Compliance

UnityPoint Accountable Care, L.C. (UAC) has adopted the UnityPoint Health Compliance Program. UnityPoint Health has devoted substantial resources to compliance activities. Since 1997, when the UnityPoint Health (formerly Iowa Health System) Board of Directors adopted the current Compliance Program, the organization and the Compliance Committee have developed over 150 Compliance Policies, many of which will be applicable to UnityPoint Accountable Care, L.C.

In addition, the UnityPoint Health Law Department has been advising the UnityPoint Accountable Care, L.C. Board on compliance matters since the inception of the Iowa Health Accountable Care, L.C.

Conflict of Interest

View UnityPoint Accountable Care, L.C.'s "Conflict of Interest Policy and Questionnaire."

The UnityPoint Accountable Care, L.C. Board of Managers has adopted the Policy I.CE.03(a) Conflict of Interest (Accountable Care Organization) for the purpose of setting forth organizational beliefs and policy with respect to conflicts of interest; identifying those corporate entities and individuals subject to certain requirements under the policy; and explaining the requirements and activities associated with identifying and ethically resolving conflicts of interest on the part of individuals affiliated with the organization.

Disclosure Questionnaires will be completed annually by individuals subject to disclosure requirements under this policy, the Internal Revenue Code, or Medicare/Medicaid program regulations.

Compliance Helpline

UnityPoint Health has established a Corporate Compliance Helpline with two options for reporting (see Policy 1.CE.05, Compliance Helpline ).

This 24-hour toll-free Helpline was established as a reporting mechanism whereby employees, medical staff, ACO participants, ACO providers/supplies, business partners and others associated with UnityPoint Health can report suspected violations and noncompliance issues without fear of retribution or retaliation. Some federal laws impose strict criminal penalties upon entities or persons who illegally retaliate against those who, in good faith, reporting wrong doing. UnityPoint Health does not permit retaliation against anyone who, in good faith, reports suspected wrongdoing.

The Compliance Helpline is an external resource which will make sure your report is anonymous and will be held in the highest confidence.

Suspected illegal activity or fraud, waste and abuse; or retaliation for the reporting of suspected illegal activity or fraud, waste and abuse, can be reported through any of the following means:

  • UnityPoint Accountable Care, L.C. Compliance Official: 1-515-241-3708
  • UnityPoint Health Compliance Officer: 1-515-241-4655
  • UnityPoint Health Audit Services: 1-515-241-6120
  • UnityPoint Health Law Department: 1-515-241-4650; 24/7 Pager: 1-515-242-2227
  • Compliance Helpline 1-800-548-8778 or www.unitypoint.alertline.com
  • 1-800-MEDICARE (1-800-633-4227)

Waivers

The Board of Management for UnityPoint Accountable Care, L.C. (formerly UnityPoint Health Partners, L.C.) has approved the following arrangements for the waivers authorized by CMS and the OIG pursuant to the "Medicare Program; Final Waivers in Connection with the Shared Savings Program" published on November 2, 2011 and the extension of such rules and regulations to the Next Generation ACO Model in the "Notice of Amended Waivers of Certain Fraud and Abuse Law in Connection with the Next Generation ACO Model" issued December 29, 2016.

Integrated Chronic Care Disease Management (ICCDM) Participation Waiver: ACO Participants may participate in a train-the-trainer program sponsored by UAC for an integrated chronic care disease management model to create a consistent strategy to engage patients and create meaningful interactions with the care team. Adopted by the Board of Managers on January 22, 2016.

Care Coordination Participation Waiver: To achieve improved individualized outcomes by continuing to monitor the care of a high risk patient post discharge, ACO participants may contract to provide post discharge services. These services can be provided telephonically or as in home visits. The number and timing of the encounters will be dependent upon the patient's medical condition and the services provided will be for the purposes of medication management and reconciliation, assurance for physician appointment follow-up, reinforcement of patient education, home safety assessment and community health resource and referral. The in-home visit(s) will be supplemental to the Post Discharge Home Visit Benefit Enhancement. Adopted by the Board of Managers on January 27, 2017.

Advanced Care Program Participation Waiver: In order to shift healthcare utilization patterns and prevent complications or readmissions, a Care Navigator nurse may be deployed to a primary care clinic to support the Primary Care Physician (PCP) in care planning and assessing healthcare utilization for the complex, chronically ill patient population. An interdisciplinary team comprised of a physician, nurse, pharmacist, therapist (e.g. physical therapist, speech therapist, occupational therapist), social worker and other experts will be used by the Care Navigator. Adopted by the Board of Managers on January 22, 2016.

Data Reporting Participation Waiver: UAC will support the cost of training individuals to assess current operations and quality reporting activities of ACO Participant physician groups, enable use of IT tools for automated electronic data interface, employ provider workflow data extraction guidelines, and be an ongoing resource to the ACO Participant physicians for the purposes of improving infrastructure. Adopted by the Board of Managers on May 26, 2017.

Mental or Behavioral Health Space for Care Coordination Waiver: To alleviate the shortage of mental and behavioral health services in the communities served by UAC, the waiver allows a PCP to make clinic space available at a rate below fair market value for the purposes of assessment, treatment, and coordinated care planning. Adopted by the Board of Managers on March 31, 2017.

Patient Experience Survey Tool: To further the understanding of patient experience within our network, encourage the use of a standard survey, and to reduce any financial barriers for the provider, UAC will provide access to a selected vendor-administered survey tool and subsidize a portion of the total cost. This arrangement will further promote accountability for the quality of the UAC patients by allowing UAC to evaluate trends and identify potential network opportunities to improve patient experience. Adopted by the Board of Managers on January 22, 2016. Amended by the Board of Managers on September 23, 2016.

Electronic Health Record ("EHR") System: To facilitate the goal of achieving interoperability of EHR systems used by all UAC network providers and encourage the investment in infrastructure that will lead to cost savings and efficient service delivery to patients, UAC will offer Independent UAC physician partners access to the UPH EHR system at a subsidized cost. The expectation is that this arrangement will allow for better integration and sharing of care plans for all patients, including Medicare beneficiaries, which will shorten the decision making process. Adopted by the Board of Managers on January 22, 2016.

Wound Care in Long Term Care Centers Waiver: Hospital wound care nurse offers services for a fee to work alongside the LTC facility nurse for 8 hours a week. The purpose is: to identify wounds early and determine the reason(s) wounds are not healing, to treat wounds earlier, evaluate volume of wounds in the facility and assist in education of treatment. Adopted by the Board of Managers on January 22, 2016.

Palliative Care Via Telehealth Waiver: UnityPoint Clinic will work with area nursing facilities to provide Palliative Medicine services via telehealth free of charge. The following services will be provided: discussions about goals of care, symptom management, prognostication, and referrals to other appropriate providers and community resources. Adopted by the Board of Managers on January 22, 2016.

Emergency Department Consistent Care Program Waiver: To facilitate prevention of unnecessary ER visits or readmissions, ACO Participant facilities may contract with a social worker, registered nurse, and or paramedic/EMS staff member to provide a home visit pre or post-emergency department visit via one or two home care visits and/or several follow-up phone calls. The pre ER visit provides explanation on proposed care plans or how to further develop, assistance with referrals and self-care management. The post ER visit is to further enforce a coordinated approach to care. Adopted by the Board of Managers on January 22, 2016.

Phase II Cardiac Rehab Waiver: Approximately 9 eligible patients a month hospitalized with acute heart failure will be chosen to enroll into the Phase II Cardiac Rehab Program for 6 weeks which includes exercise and education sessions with an emphasis on disease self-management. The overall focus is on the outcomes of reducing 30-day and heart failure readmission rates, improving quality of life, increasing exercise capacity, expanding patient knowledge and decreasing depression and anxiety. Adopted by the Board of Managers on January 22, 2016.

Post Emergency Department Visits Waiver: To facilitate prevention of unnecessary ER visits or readmissions, ACO Participant facilities may contract with a social worker, registered nurse, and or paramedic/EMS staff member to provide a home visit pre or post-emergency department visit via one or two home care visits and/or several follow-up phone calls. The pre ER visit provides explanation on proposed care plans or how to further develop, assistance with referrals and self-care management. The post ER visit is to further enforce a coordinated approach to care. Adopted by the Board of Managers on January 22, 2016.

Palliative Care Office Space and Home Visits Care Coordination: To improve access to palliative care services, providers with the ACO desire to make available palliative care providers/staff in primary care provider clinics by making exam room and/or work space available. Palliative care providers would be more readily available for initial screenings and coordinated care planning within the primary care clinics. Adopted by the Board of Managers on March 31, 2017.

High Risk Breast Clinic Care Coordination Wavier: To improve access to palliative care services, providers with the ACO desire to make available palliative care providers/staff in primary care provider clinics by making exam room and/or work space available. Palliative care providers would be more readily available for initial screenings and coordinated care planning within the primary care clinics. Adopted by the Board of Managers on March 31, 2017.

Transitional Care to Community – Quincy Medical Group: The Transitional Care to Community team is comprised of Transitional Care Nurses at Quincy Medical Group working with the inpatient rounding physician to coordinate care for patients in the post-discharge period. As a representative of the Primary Care Physician (PCP), the Transitional Care Nurse sees a patient in the hospital, then does telephonic follow-up or makes home visits post-discharge. All inpatient stay information and post-discharge follow up is documented in the clinic electronic medical record to ensure the PCP and medical home team have access. The intended outcome of this service is to reduce Emergency Department (ED) visits, decrease avoidable hospitalizations; increase uses of community based services, and enhance clinical workflow, all of which support the patient in achieving quality outcomes. Approved by the Board of Managers on September 23, 2016.