3 Compliance Monitoring Trends Impacting Healthcare

So good afternoon, everyone. Good morning for for some of you. I’m sure more on the West Coast, but I’m Morgan Smith, the director of content here at ProviderTrust. Thank you so much for taking the time out of your day to join today’s webinar, three compliance monitoring trends impacting health care in twenty twenty three. Before we get started, I would like to go over a couple of quick housekeeping items. The phone lines have been muted to eliminate any background noise. If you do have a question during this presentation, feel free to type it in the chat or the q and a section. We’ll be kind of tracking those as we go along. And, additionally, we will reserve some time at the end for a quick q and a. We did receive c a CEUs for any of you looking for credits for CHC. That info will be included in our follow-up, email. Today’s presentation is being recorded and will also be distributed in the follow-up email from provider trust, so be on the lookout for that, later today or tomorrow. So let’s let’s jump in really quick. First things first. Oops. Oops. I’m going too quick. If you’re not familiar with provider trust, I wanted to take just a quick moment to give a brief introduction. I won’t read through these specific bullet points, but first and foremost, what’s important for you to know is that we believe everyone deserves a safe health care experience. And we’ve have set new standards for compliance intelligence because we believe that’s that’s really going to lead the way in the industry. We’ve been doing this for more than a decade and and feel like we have a lot of experience to really bring, bring those standards up to par across the industry. We believe deeply in a health care system that is equitable, accessible, affordable, and free of fraud for Americans. And we support that belief by continuously innovating a more intelligent health care compliance monitoring system, which helps providers and payers identify eligibility, compliance, and credential issues within their individual populations. So, if you have any more questions about provider trust, feel free to drop those in the chat. We’d love to to get you some more details. Okay. So let’s dive into today’s presentation. I know we’re all tired of hearing about the COVID nineteen pandemic, but, obviously, we cannot ignore the profound impact, that it’s had on the health care industry and, really, the world if we think about it. Nearly three years have passed, and organizations are still grappling with the challenges they faced when it started. However, the pandemic created additional challenges and has acutely affected the human experience From workforce challenges to shifting consumer behavior, like much of the world around us, health care has changed drastically in those three short years. So what does that mean for health care compliance in twenty twenty three? Right? Luckily, we have two industry experts here with us today to dive in a little deeper, both with more than twenty five years of experience in the compliance and risk field. I love I know, Donna, I see you smirking. You like when I mention that twenty five years number. Right? So today’s presenters include Michael Rosen and Donna Thiel. Myker is Michael. Myker. Michael is a cofounder of ProviderTrust and an industry leader in compliance monitoring and eligibility solutions. Mike is an expert in designing and developing tools and risk management and compliance industries that tackle real world problems that make health care smarter and safer. He’s an active speaker and presenter at compliance legal and risk conferences. And prior to his journey as an entrepreneur, he served as a practicing attorney, general counsel, and president for a global background screening and identity theft restoration firm. So Mike brings a ton of great, insight and perspective, to the compliance issues that we’re facing today. Donna is the chief compliance officer here at ProviderTrust. In addition to running ProviderTrust compliance strategy and execution, she works with compliance officers across the country to strengthen compliance programs, manage government investigations, implement and manage a corporate integrity agreement, and prepare for the various regulatory changes that impact health care providers. She has formally served as the chief compliance officer of a large post acute health care company responsible for all compliance strategy and operations nationwide. I’m sure many of you have already heard from Michael and Donna in the past, but, you know, there are two go to, our go to teammates when when we wanna know, what’s happening, and and what’s coming, in this industry. So without further delay, I’ll turn it over to the both of you. Donna, I think you’re you’re here to kick us off. I think so. Well, thank you, Morgan, and welcome to twenty twenty three. This is our first webinar of the year, and Mike and I love having the opportunity to talk to all of you. I was just trying to sneak a peek at the participants, and I see some, familiar faces or names, I guess, I should say. And we really appreciate that you join us, whenever we have the opportunity to, to talk with you. And I was smirking when Morgan was so kind to say over twenty five and not a bigger number. So thanks, Morgan, for, for that. So today, Mike and I are just gonna spend, thirty minutes or so chatting about, some of the industry priorities. The three we’re going to focus on today are cost containment, mergers and consolidation, or mergers, acquisition, and consolidation. We’re gonna talk about some of the recent government oversight. Certainly hit just briefly on some enforcement trends, and we’ll wrap with a little summary of kind of, kind of all those right basic back to, the one on ones of compliance that we all know are important. And like Morgan said, we’ll certainly try to leave some time for questions and, hopefully, answers if Mike and I know the answers. But feel free to ask questions, as we go. And Morgan will watch that and help us, try to answer your questions in real time. So let’s, get moving. Morgan? We can kinda skip over the that slide. So here are a couple of the priorities that that we, are monitoring, here at provider trust. And I’m sure all of you are as well. So cost containment, right? Every single day we are learning or reading more and more about the challenges that, all of our providers and payers are facing, and really trying to find efficiencies and and having to make some really difficult decisions about cuts. We’re gonna talk about that a little bit more. Labor. Oh my goodness. If you don’t have something in your inbox every single morning, focusing on some of the challenges of, staffing, hiring, getting finding folks to work in our industry, I would be shocked. Another area that, again, probably because of all of the items in number one, we’re really seeing a lot of mergers and acquisitions and consolidations across the industry. So we’re going to, focus a little bit on what that means to us in the compliance world and some things that we should potentially consider. We’re not gonna talk about, the PHE or the public health emergency too much, but certainly would be remiss if we didn’t say that that still continues to be on the top of minds of of all of us in the health care industry. Certain things to think about. Right? What happens when the public emergency, ends? What’s that gonna mean for us? We’re certainly we anticipate seeing, a lot of eligibility changes in in the Medicaid space. We know many, health systems rely on important state Medicaid dollars. So, recognizing that that’s probably, a priority for many of us in twenty twenty three, one that we’re not gonna cover today, but recognizing it is important. Another couple areas, Morgan, thank you, are reimbursement changes or cuts, depending on what industry you’re in. We’re we always see changes right at this time of the year. Some of our our partners are seeing a lot of cuts that makes, things very, very, very challenging. Again, we’re not going to talk about that today, but recognizing that is top of mind for many of you. One of the areas we are gonna talk about a little bit is government oversight. The OIG came out with a special, fraud alert related to telehealth, so we’re gonna dig into that a little bit more. And then certainly when we see, government oversight, that generally means more audits for all of us. So we’ll we’ll talk a little bit about that. And then the last one, again, we’re not gonna talk about, but recognizing, more data, more risk, more breaches. We see that, every day and certainly recognize that you are all spending a lot of time thinking about what security and what how to protect the very important sensitive information that you all house, and gather. So, again, not topic for today, maybe a future webinar. But we believe those are, a few of the, high priorities in twenty twenty three. So let’s just, start off with cost containment, and we can go ahead and go to the next slide. So, just I think I don’t know if it was over the weekend or last week. There was a a Becker’s article that just focused on seventeen health systems that had, reported cuts just in the last two months. And I think, like, when we’re thinking about cuts that are happening, we know all the organizations are really looking at cost containment. But when we think about, cutting staff or or maybe it’s not staff, maybe it’s reorganization. So you look at, some of these statistics. Right? In in these seventeen organizations, in the explicit examples that were given, they identified over three thousand five hundred specific positions that were cut across, some of those organizations. Six were highlighting, kind of reduction in services or or closing practices. When I was looking at it, you know, we saw, hospitals that are being closed, practice groups that are being closed. We saw, changing from a hospital to a freestanding emergency department. One of the examples was reducing, maternity, delivery services in a hospital. So it’s ranging from all different sorts of of changes and then really reengineering leadership or changing corporate structure. A lot of the, systems were maybe not filling open positions and just eliminating those roles in a way to try to, control costs. One of, one of the examples, another article that I was reading spoke about, a health system out of Boston who had made the decision to eliminate the CEO role explicitly across all their hospitals and really consolidating into the COO role and expanding that role in in trying to, you know, reduce maybe one of the layers in the organization. So organizations today, are just being very, very creative. And as that last, item says, right, one size doesn’t fit all. And and if Chris Reddich, one of our co other cofounders was here, he would tell you kind of one of the things that he’s taught all of us, right, is when you’ve seen one health care organization, you’ve seen one. And that is so true, right, in in the world that we’re facing today. We all have to be extremely creative in trying to find ways to meet our patient needs. And, and I think it’s just important to remember, like the these we recognize that these cost containment measures are really difficult decisions and we know bring a lot of stress to, to each and every one of you in trying to make those patient care decisions. And we keep going, on to the next slide. Another really, important area as we’re looking at cost containment is staffing. Right? We talked about labor shortages. And when you look at your p and l’s or your bottom line, generally speaking, right, what we see is about half of the expense that a health care organization faces is labor. And we’re starting to see shortages in labor. This particular slide talks about some nursing strikes that we’ve seen. We know in Minnesota back in September, I believe there were about fifteen thousand nurses that went on strike, almost went on strike a second time, to really bolster their position on, what they felt were understaffing. We’re seeing that across the country. In this particular slide, we highlighted California and Oregon, Michigan, statistics, and I’m gonna cheat and look at my notes here, is that the National Council, for the state boards of nursing indicated that in twenty twenty one, there were four point four million registered nurses, but yet the Department of Labor only indicated that there were three million employed nurses. So So that’s just, I think, a really interesting statistic and makes you think about, gosh, how many nurses are leaving the industry? What are they taking different positions because of the stress that they’re feeling, and the challenges that they’re faced? So we know that this is a real challenge for us. On the compliance side, I think it brings, opportunity for us to think about how do we how do we manage that? How do we think about, when we’re trying when we have kind of that open door, people are coming and going so fast. How are we making sure people are properly credentialed? So definitely a place where, causes a lot of anxiety to a lot of people within them. Donna, I wanted to add. We we heard of a situation recently where someone’s child needed services, went to a children’s hospital, and, they, for whatever reason, didn’t have enough nurse or child anesthetists on on staff and ended up having to bring in from the adult side of the hospital, you know, somebody who’s trained for adults. That’s scary. That is, could could cause, obviously, quality of care issues. Thank thankfully, it did not present a problem ultimately for this child, but we know that that’s what’s happening in the workforce. And so we look to see and expect that there’ll be, you know, pretty deep dive audits by the government or state licensing boards into are the people that you’re placing in these roles, do they have the necessary credentials? Do they have the the PAL certificate, not just an ACLS, for example, if that’s what’s required to move into a children’s or a NIC unit. And when you’re, you know, short staffed and doing the best you can just to get, the patients through through their services with some type of qualified, it’s not gonna be defensible to say, we put someone there who really didn’t have a PALS certificate when in fact that was what was required. So we know that we’re we’re we’re preaching to the choir, but these are the things you really need to be thinking about as you work your staffing workarounds during these strikes and shortages. Absolutely. Thanks, Mike. Morgan, I think we can go to the next slide. So as Morgan said, my background is post acute, so I say near and dear to that, part of the health care spectrum. And, one of the interesting, pieces of information that I saw just, I think, really over the weekend was something that the American Health Care Association put forward. And this really is kind of looking at how, nurses have left the industry and have changed. And so I think, again, you don’t need to focus on the data in the slide, but more importantly, just thinking about as these things are are shifting, right, increase increases the risk to each of our organizations and and really asking ourselves from a compliance perspective, like how are we filling these open positions? Are we really doing background checks? Are we making sure that these people are properly credentialed or licensed? Are they eligible to work? And and when you’re sitting in in your, kind of shoes, what should we be doing? You know, what’s our compliance fund look like for this year? Should we be changing anything? Should we be auditing anything? Should we be asking for different data? And and I just think, this is an area where we have, significant risk in our organizations and an opportunity from a compliance perspective to, to step in and hopefully help keep eyes on, reducing that risk every single day. So let’s move on to the next section we wanna talk about today, and that’s really, mergers, acquisitions, and consolidation. Donna and I are gonna tag team this one. I think what’s important here for us, Donna, if you’ll kick us off on sort of with the trends that we’re seeing, and then I’ll talk a little bit about the private equity impact, at least what from what we’re reading that they’re seeing. Absolutely. And I think, there’s so many statistics. And when I was trying to look at statistics of how many mergers and how many acquisitions and it’s every I think every publication I read had a different story, but it’s a lot. And I know certainly in my inbox, I’m reading about them every day. Certainly at ProviderTrust, we’re seeing lots of our own clients, acquiring other clients or spinning off assets here and there. And, we definitely see post pandemic that things are kind of coming back into whatever normal means. Right? We’re we’re definitely seeing, activity in that way. And we’re also starting to see, financially distressed sellers, right? We just talked about cost containment and labor shortages. And we all know that that means that we’ve spent a lot more money on labor and sometimes contract labor than what was budgeted. And so we have, organizations that maybe are selling because they just don’t have the capital that they need. Maybe we’re refocusing on core business. Right? Maybe we’re spinning off a line of business that we thought, would would help our portfolio but isn’t quite right. So we’re spinning off a whole line of business. And maybe we’re we’re spinning off some of those underperforming units to try to to to really, make sure that our our monies are being spent on those, businesses or, facilities or locations that are the most profitable. So I think that’s what, we’re starting to see as trends, in this mergers and acquisition market. Mike, do you wanna take over? Yeah. Yeah. I’ll add a little bit here to it, from what we’ve seen in in researching and talking with our law firm clients who do due diligence with us on, like, pretransactional, measures. If they’re if they’re getting ready to acquire another company, they wanna do a exclusion or license verification to make sure they’re not buying into a problem, or they could, put that as an exclusion in their agreement with the seller, and they’re responsible for those fines and penalties, etcetera. And what we’ve what we’ve uncovered, both looking at the health care finance, articles that are out there that’s that track this and some of the law firms, Bassberry here in Nashville, for example, is that, what’s changed is what’s what’s been the same is about fifteen percent of the the of the consolidation or mergers last year were financially distressed companies. That’s about on par with what it was in twenty one and twenty, which was sixteen percent. So it’s roughly the same. So fifteen percent of what’s out there being sold are distressed, which means they probably have been cutting back on staffing and potentially compliance and other measures prior to sale, and you need to know what you’re buying into. What what’s drastically changed is the financial and liability of the private equity firm. This is new. There’s a case that we’re we’ll be sending out with the documentation here afterwards, and we blogged about this in the past, where a private equity firm had, purchased an organization. And at the time, they knew that organization was short staffed and staffing with, people that were not licensed. And at the board level, two of the private equity funders were members of the board and were presented with and and decided to implement a study on how that was, why that was happening and how to fix it. They neglected to ultimately fix it and continue to bill the government, which were all false claims. The court held not only the operating company, but the PE firm itself and two of the directors individually. The total fines were twenty five million dollars and the, boards of directors each paid five million of that twenty five million. So this is, resulting from a whistleblower case, and it’s filed against the PE firm directly. That’s new. That’s scaring and waking up the PE firms. And as far as due diligence is concerned, they’re gonna be looking for you to prove that the right things are in place. So this is a relatively new thing that you should be aware of. Next slide. So I think as we I think this is me, Mike. Right? Yeah. Think about what can we do in the compliance world. I always think about when when did I find out about these changes. Right? When I was the compliance officer, when did I find out and really making sure that you’re at the table, make sure that you know when acquisitions are coming so that you have the opportunity kind of to do these last two things, right? Do you have a checklist? Is there a compliance checklist that you have together that says every single time we go through an acquisition, these are the things these are the questions that I want my due diligence team because you’re not on the due diligence team, at least capturing the information. You’re in that post, team who’s reviewing the information, but making sure that you have the right list together to give your team so that you can do a good assessment of the quality of the compliance program or the risks that your organization is considering right in that acquisition. And if you’re going into a new line of business, right, that’s really important because you know what? I don’t know about you, but I certainly don’t know about all the different healthcare continuum. And if it, when it’s a new line of business, there’s a lot of regulatory research, and considerations to do. So those are some of the things that I would consider in the compliance world as we’re looking at different, possibilities of mergers or acquisitions. And, Donna, let me also add because you’ve said this before in our previous webinars. You know, are you does compliance have a seat at the table at your board meetings? Next week, we have a a quarterly board meeting with our board of directors, which includes outside investors, and Donna is presenting as she does every quarter and gives an assessment of what we are doing, how we’re moving towards, showing up things, and gives an honest risk assessment of where things are in the business. You should be able to have that too, and it should be something that’s reported directly to the board. Excellent. And continuing on kind of what would I do in the compliance role, really, like, what is the standard of practice? Right, when you think about exclusions and license verification and just making those folks Mike was just talking about, notice of kind of bad practices from the previous organization. Right? You just want to know, you just want to know what’s happening in that current organization so that your company can properly, manage the acquisition and be clear of what the risk is. And we just talked about if you’re buying a distressed asset, you know, does that, does that heighten your awareness? So I think these are just some good basic standards of practice, as you’re considering, a merger or an acquisition. We said we’re not gonna talk too much about the mercy declaration, but, Don, any major points you wanna address here in showing a few of the points at the bottom in particular that might be of interest? You bet. I think this one is just kind of where we’re at. Right? We know that the, public health emergency was extended just a couple weeks ago or last week. I’ve kinda lost track of what day it is in January already, for another, a hundred or excuse me, for another ninety days. But what I really wanted to point out here and where we’re going to deep dive a bit here is into telehealth next. And one of the things that, just came about in, the Consolidated Appropriations Act that was signed in December for twenty twenty three. I’m not sure you would say it was snuck in, but we know that, there’s lots of things that go into that particular, piece at the end of the year. And one of the things is that they have extended the telehealth, I would call them flexibilities through the end of twenty twenty four. And what that basically means, in my mind, it’s giving the telehealth industry an opportunity to prove their value. Right? To prove that there’s not this fraud that, perhaps the OIG or others are heightening or concerned about right now because everything happens so fast. Right? Telehealth just skyrocketed in, during the pandemic. So there’s there’s just a lot of question. And so I think this really gives the, the telehealth industry an opportunity to prove out their their value proposition, the business model, and the good things that can come of it. The at the bottom and and maybe at the state level, I think it’s just important to note that today, there are only seven states left, that have any sort of public health emergencies emergency still in play. All of those end at the very latest, February today as of this minute, anyways, as of February twenty eighth. And California is that state that has the the longest runway at this point in time. All the rest the other six states all end, I think the like, February seventh, February fifteenth. They’re kind of in those first two weeks of February. So I believe in our information that we’re sending y’all, there’s a link to a great site that lists by state what those public health emergencies are. I think those are the highlights, Mike. Alright. So in our remaining five or six minutes, we’re gonna cover both, telehealth, fraud alert that they’ve issued, some heightened, risk, cases, and enforcement. Not that five minutes is enough time to cover those in detail, but I think you’ll find the links very helpful for you. So what has the OIG come out and said? They’re very concerned about telehealth as they’ve identified, rightfully so, post COVID during and post COVID. Most health care health care institutions, adopted telehealth, partnered with telehealth. And and if you want, you can post in the chat if if you’re one of those organizations. I’m just curious how many of you have had that experience. We don’t have time for a poll. But what the OIG did in this report, summary wise, was they went to six six different OIGs within health care, conducted a study looking across the organizations, and statistically found that in twenty twenty two, more than thirty seven million people, use telehealth. That’s a thirteen fold increase over twenty twenty one. No surprise. That’s post COVID. That’s COVID, you know, best practices, and and I think telehealth is not going away. It is the current and future of of, part of health care. This was six billion dollars worth of reimbursements. So that’s gonna catch the OIG’s attention, and they’ve looked at it and will continue to do so. We’re gonna give you what they think are some of the characteristics that you might look at in partnering with the telehealth provider to make sure that you’re not stepping into violations of the FCA or others. What the reason that is that they’ve identified that there were some pretty big risks both in billing, upcoding, duplicate k duplicate claims, and, they certainly looked at the high volume billers. That’s where they’re always gonna start. They do that with pharmacists. They do that with, opioid prescribers. It’s always the ones that that prescribe the most that they’re gonna look to see if they’re, you know, doing something that is potentially fraudulent. The OIG acknowledges that they don’t have the programs and funding necessary for the oversight yet of telehealth, but they’re looking to and putting in their budgets request to do so. And so they’ve come out with what they believe is a fraud alert, which we’re gonna talk about next, which puts you on notice. Anytime the OIG puts out a special fraud alert, address if your compliance plan is addressing it. We’re gonna talk what those elements are in a second. It is also letting you know that’s what their watchful eye is worried about, so there’ll be increased scrutiny. On the next slide, let’s talk a little bit more in detail about what those characteristics, and what the fraud alert found. So the they issued a a special fraud alert. Here’s the link you’ll get in the presentation. And it is geared toward educating you on, what are the things you should be looking out for if it’s potentially a suspected fraudulent, agreement, in particular for telemedicine. On the next slide, we’re gonna talk about what those are. Now it needs to be said on, that these are not indicative. If you have one or many of these, it does not mean the organ the the partnership you have is fraudulent or is is a problem. It does mean you need to be looking at it more carefully. So what was looked at were telemedicine companies, in particularly, that were recruiting through advertisement free or low out of pocket cost items. You saw COVID tests being sold when they were provided for free by the government. You saw, cases that they looked at in in a republic now about targeting the elderly to do genetic testing and things that weren’t necessary. These are some of the things that telehealth got telemedicine got involved involved in. Practitioner does not have to have, access to medical necessity, or they’re not they’re not actually needed. The the services were not necessary. These are some of the things that they found. So when you look at a telemedicine company doing business with, these are the things you should be careful of. How are they compensating? Are they compensating practitioners based on volumes of service to incent the practitioner? That’s a risk. That should not that should elevate your concern about their practices. Do they only furnish items or services to program beneficiaries, and they don’t accept insurance from other payers? And you can see the others that are listed here in the interest of time. These are things that would identify, potential risks. But, again, just having one of those in the relationship does not in and of itself mean you are in trouble. On the in the next slide, we’re gonna talk also about how this as far as enforcement looks, these are the implications that you could be violating if some or all of those are present and you’re not paying attention to them. That’s a kickback in the first case where they’re paying practitioners to refer people, for testing or they’re going to nursing homes and saying you need this service when you don’t. This could also get your organization, a civil monetary, ultimately excluded as an organization or provider, which, of course, is the death knoll that the OIG has and will only use when, it rises to that level. You could also be subjecting your company or yourself to criminal, fraud, and, certainly, all of those are false claims. So, what’s changed is that practitioners have been held personally liable. Owners of those telemedicine companies, owners of those DME companies, owners of the laboratories, are being held personally liable as a result of this fraud. So as we round out the fraud on telehealth, we also wanted to share with you what are some best practices under the special fraud alert. These are what the OIG says are some skeletal things that you ought to be using in the form of conducting an internal audit to determine whether you have these issues. Or are you monitoring the provider, and are you looking to see their billing and recruiting practices? Are you developing additional billing controls to prevent claims that were false claims? And or is the provider creating and conducting, education that’s necessary to, to to stay above board. Increasing surveys for patients to ensure satisfaction and identify potential concerns. The patients are the easiest whistleblowers, and they’re the quickest to tell you what they think, was wrong or how they were contacted. And that will help you identify possible quality of care metrics and creating an audit plan to address them. So these are the things that if you read the alert, we’ve summarized for you, but the OIG is gonna provide you with some guidance. Let’s talk as we round out today’s presentation on some quick enforcement measures. You can read them in more detail. The telehealth enforcement action was, huge. This was a takedown national takedown, with all of the federal agencies Medicaid, and other authorities. In twenty twenty two, it resulted in criminal charges against both telemedicine companies, telehealth services, in particular, telemarketing services, thirty six defendants across thirteen different federal jurisdictions. Why? Because it was a one point two billion dollar, fraud submitted to Medicare, and they found that the owners of these fraudulent organizations were profiting and doing all kinds of, things with their money. So this was a national takedown. There’s a lot on this that you probably are familiar with but worth noting. And there was a few others we wanted to point out, and we’ll open up to questions. On the next slide, we’re gonna see that there was a a in the genetic testing laboratory cases, there was a key TAM meeting brought by a whistleblower, involving a doctor and her practice. She was performing cataract surgeries in on people who didn’t need them, and, profiting over almost two million dollars to do so, falsely diagnosing patients with glaucoma, just terrible things that created a bunch of harm to, elderly and, vulnerable patients. You can see she was also using, broken machinery and not using medically necessary standards. That’s a really poor position to be in when you’re approaching, trying to settle with the OIG. And then there was operation double helix for those of you who remember DNA and RNA, a play on words. There were, laboratory owners in Texas and Louisiana who, created a big kickbacks scheme involving genetic testing, and they profited over forty four million dollars and are facing criminal measures as well as, civil fines. So these are no no’s. These are what people are doing. Finally, we wanted to point one thing out. For those of you who are doing effective monitoring of licenses, of exclusions, of the things that you do for the best practice, this is not included in the databases, but available on the OIG site. We are not publicly shaming this group, but the OIG is saying these organizations or individuals have been, investigated by the OIG, refused to sign a corporate integrity agreement or an individual integrity agreement, and therefore, they call the OIG calls these highly risk providers. They are not telling you cannot do business with them. They are telling you they are very aware of this comp these companies and are tracking them for compliance. So you’re beginning to see a a potential bad actors list, not just those who’ve been administratively excluded. This is hot off the press, just came out last week. So we wanted to give you these things to to let you know what’s happening and and help you try to avoid them, I hope. In summary, it’s a back to basics program, as Donna said at the beginning. Enforcement’s not going away. Bad actors are not shying away, and the OIG and the DOJ are aware of it. They’re seeing major big dollar nationwide fraud, and they’re going after it. So what should you be doing? You ought to be looking at these alerts, reading them, and then going back and testing your audit and or investigative, measures internally and and maybe update some of the things that you’re searching or looking for when contracting with a third party like a telehealth provider. And, again, make sure these people are licensed. We know that’s difficult during staff and believe that you don’t have to break that in the way the economy is. With that being said, we covered a lot in a short period of time. If there are any questions, we’d love to address them. And, and remember, you may both this presentation, the recording, and some of the alerts that will you. We do hope this is, a scratch surface to give you an idea of where it we we believe at least should be focusing some high level review for your twenty twenty three plan. Yes. And, I appreciate all of the registrants and attendees who are they’ve hung with us about ten ten minutes almost ten minutes over our time. So just to reiterate what Mike just said, I know he cut out just a little bit, but we we will be sending, this slide deck along with, with the links and, the recording of this presentation after. So I totally understand if anybody needs to bounce. However, Mike and Donna, do we have five more minutes to to do add in any questions if possible? So if you do have a question and you have time to hang with us, go ahead and drop those in the chat, or in the q and a. Just to kick us off, it looks like, Donna, one of the and, Mike, one of the last things you said on the summary was about just make sure that your, like, license or operations are up to par. I think one of the questions that I saw come across with telehealth and a contracted workforce, though, I know that some organizations are struggling with keeping up with interstate licensure. So what are some, any suggestions or, are there opportunities to do that more efficiently? Can you guys speak to that at all? Dawn, you wanna go first? Sure. I can go first. I think half of your question is was, like, efficiencies. When we’re talking about, cross border, it is really, really complicated. And I think the the broader spectrum that you can look at and really, unfortunately, time is of the essence, but understanding, where that practitioner has been practicing, understanding, where there are opportunities which states allow, like in the Nurse Compact Act, you know, where are there places where they can. You just really have to know what your state regulations are and then understand what kind of practitioners you have, right? Not every organization has every different kind of practitioner. So focus on the practitioners that you have the highest volume of. Make sure you understand what the licensing regulations are. Or you can always call us, and we’ll help you with that and take all that burden away. But, certainly, cross borders are a challenge and and one where, in my opinion, compliance really needs to be partnering with other teams in the organization and finding who, you know, who’s the subject matter expert or going outside of your organization to to document it once and for all and make sure that you know what those rules are so then you can be communicating that to your hiring team. HR doesn’t necessarily, you know, have that accountability of understanding. So taking on that requirement or that opportunity to educate, HR and the recruitment team and what the requirements are, will be super helpful. Yeah. Two things to add. There are specific to the telehealth, that being an emerging and new area. For those of you who are entertaining that concept or at least auditing, here’s something you need to make sure that you’re doing or your partner is doing. So, for example, if Donna is the patient and calls in and, the system needs to know that she’s calling in from Wisconsin, and the practitioner that is gonna be providing her with some telehealth care has to be licensed in Wisconsin. Or if it’s a nurse, it could, you know, could be in a multi nurse compact state license. Like, it gets complicated really fast, but that is what the compliance has to do to ensure that the practitioner is licensed in the state in which the patient is providing. And the the laws are evolving in this area because, traditionally, it’s been based on an in person visit where you can see, touch, and or have face contact with the patient. That has had to be broadened with telehealth because that’s what the technology brings to the table, but it, therefore, is under a major scrutiny in in interpretation state by state as to what that means when you, by not being in person, but being able to see them online. So it varies by state. The second thing is there is an interstate medical compact that has come out in the last two years that involves physicians. So you have a nurse practitioner comp a nurse compact act, and you have now a medical that, a a good number of states are participating in, not all, that you need to be checking. These are the things that we know where to go when when our clients ask us. But if you’re not using a third party, you the if the onus falls on you to know those things. Great. Thank you. We had one more question come in, and then we’ll wrap. Can the provider work remotely from another state if the patient is in a state where they are licensed? I’m not the lawyer in the room, and I certainly don’t wanna give you legal advice, but I believe that’s accurate. Yes. It but it depends on the state. So, again, it comes down to, believe it or not, the interpretation by that state of, an in person is what a lot of it calls or the ability to see and touch a patient and how they, water that down for telehealth. So it is state specific, But yes. And and I think this is gonna change over time. I think it’s gonna become a more uniformly regulated, But at the moment, there’s no federal regulation on that. It is state by state. Awesome. Well, thank you, Mike and Donna, for, all of your special insights. I know that that I appreciate it, and I hope that all of our attendees really, have some great takeaways as they continue to map out the rest of twenty twenty three and and prioritize. So, for all those on still on the call, thanks again for hanging with us. We’ll, be on the lookout for some follow-up communication, and I hope everyone has a great Wednesday afternoon. Thank you.