 1996 Summer Olympic Games, leaving in 1998 after another “reengineering” that resulted in 15,000 managers getting the option for a benefit and retirement “buy out”.  I had seen literally years of downsizings and reengineering projects while managers struggled to catch a falling knife.  I watched thousands of workers either get laid off or reorganized into other jobs or departments in an attempt to find a level that could be supported by the customers.

What finally happened a few years after my departure was a series of mergers, sell offs and eventually a sale of AT&T to one of the Regional Telco’s.  The AT&T trademark, a brand known round the world, was garnered by this new business that is now a strong player in the cellular and business communications market.  It survived by being cut to ribbons over time.  The old AT&T died a death of a thousand cuts.

I have two family members who work in the manufacturing industry.  One is an Operations Manager for a packaging company; the other is an HR Manager for a bedding firm.  I was the Vice President and General Manager for LexisNexis Screening Solutions at the time and as I listen to those two use strange Japanese terms like “Gemba”, “Kaizen” and “Muda”, I began to wonder if Lean Principles would work in the screening and data business.  After some research I started putting this process in front of my Directors.  The results were incredible and the Principles of Lean are now an integral part of the DNA of any company I lead.

The topic is much too big to be covered in an overview article but I can give you some valuable concepts to think about.  First of all I used the term “big” not complicated.  Understanding the value your customer needs and wants from your products and services needs to be understood, articulated and embraced by all of your employees from the CEO to the rank and file.  This is defined as the “Value Stream”, a river of value that flows to your customers.

Along the stream is Muda or waste.  As an example, I was at a client location and saw employees standing around the copier.  They were creating copies of information to be used in the daily work.  I then noticed that all the work stations had two screens but the line was forming from a subset of the workers.  I asked my client what they did and he responded that they were involved in a value stream that fed into the screening report for several key clients.  It was a process outside the normal workflow.

I exclaimed, “Muda” to my client pointing at the copier clutch.  We looked at the wasted time of these employees standing by a copier.  The employees used that as a high tech water cooler to discuss last night’s game and where they were going after work.  So by just walking around the workplace or “Gemba” a trained observer saw a process improvement or “Kaizen” opportunity that had been gradually embraced as “just part of the process”.

The ultimate solutions was to review these processes in detail and the solutions which required a queuing change in the operations software and installing a third screen at two workstations, reassignment of two employees to other pressing processes.  In other words the value was doubled and waste was halved.

So here is my simple recommendation:  Buy a couple of books, Lean Thinking: Banish Waste and Create Wealth in Your Corporation by Womack, James P. and Jones, Daniel T. (Nov 23, 2010); and Gemba Kaizen: A Commonsense Approach to a Continuous Improvement Strategy 2/E by Masaaki Imai (May 23, 2012).  These books have a good framework for instituting Lean thinking into your business.

Have a meeting with your directors or lead managers and follow a few simple steps:

1)      Walk around the Workplace or “Gemba” and observe your employees.  Look at things like the workstation set up, which teams interact with which teams, use of ancillary devices like copiers or email processes.

2)      Ask your key managers what are the top three problems they spend most of their time on during the day?  Ask all the leaders to describe the issue.

3)      Pick one based on the biggest impact to one of the work groups.

4)      Break it into steps or Kaizen the process.  If need be, bring a “doer” into the discussion.

5)      Develop a theory of how the process could be changed and how the process can be measured.  If it can’t be measured, how can you know if you are successful?

6)      What is the investment in the change? – Development time, Project Management, outside resources.

7)      Make the changes.  Measure your success.

8)      Wash, rinse, repeat…

I also recommend instituting an accountability board in all your operations managers’ offices.  What is due in the next 24 hours?  Who is responsible and what is the deliverable?  I call this, “Moving the Ball”.

If you have a process you like, great!  But if you can’t seem to get your margins to grow or you are continually adding people during the good times and laying off others in the slow times, you may be a victim of the reengineering mind game.  Lean Thinking is anything but that.

There are companies or organizations Lean Thinking will NOT work.  It is in companies where the top leadership believes that all real good ideas and processes emanate from the top.  The Lean ship will sink on the sharp rocks of EGO surrounding the crystal tower of pure thought and reason.

Kim can be reached at KKerr@typhoondata.com