AWPHD, Health Futures, LLC and HIPAA/Corporate Compliance Services

The Association of Washington Public District Hospitals has entered into an agreement with Health Future, LLC to help its members comply with the administrative simplification provisions of the HIPAA statute. The agreement also provides for a comprehensive and effective corporate compliance programs at the discretion and interest of the individual member. This arrangement offers a number of benefits to AWPHD members:

• Leveraging the resources of First Consulting Group (FCG) and Health Future LLC to acquire the skills AWPHD members require for compliance.
  
• The development of a consistent approach to HIPAA and corporate compliance among Washington public district hospitals
  
• Affordable access to the HIPAA expertise of a national consulting firm
  
• Leveraging the intellectual capital (e.g., white papers, methodologies, tools/templates, best practices, benchmark studies) available within the collective knowledge base of over 2,000 FCG associates
  
• Minimizing the work effort and timeframe required for AWPHD members to complete the procurement and placement of resources required to prepare for HIPAA
  
• Access to ongoing consultation regarding HIPAA and other corporate compliance risk exposures

BUSINESS RELATIONSHIP BETWEEN HEALTH FUTURE, LLC, and FIRST CONSULTING GROUP

There is a master service agreement between Health Future and FCG to offer HIPAA education, strategy and budget development, assessment services, and consultation to member hospitals. The fees charged for those services have been significantly discounted based on the number of hospitals participating, and different support models have been identified to enable hospitals and healthcare systems of all sizes to have access to the scope of services that they wish to access.

HIPAA COMPLIANCE SERVICES

Educational Presentations

Health Future will offer a series of educational courses designed to acquaint AWPHD members with the specifics of the HIPAA regulations. These courses have been developed relying heavily on material provided by FCG and other nationally prominent HIPAA consultants. The four offerings included in this series are:

• HIPAA 101: This 2-hour course provides participants with a general understanding of the HIPAA provisions and anticipated impacts on the healthcare industry. It also lays out the Health Future program for achieving HIPAA Compliance.
  
• HIPAA Transactions 201: This 2-hour course is designed for individuals responsible for the transactions portion of compliance. This includes the EDI transactions, code sets and unique identifiers.
  
• HIPAA Privacy 202: This 2-hour course is designed for individuals responsible for the privacy portion of compliance. The final privacy regulations are discussed in further detail.
  
• HIPAA Security 203: This 2-hour course is designed for individuals responsible for the security portion of compliance. The proposed security regulations are discussed in further detail.

The preferred delivery method for these four sessions is videoconferencing. Web-cast technology or on-site presentations for multiple AWPHD members are alternative methods for delivering these presentations. All session will be taped and archived for use by members who are unable to participate "live."

HIPAA Strategy Development and Assessment Seminars

Health Future will offer AWPHD members, on a regional basis, two face-to-face educational seminars covering the development of a HIPAA strategic plan and a plan for conducting a risk assessment. The presentations will include the components/ objectives of a HIPAA strategic plan, the components/objectives of a HIPAA assessment, the assessment methodology, and training on the FCG assessment tools to determine the level of organizational compliance with the Transaction and Code Sets, Privacy, and proposed Security Rules. These education sessions will be conducted, if possible, at an AWPHD member facility for multiple members.

HIPAA Policy and Procedure Manual

The fees for HIPAA support services include access to model Privacy policies and procedures and samples of documents required by the Privacy Rule. This material has been developed by Michael Best and Friedrich, a prominent law firm in the Midwest with extensive HIPAA experience. It will be maintained by the firm to ensure its currency.

HIPAA Consultation

Health Future will provide ongoing HIPPA consultation, using the resources of FCG and prominent national law firms with dedicated HIPAA practices, as necessary. This enables AWPDH hospitals to have access to quality IT and legal expertise without having to routinely pay for such consultation independently.

CORPORATE COMPLIANCE SERVICES

Health Future has developed a model comprehensive corporate compliance program that is designed to address the high-risk areas identified by the Department of Justice and the OIG. This program consists of an organizational code of ethics and business conduct policy, compliance policy statements, and individual compliance plans for services targeted by the federal government for investigation. These plans are modified and additional plans are developed as additional risk exposures are identified, both externally and internally. This material, along with consultation on specific compliance matters and hotline services is included in the agreement with Health Future. Compliance services provided for an additional fee include:

• Focused coding reviews to identify unusual provider patterns which have prompted the investigation of other healthcare organizations for potential fraud
  
• Education and training of employees and hospital professional staff
  
• A formal assessment of compliance program effectiveness

PROFESSIONAL FEES

Based on the scope, approach and deliverables listed above, our professional fees for compliance services for 2002 and annually thereafter are outlined below.