CORPORATE COMPLIANCE AND INTERNAL AUDIT WORKING CLOSER RESULTS VP-CHIEF AUDIT, COMPLIANCE, EXECUTIVE SCRIPPS HEALTH, SAN DIEGO

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1 CORPORATE COMPLIANCE AND INTERNAL AUDIT WORKING CLOSER TOGETHER FOR OPTIMAL RESULTS GLEN C. MUELLER VP-CHIEF AUDIT, COMPLIANCE, INFORMATION SECURITY & ERM EXECUTIVE SCRIPPS HEALTH, SAN DIEGO AHIA 32 nd Annual Conference August 25-28, 2013 Chicago, Illinois 1

2 The Call to Action.. 2 As health care providers continue to face dramatic cost reductions over the next few years it will become increasingly important for Internal Audit and Corporate Compliance functions to work closer together and leverage their combined resources and skillsets to maximize the effectiveness of both functions. Whether you organization has these functions combined in one department or are separate departments doesn t change the imperative to increase coordination and maximize the use of resources.

3 Today s Learning Objectives 3 Explore various ways that Internal Audit and Corporate Compliance can work closer together. Discuss computer assisted audit techniques for improving compliance program effectiveness. Describe benefits for internal auditors conducting more compliance related audits in terms of opportunities for being more relevant and increasing interactions with clinical leadership. Prepare a roadmap for working closer together.

4 Let s Get to Know Session Participants 4 Chief Audit Executive (CAE)? Chief Compliance Officer (CCO)? Combined role of CAE and CCO Internal Audit Management? Internal Audit staff Compliance Management? Compliance staff? Others?

5 Let s Get to Know Session Participants continued 5 How many have a single Board Committee governing both Internal Audit and Corporate Compliance? How many have a combined Audit & Compliance Department? How many coordinate the preparation of annual work plans? Are there weekly or monthly meetings of Audit & Compliance leadership? Are issued reports routinely cc d to CCO and CAE?

6 6 Opportunities for Internal Audit and Corporate Compliance to work together Revenue Cycle Audits and Reviews Privacy and IT Audit coordination on multiple dimensions Data mining and development of continuous monitoring mechanisms Conflicts of Interest reviews Application controls reviews for critical compliance related clinical information systems

7 7 Opportunities for Internal Audit and Corporate Compliance to work together continued Physician payment audits Medicare excluded parties monthly monitoring reviews Statistical sampling software (use common tool and subject matter expert) On-line survey tools (use common tool and subject matter expert) Common formats in documents going to Board oversight committee Develop consistent definitions for high, medium, and low risks identified in reports shared with senior management and Board Privacy risk assessment questions added to all internal audits Other examples?

8 8 Computer Assisted Techniques for Improving Compliance Program Effectiveness Having the requisite data mining, information system access, and data analytics capabilities are essential for all functions to be effective! Generally, but not always, Internal Audit has a set of tools that t can be used to further advance compliance functions.

9 9 Examples of Computer Assisted Techniques for Improving Compliance Program Review for provider, employee, and vendor Medicare excluded parties Statistical Sampling Software (i.e. OIG RAT-STATS) Physician payment audits Verification of user status (termed vs. active) for critical clinical systems E&M code utilization comparison for all physicians in a division to identify outliers Search for missing charges by comparing daily schedule to daily charges Other favorites?

10 PHI is Everywhere Internal Auditors can add Privacy Risk Assessment Steps to all audits Patient Food Trays Electronic & paper forms Patient ID stamp plates Written Reports (e.g. Daily Activity Journal) Patient ID Bracelets IV and medication i labels Digital Camera Memory Cards Computer monitors Tele-Tracking Phones & Paging devices X-rays, monitors, EKGs, etc. Insurance Cards Verbal Conversations

11 11 Benefits for internal auditors conducting more compliance related audits (examples) IA gains more understanding of clinical operations Internal controls are examined and strengthened IA has opportunity for increased interactions with clinical leadership at department and executive level Corporate compliance can benefit from additional data mining/ analytics and staff time for testing of controls or compliance with policies. IT Audit expertise can be leveraged by Compliance Department to better understand complex areas and compliance related automated controls

12 Prepare a roadmap for working closer together. 12 Joint development of fannual Work Plans can avoid duplication of effort and gaps in coverage Look at key steering and oversight committees together to see the optimal way to cover the needs of both functions Provide training and education for each others staff on key topics. Establish joint weekly meeting of Privacy, IT Audit, and Information Security to discuss privacy and security issues and new systems in development pipeline

13 13 Summary Comments and Q & A

14 Save the Date September 21-24, rd Annual Conference Austin, Texas 14