Compliance Officer Presentation to Board of Directors: Rationale for Incident Handling

Introduction (Slide 1):

• Welcome and brief introduction of yourself and your role as Compliance Officer.
• State the purpose of the presentation: To explain the rationale behind not self-disclosing three recent potential compliance incidents.

Incident 1: Potential Overbilling (Slide 2-3):

• Briefly describe the suspected overbilling situation for a specific procedure.
• Explain the steps taken to investigate, including reviewing records, coding, and billing practices.
• Emphasize the finding that procedures were documented and billed appropriately based on current regulations and coding manuals.
• Provide rationale for not self-disclosing: Lack of evidence of actual violation, no indication of intentional wrongdoing, and adherence to established practices.

Incident 2: Employee on Exclusion List (Slide 4-5):

• Outline the situation – presence of an employee’s name on an exclusion list.
• Describe the follow-up investigation and verification of the employee’s social security number, confirming it does not match the listed individual.
• Explain the potential consequences of an actual match and the importance of due diligence.
• Justify the non-disclosure: No actual violation identified, no risk to patients or financial integrity, and steps taken to prevent similar occurrences.

Incident 3: Potential Patient Information Breach (Slide 6-7):

• Briefly describe the nature of the potential breach involving two patients.
• Highlight the immediate actions taken to contain the potential breach and limit exposure.
• Explain the ongoing investigation to determine the root cause and scope of the incident.
• Rationale for non-disclosure: Ongoing investigation, preliminary assessment indicates low risk to patient harm, and proactive measures taken to mitigate consequences.

Transparency and Collaboration (Slide 8-9):

• Reiterate commitment to open communication and transparent compliance culture.
• Outline examples of situations where the compliance committee and board would be immediately informed:
  • Confirmed violations of significant regulations or laws.
  • Evidence of intentional wrongdoings or financial misconduct.
  • Breaches with high risk of patient harm or reputational damage.
  • Incidents requiring external reporting or legal intervention.
• Emphasize ongoing communication and collaboration with relevant stakeholders.

Conclusion (Slide 10):

• Summarize the rationale for not self-disclosing the specific incidents.
• Reiterate commitment to responsible and effective compliance management.
• Open the floor for questions and discussion with the board.

Visual aids:

• Use simple and clear visuals to support your presentation points.
• Avoid using confidential patient information or specific details that could jeopardize ongoing investigations.
• Focus on conveying key messages with clarity and professionalism.

Additional considerations:

• Adapt the presentation content and level of detail to the board’s level of understanding and interest.
• Be prepared to answer questions about the incidents and your decision-making process.
• Demonstrate confidence and competence in your role as Compliance Officer.

Remember, this is a sample framework. You can adjust the content, structure, and visual aids based on your specific situation and communication style. The key is to provide a clear and concise explanation for your decisions and demonstrate your commitment to responsible compliance practices.