Stark Law Policy (Effective Date: November 1, 2017) SCOPE: This policy applies to all Sightpath Medical LLC (“Sightpath”) employees worldwide, including part time, temporary contract employees, Management Committee Members, Corporate Integrity Agreement (CIA) Covered Persons, and Vendor’s. PURPOSE: Sightpath is committed to compliance with applicable laws, rules and regulations, including the Stark Law. This policy provides general information about the Stark Law and implements relevant policy. STARK LAW Relevant Purpose The Stark Law’s purpose is to regulate physician referrals where the physician has a financial interest in the entity on the receiving end of the referral. Stark, by limiting these types of “self-referrals,” helps avoid overutilization of referred services and ensures competition by other providers, driving down healthcare costs. Summary of the Law The Stark Law prohibits physicians from referring Medicare/Medicaid patients to an entity for “designated health services” (DHS) if the physician or an immediate family member of the physician has a “financial relationship” with the entity receiving the referral. The Stark Law further prohibits the entity receiving a prohibited referral from presenting a claim to Medicare or Medicaid for the designated health service furnished under the prohibited referral. The Stark Law is not an intent based statute. Thus, receipt of a referral from a physician where a financial relationship exists results in a violation of the Stark Law, regardless of intent. Penalties Penalties for violation of Stark include: • Overpayment/refund obligation • Federal False Claims Act liability • Civil monetary penalties (CPM) and federal program exclusion for knowing violations • Potential for $15,000 CPM for each service • Civil assessment of up to three times the amount claimed POLICY Designated Health Services Under the Stark Law, under certain circumstances Sightpath will not be able to accept/provide referrals for “designated health services” to/from a physician with whom Sightpath has a “financial relationship.” Some of the “designated health services” covered by the Stark Law include radiology services (e.g., A-scans and B-scans); prosthetic devices and supplies (e.g., post-cataract eyewear, and IOL’s); outpatient prescription drugs; and inpatient and outpatient hospital services. Financial Relationships A “financial relationship” is deemed to exist if a physician (or an immediate family member of the physician) holds an ownership or investment interest in, or is a party to a “compensation arrangement” with the entity receiving the referral. A “compensation arrangement” is defined broadly to include any arrangement involving any remuneration, directly or indirectly, overtly or covertly, in cash or in kind between a physician (or an immediate family member) and an entity. Thus, a “financial relationship” could be created by a consulting agreement with a physician, the sale of product to a physician, or the provision of free goods to a physician. Exceptions Certain exceptions have been created where relationships with a physician will not be deemed to create a “financial relationship” under the Stark Law. Exceptions include, but are not limited to: a. The “personal services exception” to the Stark Law protects fair market value payments to a physician for legitimate, commercially reasonable and necessary services that are provided pursuant to a written services agreement, subject to the satisfaction of certain additional requirements. b. The Stark Law also has an exception for payments made by a physician for items or services if the items or services are furnished at a price that is consistent with fair market value. c. Other exceptions to the definition of “financial relationship” may be available for a particular business arrangement. RESPONSIBILITY FOR COMPLIANCE WITH STARK LAW POLICY It is the Compliance Officer’s responsibility along with input from the Compliance Committee and Legal Counsel to maintain compliance with Stark. As of the effective date of this policy, Sightpath is not aware of any relationship that currently implicates Stark. However, the Compliance Officer will continue to monitor Sightpath’s relationships and if Stark becomes applicable, will work with Legal Counsel to structure such relationships so as to meet Stark requirements. Further, as needed, additional policy, procedure, and controls will be developed in order to ensure ongoing compliance with Stark. POLICY – SUSPECTED VIOLATION All suspected violations of the Stark Law must be reported to the Compliance Officer who will investigate the incident and take appropriate remedial steps to address the issue. The Compliance Officer will also determine if the incident meets the definition of a reportable event per Sightpath’s Corporate Integrity Agreement. 11/01/2017 Develop a policy to reduce the likelihood of facing liability for the False Claims, Anti-Kickback, and Stark laws (ALL THREE). To help you develop your policy, use a stakeholder approach. Using your perspectives I need to know what are the specific regulations for fraud prevention.

• Compliance Officer/ Organization Administrator- How will this policy be monitored? Provide the stats about violations and penalties associated with violations.
• Physician – What is your role in limiting self-referral or ancillary service abuse, or upcoding?
• Lawyer – What are the legal implications of violations and reporting for the organization? How will the organization handle reported violations?

Develop a clear organizational policy to limit exposure for fraud and abuse. Once you have complete your policy submit below. This document is due in the dropbox on the last day of the module (see schedule details). Please cite all sources in APA format. You should have at least one source at minimum. Example Policy (Links to an external site.)

Based on the perspectives and examples you’ve researched, be sure you have included the following in your policy:

• Organizations Name/logo
• Title
• Purpose
• Scope
• Definitions of the laws associated or critical verbiage within the document
• Specific violations (or practices that are prohibited by this policy)
• Exceptions (if applicable)
• Monitoring practices (how will your organization be monitoring potential violations) 
• Potential violation consequences for the organization (fines, penalties, etc.)
• Consequences for individuals violating the policy (suspensions, termination, etc.)
• Violator statistics and penalties associated with each from previous litigation
• Sources and in-text citations in APA format

Rubric

Google Doc ProjectGoogle Doc ProjectCriteriaRatingsPtsThis criterion is linked to a Learning OutcomeQuality of Topics & Content10 ptsLevel 5Content substantially covered all areas of policy for preventing fraud: Title, purpose, definitions, scope, specific violations, exceptions, monitoring, potential violation consequences for the organization and violator and statistics of penalties associated with each.7.5 ptsLevel 4Content adequately covered all topics: Title, purpose, definitions, scope, specific violations, monitoring, potential violation consequences for the organization and violator and statistics of penalties associated with each. Overall project may not miss any components of the policy; however, it seems very shallow without in-depth analysis of the topic.5 ptsLevel 3Content did not adequately covered all topics: Title, purpose, definitions, scope, specific violations, monitoring, potential violation consequences for the organization and violator and statistics of penalties associated with each. Or is missing one or more topics. (Missing 1-3 topics) Lacks clear definitions, purpose, and/or scope.2.5 ptsLevel 2Content did not adequately covered all topics: Title, purpose, definitions, scope, specific violations, monitoring, potential violation consequences for the organization and violator and statistics of penalties associated with each. (Missing more than 3 major areas) Lacks clear definitions, purpose, and/or scope. Or contribution was last minute and did not conduct in-depth research of the topic.0 ptsLevel 1No submission or participation10 pts
This criterion is linked to a Learning OutcomePerspectives5 ptsLevel 5All shareholders perspective are evident in the development of the policy. (Compliance Officer, Healthcare Provider, Lawyer)3.75 ptsLevel 4Missing some shareholders’ perspectives or not evident in the policy. (Ex: Does not address how to avoid violations; how violations will be monitored or disciplined by organization; or how practices will avoid violations during clinic visits.)2.5 ptsLevel 3Individual shareholder’s perspective did not add value to the content or was not cohesive. Each section broken into shareholder’s perspectives and not exemplary of the policy example provided. (Ex: sections labeled “doctor” or “compliance officer” etc.)1.25 ptsLevel 2Missing the majority of individual shareholders’ perspectives and was not cohesive.0 ptsLevel 1No contribution submitted5 pts
This criterion is linked to a Learning OutcomeSources5 ptsLevel 5At least one quality, scholarly source provide in acceptable APA format (in APA reference list and in-text)3.75 ptsLevel 4At least one source provided in acceptable APA format but missing in-text citations.2.5 ptsLevel 3Source not in acceptable APA format and/or incorrect/missing in-text citation1.25 ptsLevel 2Source not scholarly (Ex: weblink or wikipedia), no in-text citation0 ptsLevel 1No sources provided5 pts
Total Points: 20PreviousNext

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please respond to this post.

Understanding the immune system is important for public health professionals as they will be able to advise members of the public on the importance of maintaining healthy immune systems. Eating a balanced diet with vitamin C, D, zinc, iron and protein has been identified as critical for the growth and function of immune cells while diets high in processed food can negatively affect it (Nutrition and Immunity, 2021). This understanding of the immune system has aided public health professionals in the creation of vaccines that protect people from potentially deadly viruses. A vaccine is the preparation of antigenic material designed to induce an immune response and immunological memory when injected and immunization has been proven to be a cost-effective way to prevent infectious diseases (Battle, 2009).

‘Inflammation can be defined as the body’s local and vascular and cellular response to injury caused by factors that invade and injure the body from outside or factors within the body that result in cellular or tissue damage’ (Battle, 2009). Signs of inflammation have been compared to a car’s dashboard engine light that tells you when something is wrong (Harvard Health Publishing, 2017). A public health professional being able to identify the signs of inflammation and understanding the pathophysiology will be able to determine when there is injury in a body that may need attention. Knowing that acute inflammation is identified with redness, swelling and pain that occurs for a relatively short period of time as opposed to chronic inflammation that lasts a long period of time can assist a public health professional advise patients. Diseases such as diabetes, cancer, arthritis and Crohn’s disease are associated with inflammation (Harvard Health Publishing, 2017).

Carcinogenesis is the generation of cancer from normal cells and has three stages-initiation, promotion, and progression. It is important for public health professionals to understand carcinogenesis as they will be able to provide the community with information about cancer prevention techniques and provide high risk populations with primary prevention. Minority communities are particularly at risk and can benefit from accessible cancer screening and pubic health professionals can act as advocates for those who need it the most.

Battle, C. U. (2009). Essentials of public health biology: a guide for the study of pathophysiology. Jones and Bartlett Publishers.

What are your thoughts Be sure that the responses to the  Post of peers include 2 peer reviewed references with content that demonstrates critical analysis and synthesis of references used.  

One of the healthcare information technology trends within my organization would be the use of Electronic health records (EHR). The use of EHR allows healthcare workers to communicate with one another, as well as with their patients. EHRs contain data concerning a patient’s medical diagnosis and treatment, that gives an extensive overview of the patient’s medical history (HealthIT.gov, 2018). This discussion will address the benefit and risks of EHRs.

EHRs have always been the cutting edge of technological advancement. McGonigle & Mastrian (2017) discusses the standards of EHRs are evolving and barriers to adoption remain as a collective momentum that would benefit clinicians and as well as patients. The benefits of using EHRs according to McGonigle & Mastrian (2017) are to increase delivery of guidelines-based care, enhanced capacity to perform surveillance and monitoring for disease conditions, reduction in medication errors, and decrease the use of care. Another potential benefit of EHR is patient support, which provides education and home telemonitoring for the patient. 

 Although using EHR brings several benefits within the healthcare setting, the use of it could potentially bring some risks. The downside of using EHRs while accessing care online may bring security issues. Privacy and security are one potential problem when accessing information online leaving an open door for cybersecurity concerns. This may increase malpractice liability, inaccurate data, and time and money (Hoden, 2020).

With this risk, legislation took a step forward in the advancement of EHRs. The legislation included a HITECH act, which provides incentives to health organizations and providers using EHRs. These incentives would provide reimbursement rates from Medicare and Medicaid Services (McGonigle & Mastrian, 2017). 

I believe the use of EHRs could be at the forefront in the advancement of healthcare as it shapes the future of technology. The advancement of EHRs from technology has allowed different applications such as mobile devices to become more accessible in healthcare. This would give way to telemedicine as well as remote telehealth. HealthIT.gov (2018), agrees the EHR system is built to go beyond standard clinical data collected in a provider’s office and can be inclusive of a broader view of a patient’s care. 

 Vianna J

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UNIT 3 – DISCUSSION BOARD

Part 2

Entering New Markets

The company enters markets in the global business environment through joint ventures and licenses every day. Licensing is a contractual agreement where one company uses another company’s intellectual property such as patents and designs. The licensees do so to reduce the risk of the market. One common brand that adopts the franchising model of licensing is McDonald’s. The company allows local companies to pay franchise fees, and, in return, they get the terms of operating the business. They are also allowed to market and use the brand name. MacDonald will occasionally evaluate the quality and the entire business. Jaguar is also a company in the UK that uses a private label manufacturing licensing model (Jayachandran et al., 2013).

This is where a local company in a different country manufactures a product and sells under the brand name of Jaguar. This makes it easy for the Jaguar brand to enter new markets, while another company can produce Jaguar quality products. 

Some companies have expanded from joint ventures and formed strategic alliances with other companies and foreign entrants. A good example of a joint venture is Pepsi and Starbucks. The two companies formed a third company to achieve a common objective. The joint venture was established in 1994 to produce ready-to-drink coffee products. The North American Coffee Partnership has been successful having received resources from giant successful companies. The flagship product Frappuccino allowed Starbucks to enter the bottled beverage market, and Pepsi obtained a new product from a well-known brand. The beverage’s ready-to-drink coffee beverage has a market share of 95% in different countries (Insights, 2017). In short, the company chooses to enter new markets through different channels such as licensing and joint ventures. This not only reduces the risk, but also ensures the success of the joint venture through the support of the parent company.

Sunshine S

WEEK 6 MAIN DISCUSSION POST
Licensing is among the commonly used forms of foreign market entry strategies. The strategy entails entering into a license agreement whereby a local company gives a foreign company the rights to use its name, brand, and intellectual property, in the foreign market. The strategy is preferred because of its low costs of entering foreign markets, although the companies may lose significant control over their businesses. Some key companies using licensing to support their global business expansion include Disney Consumer Products and the Pentland Group. Disney is American-based, with its headquarters in Burbank, California. The company operates in the retail industry. Pentland Group is a British-owned company, and in the year 2008, it licensed a significant percentage of its products, such as the Hunter, Brasher, Speedo, Ellesse, mitre, among others. The licensing strategy has proved to be an effective foreign Market entry strategy, as the two companies have established their brands appropriately in the international markets, thus recording high sales and profits (License Global, 2020).
A joint venture refers to a situation whereby two or more companies work together towards achieving a common goal. There are numerous successful joint ventures, among the highly notable ones being the NBC Universal Television Group (Comcast) and Disney ABC Television Group (The Walt Disney Company). The two companies joined their operations back in 2018, intending to create a video streaming site or an application known as “HULU.” The designed website was expected to support high-quality video streamlining, accessible using electronic gadgets like computers and smartphones. The joint center was a huge success, with a product offering of up to $1 billion, thus increasing the two companies’ value (Thakur, 2021).

Ciamyischa B

Part 2: Questions 2,4,5 

2. Please review the process and outlines of other students, providing an objective assessment and constructive feedback that will help strengthen the effectiveness of their efforts and the quality of their finished products.  

In reviewing some of my classmates outlines I see that everyone seems to be on the right track. There are many different formalities and directions that most of us are going in, however I see everyone is being very detailed and organized. I can also see there is much research and preparation going into this project.  

4. What is the purpose of a Key Operating Principle? 

The key purpose of operating principles is to make certain people are focused on doing the right things. It helps in making the right decisions and how to come collaborate and come to those right decisions. When there are conflicting situations, organizations use the operating principle to help with the solving of those issues.  

5. What sort of additional material would best ensure success of the project? Why? 

To have a successful project, collaboration, communication, and team work is a must. Also, there can be additional material that can be used, like actually interviewing key role people in an organization or one whom has just started a business to find out how they put together their business plan. Also using school resources that have been provided will help in a successful project.  

Micah S

Hi All,

Mission statements can allow individuals to see what an organization is all about.  The essential elements are the customers, markets, technology, philosophy, self-concept, concern for public image and employees, concern for survival/growth and profitability and products/services.  The customers are who the targeted demographics are.  The major products/services offered by the company and the market are included.  These two elements help in knowing where and with which products/services the company focuses on.  The concern for public image and employee refers to the company attitude and public image.  This is important because brand name and how consumers perceive you is important to profitability.  The concern for growth and profitability reinforces the efforts and determination of the organization to find financial success.  This is tantamount to self-concept and determining the competitive advantage of the company.  This connects to technology and the organization using relevant systems to stay current in the industry.

Operating principles define how an organization operates to be successful in their given industry (Austin, 2019).  The purpose of key operating principle is to show the boundaries upon which the organization conducts itself.  This includes expectations such as sustainability, employee focus, etc. that help establish the frame the organization is operating.  It also show the alignment of the organization to the mission/vision in how the operating principles connect to the goal of the organization.

There are several additional materials that would ensure success of the project.   Determining leadership style and company culture would help in reinforcing the business plan so that stakeholders are able to see how employees will be best motivated to achieve the goal of expansion.  Also, identifying strategies to have the competitive advantage or if there are any collaborative strategies that will be implemented.  Collaborative strategies, for example strategic alliances, allow companies to work together for a mutual benefit (American InterContinental University [AIU], 2021).  Including strategies that will be implemented to bring success to the project adds strength to the proposal of the project.  The implication is showing focused efforts that will establish success.