** ***** ************ **********
Corporate Compliance. Regulatory Affairs. Revenue Cycle Management Reviews
& Analysis.
Accreditation Prep and Survey Readiness. Customer/Physician Relations.
Quality Improvement. Risk Management. HIPAA - Privacy/ Security.
Identity Theft Prevention. PCI - Data Security Standards.
The Compliance Source, LLC
April 27, 2010 to current
. Compliance & Regulatory resource for physician practices and other
healthcare entities as the PPACA initiatives to detect fraud and abuse
are to become mandatory, nationally. Auditor/Monitor all practice
Regulatory Affairs: CMS/AHCA billing, HIPAA, Stark, AKS, OSHA, CLIA,
HCCL, Accreditation prep and more.
. Revenue Cycle reviews and analysis to identify opportunities for
improvement, streamline processes and standardize controls to ensure the
integrity and efficiency of the production of each claim and its accurate
adjudication and collections
. Published in SFL Hospital News and Healthcare Report, "Delusions of an
Industry" - July 2010
. Independent Contractor associated with Beacon Partners and Colaborate
for per diem/contractual work
. Develop and implement audit services to complement the needs of
National healthcare consulting agencies in all Regulatory areas, most
notably ARRA/HiTech Act - Meaningful Use Data, Business Associate
Agreements & Breach Notifications.
. Independent Contractor associated with Source Staffing, LLC a
recruitment and staffing agency for the placement of physicians and mid-
level providers.
. SBA Small business woman-owned buying partner for products, goods and
services for Federal Agencies. Registered Central Contractor.
DUNS # 963447938 CAGE # 632W8
Regulatory Compliance & HIPAA Auditor - Broward Health. 1613 SE 17th St.
Ft. Lauderdale, FL 33316. 954-***-****.
March 31, 2008 - April 26, 2010
. Responsible for the investigation and response to all Federal/State
Regulatory inquiries, including OIG, CMS/AHCA, RAC, OCR complaints;
established a communication strategy for Regulatory Affairs.
. Departmental liaison, auditor and committee manager for the Laboratory
Compliance Program, including audit project management and oversight of
corrective actions and reporting: RFP/Contractor selection, remote and on-
site audit facilitation, corrective action plan development and
monitoring.
. Developed and formalized through documentation, committee and reporting
structure, and process institution, a comprehensive, Privacy and Security
Program, including work plan and audit plan.
. Updated, reviewed and revised 41 HIPAA policies and procedures, including
development of a Breach Investigation and Notification tiered review
process to comply with the new Regulations of 2009 (ARRA/HITECH
Act/Breach Notifications), including update of the Business Associate
Agreement and all training/education initiatives.
. Created a Medical Identity Theft Investigation and Response process to
address the rising number of identity theft allegations reported to the
medical center and in preparation for the June 1, 2010 effective date of
the "Red Flag Rules" of Fair and Accurate Credit Transactions Act of
2003: formalized the Identity Theft Prevention Program and related
policies/procedures, in addition to the initiation of a PCI-DSS
compliance risk assessment for credit card security.
. Established a Privacy & Security Sub-committee, including the development
of its charge, charter and working responsibilities, including a tiered
review of all breaches and HIPAA privacy violations.
. Informally appointed compliance expert within the Department of
Compliance & Ethics; provided guidance to less senior staff in the
department with regard to all compliance risk areas.
Corporate Compliance & Privacy Officer (Director). Sheridan Healthcorp,
Inc. 1613 N. Harrison Parkway, Suite 200. Sunrise, FL 33323 1(800)437-
2672 December 4, 2000 - April 28, 2006
. Developed and implemented a comprehensive corporate compliance program at
a large, national multi-specialty physician group and billing company.
The Company has representation in 14 states, at more than 75 locations
and employs more than 1400. All elements of the OIG Compliance Program
Guidance were satisfied including the ongoing training/education,
auditing/monitoring, investigations/corrective actions, reporting
mechanisms and the establishment of requisite policies/procedures and a
code of conduct.
. Responsible for program budget, work plan development and leadership for
a team of 5.
. Created a "Compliance Extension Program" model to reduce risk of exposure
to fraud and abuse at off-site billing locations.
. Achieved and sustained significant results with respect to increasing
billing and collections in the Anesthesia, Emergency, Neonatology and
Office Based Divisions. Compliance Program initiatives driven by data
tracking, trending and monitoring using quality improvement tools and
techniques.
. Revenue Cycle Reviews and Analyses to identify efficiencies, process
improvements, implement controls and streamline production throughout the
patient care delivery continuum - from provider credentialing and
enrollment thru to patient scheduling, registration, encounter
documentation and coding, billing and collections.
. Office-based division oversight and compliance with FL State HCCL
requirements, OSHA, CLIA and more.
. Implemented controls in high-risk areas and established a formal
reporting relationship with the Board of Directors. Provided leadership,
support and reports to the Compliance & Integrity Committee.
. Directed the successful implementation of the HIPAA Privacy Regulations,
including all related training, policy and procedure generation and
monitoring processes.
. Assisted the General Counsel with the creation of a corporate Risk
Management and Quality Improvement Program.
. An integral member of the "sales team", a group of individuals that
represented the Company to attract new business or potential facility
contracts. Team lead of due diligence audits with respect to the purchase
of physician practices, new facility contracts and acquisitions.
Corporate Compliance Officer. Mount Sinai Medical Center / Miami Heart
Institute. 4300 Alton Road Miami Beach, FL 33140 305-***-**** (Mgr.,
Nov. '98 - Nov. '99/Officer, Nov. '99 - Dec. 2000)
. Responsible for the development, implementation and ongoing
administration of a corporate compliance program in accordance with
the OIG Program Guidance for Hospitals, Laboratories, Home Health
Agencies and Physician practices.
. Compliance Program development included the creation of a code of
ethics as well as all training materials and policies and procedures
in support of the compliance program and execution of all other
auditing/monitoring elements.
. Provided periodic reports to in-house Counsel and the Board of
Trustees regarding Program implementation and status of compliance
with regulatory and institutional policies for all components of the
medical center: hospital, skilled nursing facility, home health
agency, physician practices and laboratory.
. Organizational lead working with outside counsel to negotiate
repayment/demand of the OIG for false claims associated with miscoding
of investigational devices; strategy resulted in more than a 75%
reduction in the monetary repayment. No CIA was demanded, at that
time.
. Advised Board of regulatory changes, areas of liability and corrective
actions.
. Developed and adhered to annual corporate compliance work and audit
plan.
. Facilitated institutional compliance in accord with Medicare Bulletins
and Fiscal Intermediary communications and chargemaster reviews.
. Interacted regularly with senior administration, counsel, regulatory
agencies, physicians and departmental directors.
Director of Regulatory Affairs. Montefiore Medical Center. 111 E. 210th St.
Bronx, New York. 10467 718-***-**** Progressive Leadership
(June 1994 - September 1998)
. Responsible for ensuring compliance with all regulatory and
accreditation requirements, including but not limited to, JCAHO and
NYSDOH.
. Provided leadership for the preparation and process for the first
JCAHO network accreditation survey (accredited with commendation,
November 1997) and tri-ennial survey of all components: hospital,
skilled nursing facility, home health agency, laboratory, ambulatory
care center, physician practices and contract management organization.
. Collaborated with senior executives in the development and
implementation of the Corporate Compliance Program (subsequently
recognized nationally by the General Accounting Office as a model
program).
. Assisted with the establishment of a 200 member preferred provider
organization.
. Developed training materials for providers and their staff.
. Managed and oversaw the activities of 6 provider liaisons for
education, recruitment and retention of over 2000 physicians.
. Principle liaison between all regulatory agencies and the medical
center.
. Particularly active in enhancing the support of patient rights and
customer service initiatives through various modalities and consult
services.
EDUCATION/Certifications:
Master of Arts Degree. Health Advocacy. Sarah Lawrence College. Bronxville,
New York.
Bachelor of Arts Degree. Psychology. Minor: Health Education. University of
Massachusetts. Lowell, Massachusetts.
Certified in Healthcare Compliance. Health Care Compliance Association.
Minneapolis, Minnesota.
Certified Professional Coder (CPC). American Association of Professional
Coders - AAPC.
MEMBERSHIPS:
Health Care Compliance Association (ACTIVE), Association of Certified Fraud
Examiners (ACTIVE), American Association of Professional Coders (ACTIVE),
Society of Corporate Compliance and Ethics (INACTIVE)
Florida Hospital Association - Corporate Compliance (ACTIVE), Greater Fort
Lauderdale Chamber of Commerce (ACTIVE), South Florida Healthcare Network
Group (ACTIVE)
GAP EXPLANATION:
April 29, 2006 - March 30, 2008
Entrepreneur- Owner, Medspa Partners of FL, LLC d/b/a Radiance Medspa of
Fort Lauderdale.
Researched, investigated and purchased a Broward County franchise territory
from Radiance Medspa Franchise Group. Developed business plan, secured bank
financing, site selection/lease negotiations, medical director recruitment,
architectural plans, contractor selection, design and materials selection,
permitting, equipment purchase, product selection, licensure, - the
franchise parent group filed with the IRS a corporate restructuring and
subsequent bankruptcy. Financing was withdrawn before ground-breaking for
the store in the Fall of 2007; project terminated. Alternative fund
sourcing, business plan revision and other business purchases explored
prior to decision to obtain full-time employment with Broward Health.