Chapter 3: Running an Effective Compliance Program

Resource: Sample Risk Rating Survey

Risk

Impact

Probability

Comments

Medical director arrangements

Consulting arrangements with pharmaceutical companies

Evaluation and management documentation, coding and billing

Employed physician compensation

Inappropriate access to protected health information (PHI) by employees

Misdirected faxes of PHI

Billing for surgical procedures

Waiver of copayments and deductibles

Billing for incident-to services provided by mid-levels

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About SCCE

The Society of Corporate Compliance and Ethics (SCCE) is a non-profit, member-based professional association. SCCE supports our members' work with education, news, and discussion forums. We are a community of leaders, defining and shaping the corporate compliance environment across a wide range of industries and geographic regions. In developing and maintaining effective ethics and compliance programs, our members strengthen and protect their companies.

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About HCCA

The Health Care Compliance Association (HCCA), is a 501(c)6 non-profit, member-based professional association. HCCA was established in 1996 and is headquartered in Minneapolis, MN. We provide training, certification, and other resources to over 10,000 members. Our members include compliance officers and staff from a wide range of organizations, including hospitals, research facilities, clinics and technology service providers.

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