Our Services

Compliance Program

• Compliance Program Effectiveness Evaluation
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    Strategic Management conducts effectiveness evaluations using its proprietary Comprehensive Compliance Program Evaluation™ method. This method is drawn from the United States Sentencing Commission “Compliance Guidelines for Organizations and Entities”, HHS Office of Inspector General compliance guidance documents, and compliance guidance from other regulatory and enforcement agencies such as CMS. The results include a full report of findings, as well as recommendations for needed corrective or remedial action.
• Program Evaluation, Auditing and Monitoring
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    Strategic Management has wide ranging expertise related to program evaluation, particularly in the areas of detecting indicators of compliance program weakness, ineffective internal controls, and signs of fraud and abuse.
    
    Strategic Management’s experience includes evaluations of program operations tailored to the specific needs of the organization and using generally accepted standards in the areas of planning, data collection and analysis, documentation and reporting.
• Corporate Compliance Program Design and Implementation
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    Strategic Management specializes in developing and implementing compliance programs to meet the unique needs of the health care industry, including hospital systems, ancillary Medicare Advantage and Medicaid Managed Care organizations, and health care providers of all types and sizes. Strategic Management assists organizations with building a top-down structure for the compliance program, beginning at the Board level and continuing through the CEO and other executives and senior managers. Strategic Management routinely assists with sensitive client needs, particularly in relation to meeting their Corporate Integrity Agreement requirements.
• Corporate Compliance Strategic Planning and Advisory Services
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    Strategic Management serves many clients by providing both strategic planning and advisory services. Such services often entail developing corporate compliance work plans for the fiscal year, providing guidance on how compliance officers can increase their effectiveness within their organizations, and how to best position their agenda to the board of directors. We strategize and advise on how to address major industry trends in a proactive and methodical manner. Strategic Management also provides advisory services on how to handle specific situations that arise in the compliance officer’s day-to-day activities.
• Mergers and Acquisitions (M&A) Assistance and Due Diligence Review
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    Strategic Management provides multiple services to assist organizations in the health care industry with merger and acquisition strategies, including “buy versus build” assessments and regulatory due diligence reviews. The “buy versus build assessment” for business planning and M&A strategy includes an analysis of potential income growth assessments and valuation sales growth from Medicare and health care services related business, comparing organic growth versus growth of customer base and market share through mergers & acquisitions.
• Sarbanes-Oxley and Corporate Governance
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    Regulations resulting from the Sarbanes-Oxley law include many best practice standards that can be adapted and integrated within a health care organization’s existing compliance structure. Strategic Management’s approach to assessing these internal controls includes addressing major areas of corporate governance such as Board responsibilities, conflicts of interests, modification of the code, financial management issues, reporting processes, audit independence and others. Please click here to view the “49 Steps to Implement Sarbanes-Oxley Best Practices In Private and Nonprofit Health Care Entities" by Richard P. Kusserow, president of Strategic Management, and Rita Isnar (formerly Kuyumcuoglu), J.D., MPA, Vice President at Strategic Management.

Data Analysis

• Strategic Management’s data analysis services enable health care organizations to trend, analyze, and report on claims and other data that they generate on a daily basis. The Centers for Medicare and Medicaid Services has increased regulatory and enforcement efforts with the use of data analysis techniques and subcontractors. The next frontier in preventing and mitigating risks in the health care industry is to conduct internal data analysis before submitting data to regulators. This enables health care providers to take proactive steps in mitigating any potential enforcement action that might otherwise ensue.

HIPAA Compliance & ARRA HITECH Act

• Strategic Management's HIPAA services center around the importance of understanding and incorporating the regulatory compliance requirements of HIPAA Administrative Simplification, especially regarding the privacy and security of health information, into an existing organizational compliance infrastructure. Strategic Management provides assistance with analysis and implementation of HIPAA requirements. We conduct HIPAA Privacy and Security gap analyses and evaluations for health care providers and their business associates. 

Independent Review Organization, Monitor, & Assessor

• Strategic Management provides independent review services for organizations that have entered into settlement agreements with the government. The reviews include the requisite services of an independent review organization (IRO), monitor, and/or assessor under the HHS OIG, Department of Justice, Office of Civil Rights, or other enforcement agencies. We work with a variety of health care organizations to meet the demands of Corporate Integrity Agreements and other settlement agreements with both federal and state regulators.
  
  We are experienced and qualified as an Independent Review Organization (IRO) to review and assess compliance with the terms of a Corporate Integrity Agreement, whether it is related to managed care operations; evaluating the compliance program; reviewing and auditing arrangement databases; or audit of claims processing systems. Similarly, the Firm is available to assist clients in preparing for audits and reviews.

Legal and Litigation Support

• Strategic Management has assisted many law firms with their health care clients in addressing sensitive compliance issues, including conducting claims reviews, estimating overpayments, as well as in preparation and negotiation of OIG settlements, and corrective action plans. The Firm is able provide a heightened level of oversight, diligence, and sophistication during audits and reviews through evaluation and assessment of the accuracy of Medicare and Medicaid claims preparation and submission. In many instances these reviews are conducted under direction of legal counsel.
  
  Many claim system reviews require the statistical rigor and methodology of the DHHS Office of Inspector General (OIG) RAT-STATS and Self Disclosure protocols. Strategic Management performs these review in a form and manner that is presentable to the OIG and/or Department of Justice. We are equipped with significant experience in claims development, statistics, and provider claims operations. This includes designing and implementing Discovery and Full Sample Audits using RAT-STATS and Self Disclosure Protocols, claims data analysis based on regulatory coverage rules, report preparation, and presentation to providers, counsel, and government officials. The Firm employs a number of credentialed economists, statisticians, coding experts, auditors, and other experience personnel. Independent evaluations are performed by recognized experts who are experienced in validating their work before enforcement officials.

OUTSOURCED INTERIM AND DESIGNATED COMPLIANCE OFFICERS

• Strategic Management provides compliance officer or privacy officer services on an outsourced basis for either limited or extended periods. These options allow organizations to engage highly qualified and specialized individuals for a variety of reasons: temporary staffing needs, organizational change, cost and skill set requirement considerations. Interim Compliance Officer (ICO) or Designated Compliance Officer (DCO) services are provided on the basis of a staff extension model, typically under a one to three year agreement with renewal options. Services are provided on a full-time or part-time basis depending on the particular needs of the organization. ICOs typically run compliance program operations for 3-6 months in a temporary situation, DCOs from six months up to 3 years as a fully integrated officer.
  
  Our Compliance Officers are professionals of the highest integrity that are proven experts in their fields with many years of experience in health care compliance, including a variety of health care organization types. Our compliance officers and privacy officers serve as champions of the compliance program, manage it following best practices and in accordance with the seven elements of an effective compliance program in accordance with U.S. Department of Health and Human Services, Office of Inspector General guidance.

Physician Arrangements

• Strategic Management works with health care providers and/or their legal representatives to provide insight and analysis for organizations in relation to their physician arrangements in light of the changing regulatory environment. We work directly with clients to provide advisory services in relation to Anti-Kickback, Stark, and other regulations. 
  
  We also frequently work under the direction of counsel to provide additional insight and analysis to specific facts and circumstances. Our experience and caliber of personnel enable us to provide insight as to how regulators would view specific facts and circumstances in relation to physician arrangements. Strategic Management also conducts Fair Market Value Determination reviews. This enables our clients to adequately document and evidence physician compensation consistent with the Anti-Kickback Statute, the Stark Law, and governmental guidance

Responding to Government Enforcement Initiatives and Actions

• Strategic Management can assist organizations by providing a quick analysis of findings from CMS Contractors. Such contractors include Recovery Audit contractors (RACs), Medicaid Integrity Contractors (MICs, and Zone Program Integrity Contractors (ZPICs)), as well as State Medicaid OIG Audit & Investigation units to assist organizations in developing a response to those findings. This typically involves conducting an independent analysis of the claims processes to determine the proper levels of any overpayments.
  
  The Firm’s claims review follows the OIG RAT-STATS protocol that should be conducted to validate external contractor’s analysis, determine whether there are grounds for contest, and carefully present such findings. Strategic Management is experienced and prepared to work with counsel and act as an Expert Witness on behalf of the provider for the work performed.

Regulatory Analysis

• Strategic Management specializes in conducting regulatory analysis and employs a team of highly qualified and experienced analysts, providing research and analysis assistance on a number of issues including but not limited to:
  
  
  • Identifying federal and state health care industry regulatory trends
  • Managed care issues
  • Medicare and Medicaid regulatory compliance analysis
  • Fraud and abuse trends and regulations (CMS/OIG)
  • Provider relationships and joint ventures
  • HIPAA privacy and security and
  • Other federal laws and regulations affecting the health care industry

Risk Assessment and Management

• Strategic Management’s approach to risk assessment and management within health care organizations focuses on Regulatory Compliance Risks, and seeks to bring compliance risk management into the overall business strategy for the organization. Compliance risk management is a continuous, dynamic process of gathering, analyzing and updating information to ensure ongoing compliance with government rules and regulations. The process involves four phases:
  
  
  • Risk Assessment
  • Risk Remediation
  • Risk Area Auditing; and
  • Risk Reporting
  Significant to Strategic Management’s approach is the interaction of key operational personnel across departmental lines to identify critical risk areas that impact the entire organization. Critical risk areas are sourced either internally (e.g., considering the organization’s history and significant high-risk areas) and externally (e.g., OIG work plan, CMS contractors, state wide initiatives).

Compliance Policy Resource Center

• Strategic Management’s Compliance Resource Center holds a wealth of information for compliance officers and personnel. The Center includes multiple suites including a Policy and Procedure Suite that provides access to updated policies and procedures that cover a variety of topics and that can be easily downloaded and used. Other suites within the Compliance Resource Center provide users with opportunities to ask questions and learn about specific subject matters.
  
  For more information about Strategic Management’s Compliance Resource Center please go to www.compliance.com or click here. 

Strategic Planning

• Strategic Management provides strategic planning services geared towards organizations that desire to learn more about entering and navigating the ever-changing health care regulatory environment. We assist organizations in assessing the impact of pursuing potential business lines and ventures in the health care market. 

Training

• Strategic Management has been developing and delivering regulatory compliance training for the health care industry for nearly two decades. Topics cover subject matters such as: organizational standards of conduct, Medicare/Medicaid regulations, internal investigations and inquiries, as well as Stark and Anti-kickback rules, HIPAA, and other federal laws and regulations. Strategic Management courses are designed to be practical and directly applicable to participants’ duties, enlivened and customized to their audience through the addition of realistic examples and case studies.