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Establishing and implementing necessary structure and procedures
Medicare Compliance Officer advice and consultation
Coordination and cooperation with in-house counsel
Ongoing consultation on a retainer basis
Updating policies, procedures, and forms to meet changing regulatory requirements
Liaison and routine dealings with CMS
Medicare Compliance and Quality Improvement Committee
Performance oversight and Reporting-Legal Issues
Fraud, Waste, and Abuse Policies and Procedures and Control Programs
CMS Monitoring and Reporting Issues
State/Federal Regulatory Issues
Medicare Compliance Officer
advice and consultation
According to the Regulations and manuals published by CMS, it is clear that CMS intends that the Medicare Compliance Officer be an independent "watchdog" or "guard dog" whose duties are to report directly to the Board of Directors, and to be independent of the corporate structure otherwise, so that he/she can properly oversee compliance with Medicare regulations and requirements, from licensing, marketing, operations, claims and complaint handling, monitoring fraud, waste, and abuse, and audit functions.
Mr. Lippe, on behalf of the firm, stands ready to serve in the capacity of MCO to fulfill this role if desired by clients, with the firm available to act as outside counsel. As outside counsel, it will be independent of the ordinary reporting lines, and independent of the General Counsel's office. The firm will monitor compliance by ascertaining that proper policies and procedures are adopted, appropriate reporting lines are established, and proper monitoring of marketing materials and activities, fraud, waste, and abuse controls, auditing, reporting, and general regulatory compliance is done. This will be done on a contract basis to assure regulatory compliance with the independence requirement. The MCO will review internal reports, make advice and recommendations, oversee compliance, communicate with CMS in a manner designed to maintain attorney-client confidences, and report to the Board.