Contractors providing health care products or services to the Federal Government must not only comply with agency-specific requirements, but with the full range of Government procurement laws and regulations. How can a contractor effectively meet all of these requirements? One of the most effective answers is: Establishing and maintaining a bona fide, on going self-governance program—one that examines and monitors compliance as an integral part of daily business operations. The purpose of this special seminar: To provide health care contractors with just such training.

How important is self-governance...a compliance program? Its vital importance is signaled by the ever-increasing areas of health care procurement receiving tougher scrutiny from Government auditors and investigators; by rigorous new initiatives on contractor fraud, waste and abuse; and by the newly-changing requirements health care contractors must satisfy. These initiatives and changes are occurring in a number of significant areas, including: Cost allowability and allocability matters; the widening scope of the Government's access to contractors' records; tougher agency-specific health care contract provisions, and more.

This program offers solid guidance on what the full range of Government health care contracting requirements are, and then details what you need to know for establishing a thorough self governance program to monitor day-to-day compliance.

In addition, attendees will receive a comprehensive Manual authored by the Course Faculty for the program—for use during the program and as a desk-reference you can rely on after the course has been completed.

COURSE CURRICULUM

I. OVERVIEW

1. Introduction to Federal Health Care Contracting
2. Overview Of Federal Health Care Programs
   1. Medicare
   2. Medicaid (State Medical Assistance Programs)
   3. CHAMPUS: Tricare
   4. Federal Employee Health Benefits Program ("FEHBP")
   5. Veterans Programs
3. Overview Of Federal Health Care Contracts
   1. Medicare
   2. Medicaid
   3. CHAMPUS (OCHAMPUS)
   4. FEHBP
   5. Veterans Programs (VA)
   6. Special Programs (CDC)
4. Statutes & Regulations Imposing Compliance Requirements
   1. FAR, DFARS, CAS
   2. Fraud & abuse
   3. Medicare
   4. Medicaid
   5. State laws & regulations
   6. HCFA Administrative Manuals
   7. CHAMPUS
   8. FEHBP
   9. Veterans Health Care
   10. Supply Schedule Contracts
   11. Pharmaceuticals
5. Developments In Federal Health Care Contracting
   1. HIPAA
   2. Medicare & choice
   3. Medicare Integrity program
   4. Legislative trends

II. GOVERNMENT ACCESS AND AUDIT RIGHTS

1. Government Requirements: Certifications / Reporting / Contract Clauses
   1. Contract Requirements
   2. Agency-unique requirements
   3. Government-wide requirements
2. DCAA Audits
3. Inspector General
4. Department of Justice / U.S. Attorneys
5. Competitors
6. Others

III. AREAS OF SIGNIFICANT RISK

1. Cost Charging & Billing Issues
   1. Cost mischarging
   2. Unallowable costs
   3. Other indirect costs
2. Health Care Fraud & Abuse Issues
   1. False claims
   2. Kickbacks / safe harbors
   3. Self-referrals
3. Ethics/Business Practices
   1. Procurement integrity
   2. Gratuities
   3. Antikickback Act
   4. Conflicts of Interest
   5. Byrd Amendment
   6. Lobby Disclosure Act
4. Drug-Free Work Place

IV. CONSEQUENCES OF NONCOMPLIANCE WITH STATUTORY / REGULATORY / CONTRACT REQUIREMENTS

1. Criminal Sanctions
2. Civil Sanctions
3. Qui Tam
4. Suspension / Debarment / Exclusion

V. ESTABLISHING A COMPLIANCE PROGRAM

1. Recent Developments
   1. "Model" programs
   2. Corporate Integrity Agreements
2. Compliance Reviews: Screening Critical Areas For Contract Compliance & For Identifying Major Risk Areas
   1. Contract clause compliance review
   2. Administrative cost / cost accounting compliance
   3. Major internal controls / problem areas
3. Methods Of Fact Gathering
   1. Interviews of responsible personnel
   2. Review of applicable written policies & procedures
   3. Review of internal controls & procedures
   4. Review of contract, contract proposals & change order proposals
   5. Review of disclosure statement
   6. Review of past audit reports
   7. Transactional testing
4. Purchasing Systems
5. Procedures
   1. Labor charging
   2. TINA
   3. Subcontracting
   4. CAS
   5. Cost allocation plans
   6. Socio-economic considerations
   7. Other areas

VI. DISCLOSURE ISSUES

1. What & When To Disclose
   1. Whether disclosure is required
   2. To whom to disclose
   3. What information should be disclosed
2. Possible Consequences Of Disclosure
   1. Criminal liability
   2. Civil liability
   3. Waiver of privileges
   4. Relationship with employees
3. Voluntary Disclosure Programs
4. What Should Be Disclosed