healthcare compliance and credentialing

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Kesha Boykin-McLean

As Chief Compliance Officer, Kesha Boykin-Mclean brings over 20 years of experience in healthcare. Prior to joining VCS, Boykin-Mclean held a number of senior-level compliance roles, including managing and developing the compliance program for St. Francis Hospital in Connecticut. She was also the Division Ethics and Compliance Officer for the Hospital Corporation of America’s Gulf Coast Division where she was responsible for oversight of compliance programs for all hospitals within the division. Most recently, she served as an independent healthcare consultant, assisting hospitals with the planning and implementation of compliance programs.

Blog Feature

Patient Safety | Credentialing

Ebola: New Policies for Staff & Patient Safety

By: Kesha Boykin-McLean
November 24th, 2014

While hundreds of U.S. hospitals are implementing Ebola training requirements and new patient screening protocols, some are going a step further. One facility recently announced that it will place any employee on paid leave who has “in the last month returned to the U.S. from Guinea, Liberia, Sierra Leone, Nigeria and Senegal.” Other facilities are requesting its vendors refrain from sending representatives for 21 days if they traveled to the regions of West Africa within the last month.

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Blog Feature

Compliance | Stark Law

Space Lease - the Stark Exception

By: Kesha Boykin-McLean
November 21st, 2014

The other day, a new Compliance Officer asked the question, “How would you go about conducting a physician leasing audit, and if you realize there are issues, where should you start fixing them?” That was a huge question! How and where to begin are the questions every new hospital Compliance Officer faces. How do you fix a compliance problem? The answer is, “one bit at a time.” First, we must review the hospital’s policy and procedure on Space Lease and also on Equipment Leases. This is typically in the legal department (ideally, all policies and procedures will be maintained in one accessible location). Make sure the policy and the procedures are written to comply with most recent Stark Law Space and Equipment lease exception:

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Access a collection of posts providing you with valuable insights and education dedicated to making governance, risk, and compliance the simplest part of your day.

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Health Connect Partners | Office of Inspector General | Stark Law | Anti-Kickback Statue

Health Connect Partners Conference

By: Kesha Boykin-McLean
November 10th, 2014

At the Health Connect Partners (HCP) Hospital and Healthcare I.T. Conference meeting, we discussed Contracting with Physician-owned Entities and how your compliance program can implement safeguards to ensure that you don’t run afoul of the Anti-Kickback Statue (AKS) and Stark Laws. The Office of Inspector General (OIG) announced that it has moved to evaluating compliance program effectiveness during investigations. So it isn’t enough to have the appropriate policies and procedures in place. Instead we must continually monitor and evaluate the effectiveness of our processes. The Government looks at a number of factors when evaluating agreements with physician-owned companies.

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Blog Feature

Patient Safety | Compliance

Does Public Interest Outweigh Patient Privacy?

By: Kesha Boykin-McLean
November 4th, 2014

How can we know very little about a patient being treated for Ebola at Emory University in Atlanta, while reporting the details of the patient who died from the disease in Dallas? According to Michelle De Moody, Deputy Director for Consumer Privacy at the Center for Democracy and Technology, covered entities can let individuals know if they have been exposed to the disease through contact or shared space with an infected person.

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Compliance | Health Connect Partners | Stark Law | Anti-Kickback Statue

Compliance Program Effectiveness

By: Kesha Boykin-McLean
October 22nd, 2014

So your legal department has a process for contracting with physicians or referral sources. Where do you fit in the process?

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Health Connect Partners | Office of Inspector General | Stark Law | Anti-Kickback Statue

Health Connect Partners Conference 2104

By: Kesha Boykin-McLean
October 16th, 2014

Last week at the Health Connect Partners (HCP) Hospital and Healthcare I.T. Conference in Chicago, we discussed common contracting issues faced by hospital Directors of Materials Management. Materials Management professionals are central to the contracting process and are extremely vigilant about the laws imposed. The Office of Inspector General (OIG) has warned against substantial fraud and abuse issues with Physician-Owned Entities and Hospitals under the federal Anti-Kickback Statue (AKS) and Stark Laws. AKS makes it a criminal offense to knowingly and willfully offer, pay, solicit, or receive any remuneration to induce, or in return for, referrals of items or services reimbursable by a Federal healthcare program. The Stark Law is a civil statute that prohibits physicians from referring Medicare patients for certain designated health services (DHS) to an entity with which the physician has a financial relationship, unless an exception applies. The OIG considers arrangements with Physician-owned entities inherently suspect because the opportunity for a referring physician to earn a profit from the sale or use of a device could be violate AKS and Stark depending upon the intent and the structure of the deal.

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