HET Resources

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Benchmark Resources - benchmark models and measures of program effectiveness, code of conduct provisions, compliance policies and procedures, hotline operation and most elements of ethics and compliance programs.

The Compliance Officers Checklist (Adobe PDF) MEMBERS ONLY

The Ethics Test® (Adobe PDF) MEMBERS ONLY

The Hotline Effectiveness Checklist (Adobe PDF) MEMBERS ONLY

The Hotline Handbook - guidelines for establishing and operating the hotline. (Other Council publications)

The Pastin Report on Healthcare Compliance Programs - a monthly newsletter on practical issues faced by ethics, compliance and integrity officers in healthcare organizations. (Back issues / Excerpts)

Talk About Compliance - An e-mail list-serve.

Government Resources

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The federal government web sites are excellent sources of information concerning issues that are important to, or affect the operation of, corporate compliance programs. The following are just SOME (by no means all) of the web sites that contain documents and information with which all compliance professionals should be familiar.

A. Department of Health and Human Services – Office of Inspector General

OIG Workplan 2007 (outline of major projects, including audits, investigations, enforcement actions etc. to be undertaken by the OIG during the fiscal year): http://oig.hhs.gov/publications/docs/workplan/2007/Work%20Plan%202007.pdf

OIG Red Book 2002 (describes proposed cost saving measures and actions to be taken to save money in government funded healthcare programs): http://oig.hhs.gov/publications/docs/redbook/2002%20Red%20Book.pdf

OIG Semi-Annual Reports (description of activities including enforcement procedures concluded during the relevant period – most recent reports are April-Sept 2002 and Oct-March 2002): http://oig.hhs.gov/publications/semiannual.html#1

Compliance Guidances (proposed compliance plans for specific healthcare industry segments, e.g. hospitals, small physician practices, home health agencies, labs, etc.): http://www.oig.hhs.gov/fraud/complianceguidance.html

Fraud Alerts/Bulletins (OIG notices of issues or practices that are deemed suspect and which OIG is likely to investigate in the near future): http://www.oig.hhs.gov/fraud/fraudalerts.html

OIG Advisory Opinions (formal opinions from the OIG, concerning specific arrangements, programs or activities by providers, determining whether the identified practice or program would be subject to sanction under federal law): http://oig.hhs.gov/fraud/advisoryopinions/opinions.html (for 2003 and 2002 opinions)

B. DHHS – Centers for Medicare and Medicaid Services (Medicare and Medicaid Program Manuals and Memoranda): http://www.hcfa.gov/pubforms/progman.htm

C. HIPAA Privacy Regulations (final regs published in the Federal Register 12/28/00): 65 Fed. Reg. 82462-29; text found at: http://aspe.os.dhhs.gov/admnsimp/final/PvcTxt01.htm

Final Final Privacy Regulations (incorporating changes proposed in March 2002 and additional modifications): http://www.hhs.gov/ocr/hipaa/
Final HIPAA Security Regulations (published in Federal Register on February 20, 2003): http://www.access.gpo.gov/su_docs/fedreg/a030220c.html

Final Transactions and Code Sets Regulations (published February 20, 2003):
http://www.access.gpo.gov/su_docs/fedreg/a030220c.html

Model Compliance Plan and Instructions for Electronic Filing of Plan (to obtain one year extension on October 2002 deadline for electronic health care transactions requirements): http://www.cms.hhs.gov/hipaa/hipaa2/default.asp

Office of Civil Rights (up to date postings on government actions with regard to HIPAA including first Guidance document): http://www.hhs.gov/ocr/hipaa/

FAQ (Frequently Asked Questions) Guidance Memo from OCR published in October, 2002: http://www.hhs.gov/ocr/hipaa/assist.html


D. STARK II "Final Regulations" Phase 1 (published in the Federal Register on January 4, 2001) at 66 Fed. Reg. 856; text found under Health Care Financing Administration at : http://www.access.gpo.gov/su_docs/fedreg/a010104c.html

E. US Sentencing Commission

Federal Sentencing Guidelines (including description of elements of an "effective corporate compliance program"): http://www.ussc.gov/guidelin.htm

F. US Department of Justice

"What’s Hot" page (current issues of concern or interest to the Justice Department, including areas of heightened enforcement or investigation): http://www.usdoj.gov/01whatsnew/01_3.html

G. Federal Trade Commission

Privacy Initiatives (e.g. Children’s Online Privacy Protection Rule; Gramm-Leach-Bliley Act): http://www.ftc.gov/privacy/index.html

H. Government Accounting Office (GAO)

Daybook listings (publications of reports, audits, Congressional testimony by subject areas): http://www.gao.gov/daybook/daybook.htm

I. Sarbanes-Oxley

Federal statute: http://news.findlaw.com/hdocs/docs/gwbush/sarbanesoxley072302.pdf

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Links

Center for Corporate Citizenship at Boston College The Center for Corporate Citizenship is a leading resource on corporate citizenship, providing research, executive education, consultation and convenings on citizenship topics. The Center’s mission is to establish corporate citizenship as a business essential, so all companies act as economic and social assets to the communities they impact by integrating societal interests with other core business objectives. It offers research and development on corporate citizenship; publications including newsletters, research reports, and white papers; executive education programs, including a Certificate program; consulting; convenings that include an annual conference, roundtables and regional meetings; a corporate membership program; and a website that provides an online meeting place for the corporate citizenship community.

Government Departments and Agencies A list maintained by Yahoo of important government departments and agencies.

Department of Health and Human Services - Home Page Information about HHS, press releases, fact sheets, and congressional testimony. An area called Consumer Information includes on-line publications and databases for health groups. Research, Policy and Administration includes research dada and internet information. Also included are: Employee Information, Partner Gateway (HHS resources on the Web), Search (database sponsored by the Office of the Secretary and other HHS entities) and What's New (updates to the web site).

Department of Health and Human Services - OIG Under OIG Reports, you will find the current Audit, Inspection and Cumulative Sanction reports, OIG's Red Book, Semi-Annual Report, and the OIG Work Plan. Under OIG Information, Advisory Opinions, Special Fraud Alerts, Media Advisories, Model Compliance Plans, Negotiated Rulemaking, Partnership Plan, Program Manuals, and Other Information (Operation Restore Trust) are listed.

Department of Health and Human Services- Organization OIG background information, organizational chart, and links to the following offices: Audit Services, Evaluation and Inspections, Investigations, Counsel to the Inspector General and Management and Policy.

Department of Justice - Home Page Choose from topics such as Organizations and Information, Press releases, Speeches and Statements, Publications and Documents, and the Freedom of Information Act (FOIA).

Department of Justice - OIG Read Special Reports, Congressional Testimony, and Reports including Audit and Inspection.

Environmental Protection Agency The EPA posts press releases, fact sheets, newsletters and publications as well as federal regulations. Other topics included are Concerned Citizens, Business and Industry, Researchers and Scientists, and State, Local and Tribal Governments.

General Accounting Office As the investigative arm of congress, the GAO performs audits and evaluations of government programs and activities. Access GAO Reports and Testimonies, Reports on Federal Agency Rules, and GAO Policy and Guidance Publications. Subscribe to GAO Daybook, and on-line list detailing reports and testimonies as released.

Government Printing Office Access government information products and documents from the GPO WAIS database. Databases include Congressional Bills, the Congressional Record, the Federal Register, GAO Reports, Government Information Locator Service (GILS), Privacy Act Notices, Public Laws, and Supreme Court Decisions.

Centers for Medicare & Medicaid Services Research statistics and data, laws and regulations, initiatives and programs. Read press releases, fact sheets, speeches and testimony.

IGnet A helpful site for finding out what's going on in the IG community. This site contains IG Home pages, the IG Directory, the IG Community Manual, and information on the President's Council on Integrity and Efficiency. Additional resources include a virtual library, writer's tools, and a guide to using the internet more effectively.

MedWatch The Food and Drug Administration's medical products reporting program. It is designed to educate all health professionals about the importance of, monitoring for, and reporting of adverse events and problems.

Office of Government Ethics Offers information on publications, resources and the ethics programs they administer.

Report on Medicare Compliance A newsletter published by Atlantic Information Services, Inc., RMC is a source on how-to news on Medicare fraud and big-dollar false claims and billings problems. You'll learn how to audit and monitor your billing practices, which compliance programs work to prevent and detect potential violations, and how you can avoid cost reporting and DRG upcoding problems.

Thomas A guide to all legislation in Congress, Thomas is a service provided through the Library of Congress. This site lists House and Senate directorires, Library of Congress legislative, executive, judicial and state/local links, Congress daily news, floor activity, summaries of bills of the current and previous Congresses, bill texts, legislation, and public laws. In addition to current information, it explains the legislative process and provides historical documents.

U.S. Sentencing Commission This site includes General Information, Reports to Congress, Publications, Guidelines Manuals and Amendments, Guideline Training and Education, Federal Sentencing Statistics, Commission Meeting Information, Hearing Transcripts and Testimony.

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