Background
HealthPlus of Michigan, Inc. and its Subsidiaries, including HealthPlus Partners, Inc., HealthPlus Insurance Company, and HealthPlus Options have established and currently maintain practices and procedures which collectively comprise the HealthPlus Corporate Compliance Program (CCP). This program is intended to prevent, detect, and correct any illegal or improper conduct. Federal and state laws and regulations enacted by the Centers for Medicaid & Medicare Services (CMS), the Michigan Department of Community Health (MDCH), the Office of Financial and Insurance Regulations (OFIR) and other agencies to administer programs, including Medicare, Medicare Part D, Medicaid, MIChild, and Community Health Programs all contribute to the regulations organizations are to follow in their compliance programs. Basically, the Compliance Program consists of rules and regulations for both HIPAA (Privacy and Security) and Fraud, Waste, & Abuse. The Compliance Program Description specifies the structure, policies, procedures, and practices that constitute the HealthPlus Compliance Program. Compliance is not a “policing” action, but a way to ensure everyone is “doing the right thing”. To support this, HealthPlus’ Corporate Compliance Program is designed around eight primary functions
A) Establishing compliance policies and procedures
B) Business structure and responsibility that includes a Compliance Officer and committee
C) Education/training
D) Reporting mechanisms that include effective lines of communication
E) Response/prevention and enforcement through well publicized disciplinary guidelines
F) Monitoring and Auditing
G) Responding to detected offenses and developing corrective actions
H) Comprehensive Fraud and Abuse Plans – Procedures to voluntarily self-report potential fraud or misconduct.
All levels of the organization are responsible for assuring HealthPlus’ actions are appropriate –employees, providers, members, vendors, the Board of Directors, and first-tier, downstream, and related entities. Once an issue is identified, the Compliance Department works with the applicable departments to investigate and resolve the issue. All issues are recorded and tracked for timely resolution.
