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How Gotham hospital’s ACO is in compliance with HIPAA.

How Gotham hospital’s ACO is in compliance with HIPAA.

Gotham hospital has designed and implemented a well detailed and comprehensive compliance program that establishes various compliance procedures and structures. Part of these programs established is also setting forth the standards of conduct that all Gotham ACO personnel and every individual associated with Gotham ACO, are expected to follow in their employment or their course of dealings with the ACO (, 2012).

Gotham hospital has developed four elements which describe the scope and operation of the ACO’s compliance program as each element governs a different and important aspect of the program.

• The first element is the written policies and procedures. Gotham hospital ACO has developed and implemented formal written compliance policies and procedures to describe in a more detailed existing ACO compliance processes which include the use of Gotham compliance hotline and reliance on internal compliance audits by staff of Gotham providers who are participating in the ACO. There are also boards of directors who will meet annually to discuss and approve any changes necessary to these or any other compliance program documents (, 2012).

• The second element is the oversight of the compliance program consisting of compliance officer who oversees the operations of the compliance program, and works in cooperation with the Gotham compliance as necessary. The compliance director who is also designated by the ACO assists the compliance officer in the day to day operations of the compliance program. The clinical quality and compliance committee which is chaired by the ACO’s Chief Medical Officer and includes ACO personnel from various departments, compliance officer and the compliance director. The committee through the Chief Medical Officer and the Compliance officer reports to the ACO Board of Directors and oversees the ACO’s quality and compliance functions which include the performance of quality and compliance reviews, creation of an annual compliance work plan, training, addressing and resolving quality or compliance issues, improving ACO processes and procedures and monitoring the ACO’s coordination with the Compliance programs of Gotham or other ACO providers, Suppliers and Vendors. As the governing body of the ACO, the ACO Board of Directors has the ultimate responsibility for the oversight of the Compliance program and will also receive periodic reports from the Compliance Officer as to the operation of the Compliance Program, as well as to the investigation and resolution of any material compliance issues that may arise.

• The third element is Training and Education. The Compliance Department of Gotham hospital will develop a schedule of training on compliance issues for ACO staff and the training should focus on the requirements of the ACO compliance program as well as those specific requirements most relevant to the trainee’s particular job with the ACO and the compliance officer will maintain a record of all personnel who have attended such training. The Compliance officer will also work with CMO staff to ensure that any follow up training that is required as part of the Compliance Program takes place. For instance, if compliance reviews of quality data indicate ways to enhance coordination of care, quality processes and better ways to satisfy quality measures (, 2012).

• The fourth element is the Communication line as there is open communication between ACO Personnel and the Compliance Officer, senior management and the Board of Directors which is important to the success of the Compliance program and sees ways in the reduction of any potential for fraud, abuse and waste. Also, in cooperation with Gotham hospital, the ACO is using the Gotham compliance hotline, to which all ACO personnel can report anonymously or otherwise any compliance concerns, issues or potential violations of ACO compliance program requirements. In respect to confidentiality, reports received will be treated confidentially to the extent possible under applicable law. There may be an exception to the rule where an individual’s identity may become known or have to be revealed, that is, if authorities from the government become involved which can be in response to a subpoena or other legal proceedings, or during the process of the investigation, the identity of the reporter cannot be anonymous.(, 2012)


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