Boerner Consulting is a company with a strong emphasis on integrity and openness. Boerner Consulting’s competitive advantage is its ability to assemble a team of professionals, each selected for their experience and expertise with a particular industry segment or project type. This flexible approach to staffing allows Boerner Consulting to offer its clients access to the most qualified experts for their compliance projects.

Boerner Consulting consultants take great pride in their commitment to develop a thorough understanding of your objectives, needs and expectations in order to meet them. We have a passion for the work we do and conduct ourselves with honesty and integrity. All subcontractors engaged through Boerner Consulting must sign our own internal Standards of Conduct.

Types of services provided to support Compliance Officers within each element of their compliance program include:

Compliance Officer and Compliance Committee:

• Interim Compliance Officer, HIPAA Privacy Officer and HIPAA Security Officer positions
• Develop/review Compliance Plan
• Develop/review Compliance Committees structures and processes
• Perform a staffing assessment of the Compliance Department
• Develop/review structure of reports to the Board of Directors

Standards and Code of Conduct:

• Develop/review Standards/ Code of Conduct

Policies and Procedures:

• Develop/review policies and procedures in operational risk areas including:
  1. Screening employees and medical/clinical staff against the OIG’s LEIE and GSA’s     EPLS
  2. Conflicts of Interest
  3. Referrals and Kickbacks
  4. Gifts and Gratuities
  5. EMTALA
  6. CDM Maintenance
  7. Medicare Cost Reports
  8. Physician Contracting
  9. Charity Care
  10. Advanced Beneficiary Notice (ABNs)
  11. Outpatient Services and Medicare Three-Day Window (i.e., 72 hour rule)
  12. Inpatient admissions versus Outpatient Observation
  13. Post Acute Care Transfers
  14. Medicare Bad Debt
  15. Medicare Secondary Payer (MSP) Monitoring and Billing
  16. Confirming and Refunding Overpayments
  17. Coding and Documentation for Inpatient Services
  18. Coding and Documentation for Outpatient Services
  19. Physician Query/Clarification Process
  20. Teaching Physician E&M Services
  21. Research
  22. HIPAA Privacy
  23. HIPAA Security
  24. 340B Drug Pricing Program

General Compliance Training:

• Develop/review content of general compliance training
• Develop/review content of new employee orientation compliance training

Specialized Compliance Training:

• Conduct a compliance training needs assessments through focus groups of supervisors and managers
• Develop/review content for supervisor/manager compliance training
• Develop/review content of Board of Director compliance training
• Develop/review content of specialized compliance training within operational risk areas

Reporting Mechanism:

• Perform/support compliance investigations
• Develop/review policies and procedures on how to conduct an internal investigation
• Develop/review policies and procedures on how to respond to federal or state agencies and/or regulatory agency visits

Monitoring and Auditing:

• Perform Compliance Program Effectiveness Review – Hospital
• Perform Compliance Program Effectiveness Review – Health Plan
• Perform Compliance Program Effectiveness Review – SNF
• Perform Compliance Employee Survey for outcome measures within each element
• Develop/review/perform Compliance Work Plan (including monitoring)
• Develop/review/perform Compliance Audit Plan
• Develop/review/perform Compliance Annual Risk Assessment
• Perform HIPAA Privacy and HIPAA Security risk analysis
• Professional Fee Coding and Billing reviews
• Hospital Coding and Billing reviews
• Skilled Nursing Facility RUGS reviews
• Support for PEPPER report monitoring activities
• Charge Description Master (CDM) Reviews
• Charge Capture Review Services
• CDM Maintenance & Support Services
• Perform initial assessment of research billing compliance processes
• Perform Medicare Coverage Analyses (“MCA”)
• Perform initial assessment and review of IRB processes
• Indirect Cost Rate Calculations scope and accuracy reviews
• RAC pre-review assessments
• 340B Program Compliance Assessment

Response and Prevention:

• Perform/support root cause analysis
• Develop/review Corrective Action plans
• Support Calculation of Overpayments process
• Support Self Disclosure process to CMS or OIG
• Support HIPAA Breach Notification process to OCR
• Support RAC appeals process
• Support 340B Program Corrective Action Plans

Enforcement and Discipline:

• Develop/review disciplinary standards