2023 Board Resources

compliance with Federal health care program requirements. Throughout the term of the CIA, Banner will make compliance with its Compliance Program an element in evaluating the performance of its employees. III. Compliance Training and Education A. Covered Persons Training Banner developed and submitted to the OIG a written training plan that outlined the steps that it will take to ensure that all Covered Persons receive annual training regarding Banner’s CIA requirements, Banner’s Compliance Program, and applicable Federal health care program requirements (including the requirements of the Anti Kickback Statute and the Stark Law). B. Board Member Training Banner must provide at least two hours of training to each member of the Board of Directors within 120 days after the Effective Date. This training must address, at a minimum: (1) corporate governance responsibilities; (2) the responsibilities of board members associated with reviewing and overseeing the Compliance Program; and (3) the unique responsibilities of health care board members, including the OIG’s guidance on Board member responsibilities. Independent Review Procedures A. Engagement of an Independent Review Organization (IRO) The CIA requires Banner to engage an IRO within 120 days to perform the two reviews described below and to provide written reports for submission to the OIG. B. Claims Review The IRO will annually review 100 claims that have been submitted and reimbursed by the Medicare Program for two Covered Facilities to determine whether the items and services furnished were medically necessary and appropriately documented and whether the claims were correctly coded, submitted, and reimbursed. The OIG will select the two Covered Facilities to be reviewed based on data submitted by Banner prior to the end of the year, and the IRO will randomly select and review a sample of 100 claims from each Covered Facility. C. Inpatient Medical Necessity and Appropriateness Review In addition, the IRO will annually analyze 100 claims that have been submitted and reimbursed by the Medicare Program for two Covered Facilities that relate to zero-day or one-day inpatient admissions to determine whether the admissions were medically necessary and appropriate under the applicable Medicare rules and regulations and, if not, whether the claims were correctly documented, coded, and billed appropriately. The OIG will select the two Covered Facilities to be reviewed based on data submitted by Banner prior to the end of the year, and the IRO will randomly select and review a sample of 100 claims from each Covered Facility. Risk Assessment and Internal Review Process Banner must maintain a risk assessment and internal review process for the term of the CIA to identify and address risks associated with Banner’s participation in the Federal health care IV. V.

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