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HPMP Compliance Workbook

This exhaustively-researched workbook provides crucial guidance, suggestions and tools for hospitals seeking to develop, update or strengthen their compliance programs, particularly for areas monitored by the Centers for Medicare & Medicaid Services (CMS).

One of the key synergies compliance officers can create is with their hospital's utilization, health information management and quality improvement staff to uncover the root causes of improper payments. The HPMP Compliance Workbook was designed to give these individuals practical guidance and provide helpful tools for identifying and improving hospital compliance program structures and processes that contribute to payment errors due to medically unnecessary services and inaccurate DRG assignment, admission screening criteria noncompliance and insufficient medical record documentation.

The latest edition of this workbook was updated by Catherine Boerner, JD, senior vice president of The Moore Consulting Group, LLC, under contract with TMF and with input from quality improvement organizations, CMS, the Health Care Compliance Association and working compliance officers.

Note: To save files to disk, right click on each icon and choose Save Link As or Save Target As.

File Format
HPMP Compliance Workbook, Sections 1 - 8
Updated 12/05
Improvement Plan Template Tool for Corporate Headquarters
All Appendices in one .zip file ( all files below - 2.8 MB) Zip File  
Appendix A: AHIMA Code of Ethics, revised 2004 AMA Code of Ethics  
Appendix B: AHIMA Standards of Ethical Coding, 1999 version Improvement Plan Template Tool for Corporate Headquarters
Appendix C: Corporate compliance officers should incorporate PEPPER reports into their compliance program auditing and monitoring, by Catherine M. Boerner, JD, CCH Health Care Compliance Letter, Volume 7, Issue 24, November 29, 2004, p.4-6 Improvement Plan Template  
Appendix D: Audit Tool - DRG 079/080 Pneumonia Review, TMF Health Quality Institute Improvement Plan Template  
Appendix E: Audit Tool - Coding Improvement Plan Template  
Appendix F: Audit Tool - Discharge Status Code Validation, Arkansas Foundation for Medical Care Improvement Plan Template Tool for Corporate Headquarters
Appendix G: Patient Discharge Status Policy and Procedure Checklist, Indiana Medicare Quality Improvement Organization Improvement Plan Template Tool for Corporate Headquarters
Appendix H: Postacute Care Transfer Payment Policy, Medicare Program; Changes to the Hospital Inpatient Prospective Payment Systems and Fiscal Year 2006 Rates, Final Rule, 70 FR 47411 - 47420 (August 12, 2005) Improvement Plan Template  
Appendix I: Audit Tool - Admission and DRG Review, TMF Health Quality Institute Improvement Plan Template  
Appendix J: Audit Tool - One-Day Inpatient Stays, Lovelace Health System, NMMRA Improvement Plan Template Tool for Corporate Headquarters
Appendix K: Audit Workplan - One-Day Hospital Stays, The Moore Consulting Group, LLC (MCG) Improvement Plan Template  
Appendix L: Hospital Payment Monitoring Program Fact Sheet, Admitting Orders Examples, Louisiana Health Care Review, Inc. Improvement Plan Template  
Appendix M: HPMP Utilization Management Strategies, Louisiana Health Care Review, Inc. Updated 12/05 Improvement Plan Template  
Appendix N: Medicare Level of Service Matrix, New Mexico Medical Review Association (NMMRA) Improvement Plan Template  
Appendix O: Observation or Inpatient Admission Decision Tree Card, TMF Health Quality Institute Improvement Plan Template Tool for Corporate Headquarters
Appendix P: Medicare Hospital Observation Status, Physician Quick Reference Guide, OMPRO - A Healthcare Quality Resource, November 2003
Updated 12/05
Improvement Plan Template  
Appendix Q: Inpatient Documentation Prompter, TMF Health Quality Institute Improvement Plan Template Tool for Corporate Headquarters
Appendix R: Provider Liable Billing, TrailBlazers Improvement Plan Template Tool for Corporate Headquarters
Appendix S: Applying Root Cause Analysis and Failure Mode and Effect Analysis to our Compliance Programs, by Margaret Hambleton, Journal of Health Care Compliance, Volume 7, Number 2, March/April 2005, pg. 5 Improvement Plan Template Tool for Corporate Headquarters
Appendix T: Joint Commission on Accreditation of Healthcare Organizations (JCAHO)'s "A Framework for a Root Cause Analysis and Action Plan In Response to a Sentinel Event" Excel Format  
Appendix U: Admission Medical-Necessity Errors Abound; Hospitals Try New Compliance Strategies, by Nina Youngstrom, Report on Medicare Compliance, Volume 14, Number 10, March 21, 2005 Improvement Plan Template  
Appendix V: Amendments to Chapter Eight of the United States Sentencing Organizational Guidelines - November 2004 Improvement Plan Template Tool for Corporate Headquarters
Appendix W: OIG and AHLA's Corporate Responsibility and Corporate Compliance: A Resource for Health Care Board of Directors Improvement Plan Template  
Appendix X: List of Web sites for additional resources
Updated 12/05
Improvement Plan Template Tool for Corporate Headquarters

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