All candidates for Certified Ambulance Compliance Officer (CACO) certification must complete the training as well as a written final exam. The program, designed to provide the CACO candidate with a comprehensive understanding of the development, implementation and oversight of an effective ambulance compliance program is divided into six courses, as follows:
Course 1 - The Ambulance Compliance Officer
Course 1 provides an overview of the roles and responsibilities of the Certified Ambulance Compliance Officer, ensuring ethics and accountability within the organization, and the laws, regulations and payer payment policies that impact compliance.
Lesson 1A - CACO Roles and Responsibilities
In this lesson we discuss the roles and responsibilities of the effective CACO and the unique challenges facing the ambulance compliance officer. We also discuss the compliance infrastructure and how to develop an annual compliance work plan.
Lesson 1B - Program Integrity and Credibility
This lesson deals with accountability and ethics within the ambulance industry and ensuring the credibility and integrity of the compliance program including identifying and dealing with conflicts of interest.
Lesson 1C - The Compliance Library
An effective CACO must have strong knowledge of the laws, rules, regulations and payment policies related to ambulance compliance such as the False Claims Act, Anti-Kickback Statute and Civil Monetary Penalties Law, medical necessity requirements, Medicare and Medicaid payment policies, and insurance fraud laws.
Course 2 - Developing an Effective Compliance Program
Course 2 discusses the key elements of an effective compliance program, the necessary plans, policies and procedures, and the importance of conducting a thorough risk assessment.
Lesson 2A - Essential Elements
This lesson examines the Office of Inspector General’s seven essential elements of an effective compliance program as well as other compliance resources and provides the steps necessary to implement a successful compliance program.
Lesson 2B- Plans, Policies and Procedures
This lesson provides guidance for writing a compliance plan and a code of conduct, along with an overview of key compliance policies for the organization as a whole. Specific policy needs based on organizational roles and responsibilities are also addressed.
Lesson 2C- Risk Assessment
Lesson 2C discusses the principles and methodologies for assessing the key compliance risk areas in the ambulance organization and how to conduct a risk assessment, prioritize risk and develop a corrective action plan.
Course 3 - Employee Training and Conduct
This course covers employee training and education, investigating complaints and concerns, and dealing with compliance mistakes and misconduct.
Lesson 3A - Training and Education
In this lesson we discuss promoting a culture of compliance through general and department-specific compliance training, along with different training methods and how to evaluate training efforts.
Lesson 3B - Investigating Complaints and Concerns
One of the essential elements of an effective compliance program is open lines of communication. This lesson covers establishing and publicizing reporting mechanisms, how to investigate complaints and concerns, and enforcing a non-retaliation policy.
Lesson 3C- Compliance Mistakes and Misconduct
This lesson examines the difference between mistakes and misconduct and how to respond appropriately, fairly and consistently when mistakes are made or misconduct is uncovered.
Course 4 - Auditing, Monitoring and Enforcement
This course covers proactive internal auditing and monitoring to ensure continued compliance and program effectiveness, and discusses how to respond to external audits and investigations initiated by various government enforcement agencies.
Lesson 4A - Proactive Auditing and Monitoring
This lesson discusses the steps and methods for conducting internal audits, the effective use of external review and how to continuously monitor results. This lesson also covers the process for refunding identified overpayments and the proper use of the OIG’s self-disclosure protocol.
Lesson 4B - External Audits and Investigations
In this lesson we discuss the various enforcement agencies who can initiate audits or investigations, the difference between a civil and criminal investigation, how to respond appropriately to an audit or investigation, and when to engage legal counsel.
Course 5- Contracting and Corporate Compliance
In this course we discuss proper pricing and contracting practices, ensuring compliance of the agency as a whole, and compliance with privacy and security laws.
Lesson 5A - Pricing Practices
Lesson 5A discusses how to avoid discounting issues under the Anti-Kickback Statute through a fair market value analysis and cost analysis as well as tips for educating facilities and others about lawful pricing.
Lesson 5B - Contracting Compliance
This lesson covers key compliance issues with business contracts as well as specific compliance issues with business partners, facilities, vendors and other outside parties.
Lesson 5C - Agency Compliance
This lesson discusses agency licensure and enrollment issues, the steps to conduct proper credential and certification verifications, including the OIG's list of excluded individuals and entities, and how to identify and manage potential whistleblower activity.
Lesson 5D - HIPAA Compliance
In this lesson we examine the privacy and security rule and discuss how to ensure HIPAA compliance. The interplay between the CACO and the Privacy Officer is also addressed.
Course 6- Evaluation
Lesson 6 - Evaluating Compliance Effectiveness
Lesson 6 covers what government agencies consider in assessing compliance effectiveness, best practices for assessing effectiveness of your compliance program, and when and how to implement changes.