Compliance | Accountable Care Association


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 Officer: 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.

Care Coordination Participation Waiver

To achieve improved individualized outcomes by continuing to monitor the care of high-risk clinic and post discharge patients, 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 August 25, 2017.

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 January 22, 2016.

Mental or Behavioral Health Space for Care Coordination Participation 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 Participation Waiver

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 September 23, 2016.

Electronic Health Record ("EHR") System Participation Waiver

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 September 22, 2017.

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 May 25, 2018.

Phase II Cardiac Rehab Participation Waiver

Phase II Cardiac Rehab Program will be offered to a segment of patients with acute heart failure who may not meet traditional criteria for Cardiac Rehab benefits. Benefits include a reduction in 30 day readmission rate, decreased heart failure readmission rate, improved quality of life, increasing exercise capacity, expanding patient knowledge and decreasing depression and anxiety. Adopted by the Board of Managers on September 22, 2017.

Palliative Care Office Space and Home Visits Care Coordination Participation Waiver

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 Participation Waiver

To improve access to early breast cancer detection, providers with the ACO desire to make available high risk breast cancer care program providers in a single location such as primary care provider clinics by making exam room and/or work space available. Surgeons and breast cancer care providers would be more readily available for initial screenings and coordinated care planning within the a single location such as 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.

Hospital at Home Waiver

To provide services to patients who choose to avoid hospitalization as clinically appropriate in compliance with eligibility criteria as outlined in the waiver. Patients who meet criteria voluntarily enter the Hospital at Home® Program to complete their care plan in their home environment. Approved by the Board of Managers on May 25, 2018.

Funds Flow Participation Waiver

The Next Generation ACO funds flow ("NGACO Funds Flow") is an arrangement that entails (i) an incentive-based payment system that rewards providers who are high-performers on key quality/utilization targets measures through by drawing on a pool of money paidfee-for-service funds withheld by CMS on to UAC's behalf to fund a "Global Incentive Plan" and (ii) management of the distribution of UAC's savings/losses on UAC's agreement with CMS to participate in the Next Generation ACO program ("CMS NGACO Model Participation Agreement"). The model also provides for similar arrangements applying with respect to third party payor arrangements which include a value-based arrangement or shared savings/losses arrangement with UAC and UAC network providers who elect to participate in such arrangements. Approved by the Board of Managers on December 1, 2017.