Health Compass

Coordinator: Marcia Ashline, RN, BS

Supervising Public Health Nurse

Telephone: (315) 376-5453

Hours of Operation:
M - F, 8:30 am - 4:30 pm

 

The Prevent Team:

Maryann Vargulick, PHN

Communicable Disease Nurse

 

Mary Kimbrell, RN

Health Educator

 

Ellen Scanlon, RN

Immunization and Lead Poisoning Prevention Coordinator

NY STATE OF HEALTH

What Does it Mean for You?

NY State of Health, The Official Health Plan Marketplace, is where New Yorkers can shop for, compare and enroll in health insurance coverage.  You have a choice of health plans and help finding the plan that is right for you.  It’s the only place to get financial assistance to reduce the cost of coverage.Health insurance offered in the Marketplace includes a comprehensive set of benefits. To learn more, visit nystateofhealth.ny.gov or call         1-855-355-5777.

Website Disclaimer

This site does not provide medical advice
The contents of the Lewis County Public Health Website are for informational purposes only.  The information contained on this website is not intended to be used as a substitute for professional medical advice, diagnosis or treatment.  Always seek the advice of your physician or other qualified health care provider when you have questions regarding a health or medical condition.  If you think you have a medical emergency call 911 immediately, or call your physician, or go to a hospital emergency department.

Disclaimer of Liability
Every effort has been made to offer the most current, correct , and clearly written information possible.  However, unintentional errors in information may occur.  Lewis County Public Health disclaims any responsibility for typographical errors and accuracy of the information that may be contained on Lewis County Public Health’s Web pages.  Lewis County Public Health also reserves the right to make changes at any time without notice.
The links on this website access to the World Wide Web.  The Lewis County Public Health Website connects to the Internet, once you leave the Lewis County Public Health site, Lewis County cannot control the information you access.  Each individual site has its own set of policies about what information is appropriate for public access.  Lewis County is not responsible for any information or material located at any site other than its own.
The information and data included on the Lewis County Public Health Website have been compiled by County staff from a variety of sources, and are subject to change without notice.  Lewis County makes no warranties or representations whatsoever regarding the quality of content, completeness, or adequacy of such information and data.  In any situation where the official printed publications of Lewis County or Lewis County Public Health differ from the text contained on this website, the official printed documents take precedence.
If misleading, inaccurate or otherwise inappropriate information is brought to our attention, a reasonable effort will be made to correct or remove it.  Such concerns should be brought to the attention of Lewis County Public Health.

Children’s Privacy
We may occasionally ask individuals to indicated their name, address, phone number or email address.  These requests are made only for individuals 18 years of age or older.  The requests may be to evaluate the effectiveness of the information on our website.  All responses are completely voluntarily. We do not intend to collect personally identifiable information from any person under 18 years of age.

Sexual Content
This site may contain health related materials which may have sexual content.  If you find these materials offensive, you may not want to use our website.

Disclaimer of Damages
By using the Lewis County Public Health Website, you assume all risks associated with the use of this site including any risk to your computer, software or data being damaged by any virus, software, or any other file which might be transmitted or activated via a Lewis County Public Health Website link or your access to it.  Lewis County shall not be liable for any special, incidental or consequential damages, including but not limited to lost revenue, lost profits resulting from the use or misuse of the information contained on the Lewis County Public Health Website.

Disclaimer of Endorsement
Any reference to any specific commercial products, process, or service by trade name, trademark, manufacturer or otherwise does not constitute or imply its endorsement, recommendation or favoring by Lewis County Public Health.  References may indicate that the item has been included on a listing of recalled unsafe items by the United States Food and Drug Administration, New York State Department of Health or the New York State Department of Agriculture and Markets.  The views and opinions of employees expressed herein do not necessarily state or reflect those of Lewis County, and shall not be used for advertising or product endorsement purposes.

CORPORATE COMPLIANCE PROGRAM

MISSION: The mission of the Lewis County Public Health Department (LCPHD) is to prepare and educate the people of Lewis County to ensure their health and safety.

CORE VALUES:                 ▪ Compassion

                                             ▪ Integrity

                                             ▪ Dedication

                                             ▪ Quality

                                               

FUNCTIONS:          

The Ten Essential Public Health Functions are:

1.  Monitor health status to identify community health problems,

2.  Diagnose and investigate health problems and health hazards in the community,

3.  Inform, educate, and empower people about health issues,

4.  Mobilize community partnerships to identify and solve health problems,

5.  Develop policies and plans that support individual and community health efforts,

6.  Enforce laws and regulations that protect health and ensure safety,

7.  Link people to needed personal health services and   ensure provision of health care when it is otherwise unavailable,

8. Ensure the availability of a competent public health and personal care work force,

9. Evaluate effectiveness, accessibility, and quality of personal and population-based health services, and

10. Research new insights and innovative solutions to health problems.

 

VISION: To be recognized as the leader in the prevention of disease, preparedness for disaster, and promotion of life-long health.

PURPOSE: To develop effective internal controls that promote adherence to applicable Federal and State laws, and the program requirements of Federal, State, and private health plans.

 

POLICY: LCPHD shall:

· implement written policies, procedures and standards of conduct,

 · designate a compliance officer and compliance committee,

 · conduct pertinent and effective training and education,

  · develop effective lines of communication,

  · enforce standards through well-publicized disciplinary guidelines,

  · conduct internal monitoring and auditing, and

  · respond promptly to detected offenses and develop corrective action.

INTRODUCTION

LCPHD will develop effective internal controls that promote adherence to applicable Federal and State law, and the program requirements of Federal, State, and private health plans.  The Department will establish a culture that promotes prevention, detection, and resolution of instances of conduct that do not conform to Federal, State, and private payer health care program requirements, as well as business policies.

DEPARTMENT ETHICS STATEMENT

The Lewis County Public Health Department (LCPHD) has established this statement of Department ethics in recognition of the department’s responsibility to our clients, employees, and the residents of Lewis County.  All Department employees will act in a manner that is consistent with this statement and its supporting policies.  The following principle will govern our behavior:

Commitment to the standard that all clients, employees, physicians, and visitors are worthy of being treated with dignity, respect, and courtesy.  The Department will continuously strive to adhere to this principle.

The Department will strive to provide quality care regardless of the setting in which it is provided.  However, the Department will provide services only to those clients to whom we can safely provide care and in the appropriate setting. 

STANDARDS OF DEPARTMENT CONDUCT STATEMENT

The Code of Department Conduct has been adopted by the Lewis County Board of Legislators in order to establish standards by which the employees of the Department will conduct themselves in order to protect and promote integrity and ethical values.  These standards will enable the Department to accomplish the Department’s mission, vision, and functions.

▪ The Department is committed to conducting all activities in accordance with applicable local, state, and federal regulations, with an emphasis on preventing fraud and abuse.

▪ Department employees will honestly represent the LCPHD and will not engage in any activity with intent to defraud anyone of money, property, or honest services.

1.  Personal and Confidential Information:  All efforts will be made to protect personal and confidential or privileged information about Lewis County Public Health Department clients.

2. Performance Evaluations:  The promotion of, and adherence to the elements of the Compliance Program will be a factor in evaluating the performance of all LCPHD employees.

Following is a list of possible risk areas:

• Billing for items or services not actually rendered;

• False cost reports;

• Duplicate billing;

• Failure to refund credit balances;

• Offering incentives to actual or potential referral resources;

• Joint ventures between parties, one of whom can refer Medicare or Medicaid business to the other;

• Stark physician self-referral law;

• Billing for visits to patients who do not require a qualifying service;

• Over-utilization and under-utilization;

• Knowingly billing for substandard or inadequate care;

• Billing with insufficient documentation of evidence that services were performed, or to support reimbursement;

• Billing for services provided by unqualified or unlicensed clinical personnel;

• False dating of amendments of clinical documentation;

• Falsified plans of care;

• Untimely and/or forged physician certification on plans of care;

• Improper patient solicitation activities and high-pressure marketing of uncovered or unnecessary services;

• Inadequate management and oversight of subcontracted services, which results in improper billing;

• Discriminatory admission and discharge of patients;

• Compensation programs that offer incentives for number of visits performed and revenue generated;

• Improper influence over referrals;

• Patient abandonment in violation of applicable statutes, regulations;

• Federal home care program requirements;

• Knowingly misusing provider certification numbers, which results in improper billing;

• Duplication of services provided;

• Failure to adhere to licensing requirements;

• Knowingly failing to return overpayments made by Federal health care programs.

 CLAIM DEVELOPMENT & SUBMISSION PROCESS:

a.)  Medical Necessity:

Clinical reviews will be conducted periodically as a means of verifying that clients are receiving only medically necessary services.  These reviews will take place both prior to and subsequent to billing for services.  The Department will examine the frequency and duration of the services performed to determine whether the client’s medical conditions justify the number of visits provided and billed.

Additionally, the Department will verify that beneficiaries have actually received the appropriate level and number of services billed. 

b.)  Physician certification of the plan of care: 

LCPHD will take the following steps to ensure that claims for home health services are ordered and authorized by a physician:

  1. 1.Before LCPHD bills for services provided to a beneficiary, the plan of care must be established, dated, and signed by a qualified physician;
  2. 2.The plan of care must be periodically reviewed by a physician in order for the beneficiary to continue to qualify;
  3. 3.Home health services are only billed if the Licensed Home Health Agency is acting upon a physician’s certification attesting that the services provided to a patient are medically necessary and meet the requirements for insurance reimbursement;
  4. 4.When consulted, LCPHD will assist the physician in determining the medical necessity of services and formulating an appropriate and certified plan of care;
  5. 5.LCPHD will properly document any assessment it has made of a beneficiary’s home health needs, which may be used by a physician in developing and authorizing a plan of care.

c.) Lack of Qualifying Service:

LCPHD will ensure that all claims satisfy the requisite need of a qualifying service.

d.) Cost Reports:

LCPHD will submit annual cost reports for determination and validating of administrative, overhead, and other general costs.

e.) Anti-kickback and self-Referral Concerns:

All of LCPHD’s contracts with actual or potential referral sources will be reviewed by the County Attorney and will comply with applicable statutes and regulations.

LCPHD will not submit or cause to be submitted to the Federal health care programs, claims for patients who were referred to the Department pursuant to contracts or financial arrangements that were designed to induce such referral, in violation of the anti-kickback statute, Stark physician self-referral law, or similar Federal or State statutes or regulation.

LCPHD will not offer or provide gifts, free services, or other incentives to patients, relatives of patients, physicians, hospitals, contractors, assisted living facilities or other potential referral resources.

g.) Retention of Records:

LCPHD has established a records system.  See Medical Records Policies.

COMPLIANCE OFFICER

LCPHD will designate a compliance officer to serve as the focal point for compliance activities.

The Compliance Officer’s primary responsibilities include:

▪ Overseeing and monitoring the implementation of the compliance program;

▪ Reporting on a regular basis to the County Legislators, the Director and the committee (as applicable) on the progress of the program, and assisting these components in establishing methods to improve the Department’s efficiency and quality of services, and to reduce the Department’s vulnerability to fraud, abuse, and waste;

▪ Periodically revise the program in light of changes in the law and policies and procedures of state, federal,  and private payer health plans;

▪ Reviewing employee’s certifications that they have received, read, and understood the standards of conduct;

▪ Developing, coordinating, and participating in an educational and training program that focuses on the elements of the compliance program, and seeks to ensure that all employees are knowledgeable of, and comply with, pertinent Federal and State standards;

▪ Ensuring that independent contractors and agents who furnish nursing and other health care services to the Department are aware of the requirements of the LCPHD compliance program with respect to coverage, billing, and marketing;

▪ Assisting the Department’s financial management in coordinating internal compliance review and monitoring activities, including annual or periodic reviews of programs.

▪ Independently investigating and acting on matters related to compliance, including the flexibility to design and coordinate internal investigations, and any resulting corrective action with all Department programs, subcontracted providers, and health care professionals under the control of LCPHD;

▪ Developing policies and programs that encourage managers and employees to report suspected fraud and other improprieties without fear of retaliation; and

▪ Continuing the momentum of the compliance program.

 COMPLIANCE COMMITTEE:

The Corporate Compliance Committee is established to advise the compliance officer and assist in the implementation of the compliance program.  The Committee’s functions include:

a.Analyzing the Department, in light of the regulatory and legal requirements with which it must comply, and evaluating to detect specific risk areas;
b.Assessing existing policies and procedures that address these risk areas for the possible incorporation into the compliance program;
c.Working with appropriate Department programs to develop standards of conduct and policies and procedures to promote compliance with legal and ethical requirements;
d.Recommending and monitoring the development of internal systems and controls to carry out the Department’s standards, policies, and procedures as part of daily operations;
e.Determining the appropriate strategy/approach to promote compliance with the program and to detect any potential violations, such as through hotlines and other fraud-reporting mechanisms;
f.Developing a system to solicit, evaluate, and respond to all complaints and problems; and
g.Monitoring internal and external audits and investigations for the purpose of identifying troublesome issues and deficient areas experienced by the Department, and implementing corrective and preventive action.          

TRAINING AND EDUCATION:

LCPHD employees will participate in annual training - reviewing the County ethics statement, corporate compliance program, patient rights, etc.  New employees will participate in corporate compliance training during the orientation period.  The training will be documented.  Attendance at training will be reviewed during the annual evaluation process.

 HOTLINE:

Employees are encouraged to report matters of concern by E-mail, or via the confidential lock box, anonymously to the Corporate Compliance Officer’s confidential voicemail at 376-5161.  A log will be maintained by the Compliance Officer that records such calls, including the nature of the investigation and its results.  Such information will be reported to the Director and the Board of Legislators or their designee.  If an employee is not comfortable or secure in reporting to the Compliance Officer, the report may be made to the Public Health Director, the Chair of the Public Health Legislative Committee, or to the Chair of the Board of Legislators.  There is no retaliation for reporting Corporate Compliance concerns.

 DISCIPLINE AND ACTION:

Intentional or reckless noncompliance may subject transgressors to significant sanctions.  Such sanctions could range from oral warnings to suspension, termination, or financial penalties, as appropriate.  Each situation must be considered on a case-by-case basis to determine the appropriate sanction.

 AUDITING AND MONITORING:

External auditors who have expertise in Federal and State health care statutes, regulations, and Federal health care program requirements will perform regular, periodic audits. The following techniques may be part of the review process:

▪ Analysis of utilization patterns;                                          

▪ Presentation to clinical staff, hypothetical scenarios of situations experienced in daily practice and subsequently assess responses;

▪ Unannounced mock surveys, audits, investigations;

▪ Re-evaluation of deficiencies cited in past surveys;

▪ Reviews of clinical documentation that support claims for reimbursement;

▪ Validation of qualifications of physicians who order services provided by LCPHD.

 VIOLATIONS AND INVESTIGATIONS: 

Upon reports or reasonable indications of suspected noncompliance, the Compliance Officer will immediately investigate the conduct in question to determine whether a violation of applicable law or the requirements of the compliance program has occurred, and if so, take decisive steps to correct the problem.  As appropriate, such steps may include an immediate referral to criminal and/or civil law enforcement authorities, a corrective action plan, a report to the Government, and the return of any overpayments, if applicable.

 REPORTING: 

When credible evidence of misconduct that may violate criminal, civil, or administrative law is discovered, the Department will promptly report the existence of misconduct to the appropriate Federal and State authorities within a reasonable period, but not more than 60 days after determining there is credible evidence of a violation.

Lewis County Public Health Department

Notice of Privacy Practices

Effective April 14, 2013

This notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please review it carefully.

We are required by law to protect the privacy of health information that may reveal your identity, and to provide you with a copy of this notice which describes the health information privacy practices of our public health department. A copy of our current notice will always be posted in our reception area. You will also be able to obtain your own copies by accessing our website at www.lewiscountypublichealth.com, calling our office at 315-376-5453, or asking for one at the time of your next visit.

In the even that a breach of unsecured protected health occurs that affects you, you have a right to be notified of this.

WHAT HEALTH INFORMATION IS PROVIDED

We are committed to protecting the privacy of information we gather about you while providing health-related services. Some examples of protected health information, or PHI, are:

  • Information about your health condition (such as a disease you may have),
  • Information about health care services you have received or may receive in the future,
  • Information about your health care benefits under insurance plan,
  • Geographic information (such as where you live or work),
  • Demographic information (such as your race, gender, ethnicity or marital status),
  • Unique numbers that may identify you (such as your social security number, your phone number, or your driver’s license number), and
  • Other types of information that may identify who you are.

HOW WE MAY USE AND DISCLOSE YOUR PHI WITHOUT YOUR WRITTEN AUTHORIZATION

Without your one time written consent, the department and its staff may use your PHI or share it with others in order to provide health services, obtain payment for the services, and run the department’s normal business operations. This consent will be in effect indefinitely. You may revoke your consent at any time, except to the extent that we have already relied on it.

Treatment

We may use and disclose PHI about you to provide, coordinate or manage your health care and related services. We may consult with other health care providers regarding your treatment and coordinate and manage your health care with others.

Payment

We may use and disclose PHI so that we can bill and collect payment for the treatment and services provided to you. We may use and disclose PHI for billing, claims management, and collection activities. We might also need to inform your health insurance company about your health condition in order to obtain pre-approval for your health care, such as having nurses visit you to provide care at home.

Business Operations

We may use your PHI or share it with others in order to conduct our normal business operations. For example, we may use your PHI to evaluate the performance of our staff in providing health care for you, or to educate our staff on how to improve the care they provide for you. We may also share your PHI with another company that performs business services for us, such as billing companies.

COMMUNICATIONS FROM OUR OFFICE

You have the right to request that you receive communication regarding PHI in a certain manner or at a certain location. We may contact you through the mail or by telephone to remind you of appointments and to provide you with information about treatment alternatives or other health related benefits and services.

INFORMATION DISCLOSURE

 Uses and disclosures for which you have the opportunity to agree or object. Friends and Family involved in Your Care or Payment for Your Care: If you do not object, we may share your PHI with a family member, relative, or close personal friend who is involved in your care or payment for that care. We may also notify a family member, personal representative or another person responsible for your care about your general condition or about the need for more care than we can provide through our services. In some cases we may need to share your PHI with a disaster relief organization that will help us notify that person.

As Required By Law

We may use or disclose your PHI if we are required by law to do so.

Public Health Activities

We may disclose your PHI to authorized public health officials so they may carry out their public health activities. For example, we may share your PHI with government officials that are responsible for controlling disease, injury or disability.

Victims of Abuse, Neglect or Domestic Violence

We may release your PHI to government agencies authorized to conduct audits, investigations, and inspections of our department or the services we provide. These government agencies monitor the operation of the health care system, government benefit programs such as Medicare and Medicaid, and compliance with government regulatory programs and civil rights laws.

Lawsuits and Disputes

We may disclose your PHI if we are ordered to do so by a court that is handling a lawsuit or other dispute.

Law Enforcement

We may disclose your PHI to law enforcement officials for the following reasons:

  • To comply with court orders or laws that we are required to follow;
  • To assist law enforcement officers with identifying or locating a suspect, fugitive, witness, or missing person;
  • If you have been the victim of a crime and we determine that 1) we have been unable to obtain your consent because of an emergency or your incapacity; 2) law enforcement officials need this information immediately to carry out their law enforcement duties; and 3) in our professional judgment disclosure to these officers is in your best interest;
  • If we suspect that your death resulted from criminal conduct;
  • If necessary to report a crime that occurred on our property; or
  • If necessary to report a crime discovered during an offsite emergency (for example, by emergency medical technicians at the scene of a crime).

To Avert a Serious Threat to Health or Safety

 We may use your PHI or share it with others when necessary to prevent a serious threat to your health or safety, or the health or safety of another person or the public. In such cases, we only share your PHI with someone able to help prevent the threat. We may also disclose your PHI to law enforcement officers if you tell is that you participated in a violent crime that may have caused serious physical harm to another person (unless you admitted that fact while in counseling), or if we determine that you escaped from lawful custody (such as a prison or mental health institution).

Coroners, Medical Examiners and Funeral Directors

 In the unfortunate event of your death, we may disclose your PHI to a coroner or medical examiner. We may also release your PHI to funeral directors as necessary to carry out their duties.

Research

 We may use and disclose PHI about you for research purposes under certain limited circumstances. We must obtain a written authorization to use and disclose PHI about you for research purposes except in situations where a research project meets specific, detailed criteria established by the HIPPA Privacy Rule to ensure the privacy of PHI.

YOUR RIGHTS TO ACCESS AND CONTROL YOUR HEALTH INFORMATION

 We want you to know that you have the following rights to access and control your health information. These rights are important because they will help you make sure hat the health information we have about you is accurate. They may also help you control the way we use your information and share it with others, or the way we communicate with you about your medical matters.

Right to Inspect and Copy Records

 You have the right to inspect and obtain a copy of any of your PHI in certain records that we maintain. This includes health and billing records. We may deny your request to inspect or copy PHI only in limited circumstances. To inspect or copy PHI, please contact our Privacy Officer. There will be a charge for copies.

Right to Amend Records

 You have the right to request that we amend PHI about you as long as such information is kept by or for our Department. You must submit your request in writing to our Privacy Officer. You must give a reason for your request. We may deny your request.

Right to An Accounting of Disclosures

 After April 14, 2003, you have the right to request an “accounting of disclosures” which is a list with information about how we have shared your information with others.

Right to Restrict Certain Disclosures to a Health Plan

 You have the right to restrict certain disclosures of protected health information to a health plan when you pay out of pocket in full for the health care item or service.

Right to Request Addition Privacy Protections

 You have the right to request that we further restrict the way we use and disclose your PHI. You may also request that we limit how we disclose information about to family or friends involved in your care. To request restrictions, please contact our Privacy Officer in writing. We are not required to agree to your request for a restriction, and in some cases the restriction you request may not be permitted under law.

Right to Request Confidential Communications

 You have the right to request that we communicate with you about your PHI in a more confidential way. For example, you may ask that we contact you at work instead of at home. To request a more confidential communication, please write to our Privacy Officer.

Right to a Paper Copy of this Notice

 You have the right to receive a paper copy of this notice at any time. Other uses and disclosures not described in this Notice will be made only with authorization from you. Most uses and disclosures of protected health information for marketing purposes, and disclosures that constitute a sale of protected health information require express written authorization.

If you have any questions about this Notice or would like further information, please contact our Corporate Compliance Officer Ashley Waite, at 315-317-5161.

How to File a Complaint

If you believe your privacy rights have been violated, you may file a complaint with us or with the Secretary of the Department of Health and Human Services. To file a complaint with us, please contact Ashley Waite, Corporate Compliance Officer at the Lewis County Public Health Department at 7785 N. State Street, Lowville, NY 13367, or phone 315-376-5161. No one will take action against you for filing a complaint.

DSRIP Corporate Compliance

Lewis County Public Health is part of a Performing Provider System (PPS) under New York State’s Delivery System Reform Incentive Payment (DSRIP) program.  DSRIP focuses on health care system transformation, where providers work to improve and coordinate community based, primary care, mental health and preventive care services.  The lead PPS organization in our area is Central New York Care Collaborative, Inc. (CNYCC).

We participate in certain DSRIP projects in the CNYCC PPS, including the following: Patient Activation and Reduction in Cardiovascular disease. If you have any questions, concerns or complaints about these DSRIP projects or the CNYCC PPS, please contact:

Lewis County Public Health’s Corporate Compliance Officer at 315-376-5453, via e-mail at This email address is being protected from spambots. You need JavaScript enabled to view it. or via our compliance hotline at 315-376-5161; Or CNYCC’s Compliance Officer at 315-703-2985, or via email at This email address is being protected from spambots. You need JavaScript enabled to view it. or via CNYCC’s compliance hotline number at 855-343-5598, or online via CNYCC’s compliance webpage at https://cnycares.org/get-involved/corporate-compliance/.

All reports are treated with respect and may be made anonymously. No one will retaliate against any person making a report in good faith. Thank you.