The Certified Medical Compliance Officer addresses the unique compliance concerns in non-hospital health care provider offices, including small to mid-sized outpatient medical office settings, home health, hospice, DME, PT clinics, and third-party billing companies.
CMCOs are proficient in the development, implementation, and management of an ongoing compliance program. They have advanced compliance knowledge that few medical office professionals have obtained.
The curriculum has received great feedback and is believed to be the most comprehensive, targeted compliance certification program currently available to small and mid-sized health care provider organizations.
‘Men must turn square corners when they deal with the Government.’
Rock Island, A. & L.R. Co. v. United States, 254 U.S. 141 (1920).
“The U.S. Supreme Court made this observation more than a century ago and this statement is more true today than it was then. It encapsulates everything we teach in this course. If a physician, practice, home health agency, hospice or other health care provider wants to participate in Medicare and other Federal health care benefit programs, it is incumbent on the provider to ensure that the government's money is protected, no proverbial ‘corners are cut’ when providing services, and all statutory and regulatory requirements for coverage and payment are met.”
- Robert W. Liles, JD, MBA, MS, Managing Member Liles Parker PLLC, and former Federal Prosecutor
Certified Medical Compliance Officer Co-Author & Instructor
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Robert W. Liles, JD, MBA, MS and Paul Weidenfeld, JD
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Robert W. Liles, JD, MBA, MS
Robert has worked in regulatory compliance as a Federal prosecutor and as defense counsel, for more than 25 years. Robert focuses his practice on fraud defense, internal audits, investigations, compliance and regulatory matters. He has represented both individuals and entities in administrative and civil proceedings and in connection with internal compliance reviews.
Robert is a nationally recognized speaker and educator on legal and regulatory issues. His extensive health care management education / background and his prior experience as a federal prosecutor provide a real-world perspective when advising individuals and entities on enforcement and regulatory compliance issues. He has also represented health care providers in connection with government regulatory investigations and audits by UPICs, ZPICs, SMERCs, RACs and reviews by SIUs working for private payor plans.
He holds master's degrees in both Business and Health Care Administration. After graduating from law school, he was hired as an Assistant United States Attorney (AUSA) in the Southern District of Texas (SDTX) primarily to handle False Claims Act matters and cases. He was later promoted to serve as Chief of the Financial Litigation Unit. Shortly after the passage of the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Robert was asked to serve as the first National Health Care Fraud Coordinator and was later promoted to the position of Deputy Director, Legal Programs, for the Executive Office for U.S. Attorneys (EOUSA), a component of the United States Department of Justice (DOJ) where he advised on civil and criminal fraud statutes, schemes, investigative tools, privacy concerns, and compliance issues. He was instrumental in writing and implementing DOJ guidance on the judicious use of the False Claims Act. Robert received "Director's Award," the highest award that can be bestowed by the agency, for his work.
Paul Weidenfeld, JD
Paul Weidenfeld is nationally recognized for his work in both the prosecution and defense of Healthcare Fraud investigations, False Claims Act cases and qui tam litigation. He has earned numerous awards including the prestigious Attorney General Award for Fraud Prevention and Nightingale Outstanding Healthcare Litigator.
A former Health Care Fraud Coordinator for the Executive Office of the Department of Justice, Paul has represented providers and individuals in Healthcare Fraud matters since leaving the department. Whether serving as mediator, litigation consultant or legal representative, or trying to understand and help craft solutions to even the most difficult litigation problems, Paul draws upon a broad range of experiences as a lawyer/litigator that includes over 50 trials, 25 appellate arguments and appearances before the United States Supreme Court, Federal and State Appellate Courts, and Federal and State trial courts.
He has also represented health care providers in connection with government regulatory investigations and audits by UPICs, ZPICs, SMERCs, RACs and reviews by SIUs working for private payor plans. He brings a unique perspective to False Claims Act cases, Fraud Investigations and Qui Tam, or whistleblower, lawsuits which is partly the result of his rare combination of having BOTH extensive litigation experience (more than 50 trials and 25 appellate) AND subject matter expertise (10 years as a fraud prosecutor, 2 years as the DOJ Healthcare Fraud Coordinator, and experience as a partner in a major healthcare law-firm). Paul's experiences have taught him that there is no one-size-fits-all in the world of settlement or conflict resolution, and he is well known for his ability to find innovative solutions to difficult litigation problems.
Compliance expertise is among the most valuable and versatile attributes in healthcare. A cookie-cutter compliance plan template downloaded from the Internet won't meet federal compliance expectations. Your compliance program extends beyond the maintenance of policies and PHI. It represents an ongoing effort to operate a medical practice or clinic in an ethical manner within the four corners of the law.
Lack of knowledge won't hold up in a federal audit. Medicare and Medicaid have expanded audit contractor programs tasked with identifying fraud, waste, and abuse. UPICs, ZPICs, RACs, and other contractors are authorized by CMS to come into your office and request the documentation that supports the claims for reimbursement that you have submitted to the Medicare program. These onsite audits can occur with little or no notice and penalties can add up quickly.
An effective compliance program can benefit a physician's practice by speeding up and optimizing the proper payment of claims, minimizing billing mistakes, and may reduce the likelihood of an audit. This includes meeting regulatory obligations and minimizing threats to the organization. The CMCO curriculum provides candidates with advanced knowledge that very few practice management professionals have attained. This specialized training guides the development, implementation, and management of a complete compliance program and serves as an ideal platform for professional growth.
The CMCO Certification training covers every aspect of compliance in an outpatient medical office or facility. The training manual is packed with reference materials and resources, and tactical skills needed to develop and maintain a custom program that complies with federal guidelines and fits your unique requirements. Equally important, if you are audited, the training provides proof that your organization has taken steps to comply with applicable billing and coding rules.
The CMCO is created for non-hospital healthcare professionals. Experience working in an outpatient medical office setting is recommended. The material covered in this program represents a tremendous amount of information and real-world experience, systematically presented during each session.
Each section was carefully developed especially for professionals working in outpatient medical settings by Healthcare Compliance Attorney Robert W. Liles and longtime Compliance Officer D.K. Everitt - well-tenured healthcare compliance experts. They know the subject matter inside and out.
The curriculum is taught by Robert Liles and Paul Weidenfeld, both practicing attorneys who are intimately involved in the business of healthcare compliance and management. Their teaching style is not intimidating. Their goal is to put you at ease, so you can tackle tough situations with confidence. It includes many real-world compliance examples relevant to private practices.
Compliance structure and enforcements
- The seven elements of the compliance plan
- Health care fraud enforcement and sentencing guidelines
- False Claims Act, Stark, and the Federal Anti-Kickback Statute
- Calculation of civil monetary penalties
- Whistleblower complaints
- Legal provisions of compliance with a review of actual case examples
- Impact of Health Care Reform on enforcement statutes and practices
- Performing a gap analysis and other means of identifying practice-specific risks Billing/coding/coverage and reimbursement
Billing/coding/coverage and reimbursement
- Coding, billing and documentation considerations
- LCDs/NCDs and their applicability to coverage decisions
- Drafting and incorporating the office compliance plan
- Mission statement, codes of conduct, and organizational goals
- The growing threat of electronic security and identity theft Compliance, risks, actions and issues
Compliance, risks, actions, and issues
- Role of the Compliance Officer in the organizational hierarchy
- UPICs, ZPICs, RACs, SMERCs, and other Medicare/Medicaid contractors
- Correct handling of an audit request
- Organizational risks, peer review actions, state licensure issues
- Employee screening, staff, and patient relations
- Employee notification of obligations and consequences for failure to comply
- Drafting enforcement and discipline provisions
- Ongoing monitoring and auditing
- Overview of law enforcement organizations Medicare exclusion and its impact on an organization
Medicare exclusion and its impact on an organization
- Permissive vs. mandatory exclusion
- Co-payments, waivers, deductibles, and write-offs
- Overpayments, federal Anti-Kickback, False Claims Act, and Stark implications
- Gratuities, kickbacks, and payments to physicians
- Types of referrals that may violate one or more federal statutes
- Business relationships between your practice/clinic and other providers
- Setting up mechanisms for employees to file anonymous complaints
- Avoiding allegations of reprisal and responding to identified deficiencies
- Voluntary repayments - advantages and disadvantages of making repayment Law enforcement investigation tools
Law enforcement investigation tools
- Subpoenas and search warrants and how to respond to compulsory process
- Employment of consultants, lawyers, and other third-party advisors
- Federal and non-federal administrative appeals of denied claims
- HIPAA/HITECH and the relationship between privacy and compliance
- Business associate pitfalls to consider
- Future risks to your organization
Five hours are allotted for the certification exam and a score of 70% or better is required to earn the CMCO certification. If a passing grade is not achieved on the first attempt, candidates may re-test for an additional fee.
“I just wanted to express my thanks to you, the staff at PMI, and the facilitators who conducted the training; Robert Liles and D. K. Everitt. They were both outstanding instructors and made our week together both informative and enjoyable. I took away a tremendous amount of information which will be extremely useful as I continue my work as a Physician Practice Advocate and Educator. I look forward to future PMI seminars and training events and will definitely recommend your sessions to my colleagues.” - Joe Maruk, CMCO
“As physicians, we are just not prepared to deal with all of the laws and regulations that the Office of the Inspector General (OIG) expects us to be compliant with. The Certified Medical Compliance Officer class teaches you how to prepare your practice for an audit by the OIG. Physicians, especially, need to be aware that each practice is responsible for the wrongful acts of its employees, and that failure to know applicable laws and statutory provisions, such as the False Claims Act, Anti-Kickback Statute, stark Laws and Fraud and False Statements, is not a defense and can lead to large monetary. Attending this class will benefit physicians who run their own practice, or who are interested in any aspect of legal compliance.” - Steven F. Crawford, M.D.; Chair, Committee on Scientific Activities; MedChi, The Maryland State Medical Society
“This was one of the most educational courses I have ever attended.” - Heather Yoo, CMOM, CMC, CMCO, Palomar Neurosurgery Center
“I wanted to take a moment and say how very much I appreciate the privilege to take the CMCO course. Wow! What a fantastic course! Robert and DK were both exceptional speakers! This course is perfect for the physician's office for compliance. The materials were well written and provided excellent explanations to the reader. I know I will refer to it often, however I know the information is subject to change. It expanded my knowledge and provided insight to things I didn't even know were important on the business side of the office.
Thank you again for the opportunity to attend this course- it truly made a difference in my career and knowledge on the business of medicine.” - Vanessa M Lankford, CPC, CMOM, AACE- CEC
“When I started in healthcare, my goal was to get a job in the front office for a year and move on to a different career path. By taking that first step into the unknown, it led me down the road of success. In my 30 year journey, I developed a passion for health care and I believe it all started in the front office.” - Ada X Gonzalez, CMCO CMOM, VP Revenue Cycle, DHR Health
Prod ID: 122
