Compliance Education for the Clinically Integrated Network Objectives

Compliance Education for the Clinically Integrated Network

Objectives To describe the compliance requirements for the Clinically Integrated Network (CIN), including: • Brief overview of the CIN • Understand CIN Compliance Plan • Overview of record retention requirements • Introduction to the CIN Compliance Official 2

Clinically Integrated Network (CIN) Common. Spirit Health is the parent company for each CIN. The Clinically Integrated Network (CIN) is: • Physician managed and governed • An active and ongoing program to promote greater accountability for the quality, effectiveness and efficiency of health care services delivered to patients in the CIN • A network of contracted independent physicians, medical foundations, medical clinics and other professionals and providers 3

CIN Participation Structure The CIN has an attributed beneficiary population through various agreement with payors. Various Payors Group practices and sole practitioners contract with the CIN. In addition, acute care hospitals may also participate in a CIN Acute Care Hospitals Providers and practitioners who bill under the group practice Tax Identification Number (TIN), or SSN of the sole practitioner, are providers of the CIN. Physician Group Practice CIN Participant Providers Medicare-enrolled practitioners, including but not limited to physician, nurse practitioner, and physician assistant, who has entered an agreement with the Participant

Common. Spirit Health has 17 CINs across 11 States *These CINs operate under a Joint Operating Agreement and have separate compliance oversight. Rainier Health Network WA CHI Health Partners Nebraska Mercy Health Network Iowa* Healthcare Solutions Network North State Quality Care Network California Ohio* San Joaquin Quality Care Network California CHI Saint Joseph Health Partners Kentucky Pacific Coast Quality Care Network California Mission Health Care Network Tennessee Central Valley Quality Care Network California Santa Cruz Quality Network California Southern Integrated Quality Care Network California Valley Integrated Provider Network California Arkansas Health Network Arkansas Arizona Care Network Arizona* CHI St. Luke’s Health Network Texas St. Joseph CHI St. Luke’s Health. Regional Health Partners Texas Network Houston , Texas

CIN Compliance Plan Common. Spirit Health has developed a compliance plan based on federal guidelines and policies. The CIN Compliance Plan requires: • A compliance official who reports directly to the ACO governing body • A reporting mechanism for CIN compliance concerns, including anonymous reporting • CIN compliance education • CIN auditing and monitoring 6

CIN Reportable Compliance Concerns Examples of reportable CIN compliance concerns may include, but are not limited to the following: • Withholding patient services to meet savings goals • Avoidance of at-risk beneficiaries • Discrimination • Denying a beneficiary the right to chose healthcare providers and facilities • External official notification of an audit or investigation involving a CIN beneficiary 7

Compliance Reporting Process Everyone is responsible for promptly reporting potential violations of law, regulation, policy or procedure. Individuals are protected from retaliation for making a good-faith report, complaint or inquiry. Report Directly to a Supervisor or CIN Executive Director CIN Compliance Official Supervisor or CIN Executive Director is unavailable Uncomfortable speaking to a supervisor or CIN Executive Director Individual believes the matter has not been adequately resolved Call the Confidential Compliance Hotline Call the reporting hotline 1 -800 -845 -4310 File a report online https: //commonspirit. complytrack. com/Portal/Create. Form/450009

CIN Risk Assessment and Monitoring CIN Risk Assessment An annual system-wide risk assessment based on a variety of sources, including, but not limited to: • • • Regulatory risks based on CMS and state government program guidance Audit findings from CMS Notices of non-compliance from CMS, other government programs, or from commercial health plans Industry guidance Office of the Inspector General (OIG) work plan. New or revised regulatory requirements CIN Entity Level Risk Assessment CIN Work Plan After the System Risk Assessment has been completed, the CIN, acting through the CIN board of managers or the CIN board compliance committee, shall further review risks that are entity level specific based on: The development of the annual work plan for oversight audits will be based upon the results of the risk assessment, the OIG’s annual work plan, supplemental guidance, and identified focus reviews. • • • The CIN compliance committee will recommend an annual work plan to the CIN board of managers. The CIN board of managers may modify the work plan based upon the availability of resources and its unique risk exposure. New operational systems or practices Corrective action plan monitoring Findings from business unit self-audits/internal monitoring For example, all members of the CIN governing body must complete a Conflict of Interest (COI) form before participating in a board meeting, and annually thereafter.

CIN Record Retention The organization and all participating providers in the arrangement are required to maintain and give access to all books, contracts, records, documents, and other evidence needed to CMS to determine if an organization is in compliance. Required to keep books, contracts, records, documents and other evidence for 10 years from: Expiration or termination of the arrangement, OR From the date of completion of any audit, evaluation, inspection or investigation

CIN Compliance Official Christi Knox, MBA, CHC, CHPC System Director, Corporate Responsibility Clinically Integrated Networks and Population Health Phone: (916) 545 -4965 Fax: (602) 604 -4759 Christi. Knox@Dignity. Health. org 11

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