I custom designed this PowerPoint template for our agency and I put together the presentation. Since Compliance can be a dull subject, the Compliance Manager wanted to me to create a “fun feel” presentation. You will notice that in the music clip on one of the slides and some of the graphics. Please view in slide show mode to get the best feel of the presentation and to hear the sound.

1. Health and Home Care’s Compliance Program “Compliance is Everyone’s Responsibility” 1

2. What is Compliance? Compliance means following the rules. It means we understand and comply with all the laws, regulations, policies and procedures that apply to Health and Home Care and Health and Hospitals Corporation. 2

3. The Compliance Climate Continues to Change, even Since our Presentation last year! Congress and National Governors Conference Focus on Medicaid Fraud Ex-Governor Spitzer appoints JamesSheehan NY Medicaid Inspector General Governor Patterson appoints NYSMedicaid Inspector General Joseph Fisch Authorization to hire 75 additional auditorsthis year in NYOIG. First Annual NY OIG Work Plan issued by James Sheehan on April 19, 2008 with a focus on Fraud and Abuse of the 48 billion dollar Medicaid program. 3

4. How does Health and Home Care Structure its Compliance Program? Developed and expanded our comprehensive internal audit and Compliance Program to: Monitor and audit areas based on the 2008 OIG Work Plan and internal risk assessment areas of concern. Track and trend based on perceived and/or audited process issues Use results to formulate a plan of corrective action Re-audit to determine performance improvement Share comparative audit results quarterly with all department heads at the newly created “audit committee” Develop education programs to address audit findings and improve process and quality issues. 4

5. The Auditing Cycle (Re)Audit Findings Interventions Plan of Corrective Action 5

6. Who Oversees H&HC’s Compliance Program? Compliance Committee Members Executive Director Associate Executive Director/Compliance Officer - Committee Chairman Deputy Executive Director/Chief Nurse Executive Chief Financial Officer Director Patient Safety/ PI Associate Director Nursing/Compliance Privacy Officer Ad Hoc Participants 6

7. The Buck Stops Here… 7

8. New York City Health & Hospitals Corporation Compliance Oversight HHC Pres Corp Compliance Off Corp Compliance Committee Health & Home Care Executive Director Health & Home Care Compliance Officer Health & Home Care Compliance Committee Health & Home Care Employees 8

9. Office of the Inspector General (OIG) Major Home Care Risk Areas include: Billing for falsely credentialed HHA/PCA workers. Billing for services that could be performed by other willing and able caregivers Billing for items or services not actually rendered (All Payers) Billing for medically unnecessary services (All Payers) Submitting claims for equipment, medical supplies and services that are not reasonable and necessary Billing for Services provided to patients who are not confined to their residence (“homebound”)-as defined by the Medicare COPS Insufficient documentation to evidence that services were performed and/or to support reimbursement (All payers) Source: 2008 NY Medicaid OIG Work Plan 9

11. Outlier Audit

12. Cost Report Audit

13. Rehab Audit

14. OASIS Integrity Audit

15. Start of Care Documentation Audit

16. HHA/PCA Attendance Audit and Training Certificate Review

17. Vendor HIPAA Privacy Audits10

18. What Internal Audit Activities Comprise the Compliance Program? Quarterly Mock Surveys HIPAA Privacy and Security Audits Professional and Paraprofessional Quality Integrity Audits Intake Audit Select Data External Coding Audit Select Data Invoice Review Post Billing Audits Managed Care denials followed-up for resolution 11

19. Professional and Paraprofessional Quality Integrity Audits A total of 217 patients (approx. 20% of census) were contacted during Q4 2007 to confirm Clinician Visits 100% of visits were found to have been made. We expanded this Professional Services audit to include attendance checks of HHA/PCAs beginning April 1st, 2008 Continuous review of HHA training certifications of new aides assigned to our cases and compare with the AG list of fraudulent training schools 12

20. What Activities Will Ensure Continued Compliance in the Future? Enhancing the visibility of the Compliance Program via Compliance Fairs, Compliance topic presentations at monthly borough meeting, posters with the theme that “Compliance is Everyone's Responsibility”, Compliance Newsletter and Compliance Tips Continue audits to address the annual NY OIG Work Plan and other risk areas identified by our internal risk assessment Expanding HIPAA Security audits in coordination with central IS Expanding clinical review functions Developing educational initiatives to address significant audit findings or areas where clinical, operational or financial improvements are indicated 13