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OCR

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Let’s Talk Trash

Do you ever have trouble figuring out which trash can to use when throwing something away? Even a simple cardboard coffee cup with a plastic lid may give you pause while trying to choose the best option. Now, you may be confronted with a myriad of sorting choices: paper, aluminum, plastic, paper, glass, all recyclables

Compliance Program: What is the Value?

The value placed on a compliance program varies greatly with perspective and remains difficult to define. Obviously, the purpose of a compliance program is to prevent and deter wrongdoing. A strong program preempts problems. However, it is difficult to know what might happen in the future or what could have gone wrong in the past.

Individual’s Rights to Access PHI

An individual’s right to access their protected health information (PHI) should be nothing new to covered entities. In 1996, HIPAA Privacy Rule detailed an individual’s right to access PHI. As part of HITECH and the Final Omnibus Rule, modifications to the Privacy Rule have included additional requirements for covered entities and business associates. Unfortunately, recent

OIG WORKPLAN 2016

The Office of the Inspector General (OIG) is responsible for protecting the integrity of the programs in Health and Human Services against fraud, waste and abuse as well as recommending improvements to the system that would promote efficiency and efficacy within the limits of the health care laws.   Although OIG oversight includes programs such as

Overview of a Corporate Integrity Agreement (CIA)

Health care fraud recoveries for fiscal years 2009- 2014 exceeded previous records with five straight years of more than $2 billion in annual recovery from cases involving fraud and false claims against federal health care programs such as Medicare and Medicaid.  Most healthcare providers are aware of significant civil liability due to recent enforcement. However,

Are You Prepared for the HIPAA Phase 2 Audits?

After reviewing the HIPAA Privacy case investigations from 2009-2011, the Office of the Inspector General sent a strong message to the Office of Civil Rights in regard to the administration and enforcement of the HIPAA Privacy Rule. The OIG recommendation is clear in the September 2015 executive summary, “OCR Should Strengthen Its Oversight of Covered

How would your staff react to an auditor or investigator?

Audits and investigations are stressful events either with or without prior notice. Medical staff should be prepared for an unannounced visit. First Healthcare Compliance provides a sample policy that assists clients in preparing the front office. Here are some recommendations to ensure that proper steps are taken: Immediately contact your supervisor, manager and/or Compliance Officer

Have you been asked to attest to offshore subcontractor reporting?

There is a renewed focus on the 2007 requirement for offshore outsource reporting  due to significant concern for potential vulnerability of PHI  (See Table 5). The 2014 OIG memorandum to CMS and the OCR describes the study conducted on state Medicaid agencies to assess the outsourcing of administrative functions directly and indirectly.   Outsourcing can be domestic or offshore. Offshore