CCi Compliance Management System

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The System Behind the Officer

Compliance at CCi

We are extremely fortunate to have Dawnielle Grace on our team at CCi. As our in-house General Counsel and Compliance Officer, she oversees

  • Compliance training and the execution of our Compliance Program
  • Operations of our in-house collection agency
  • Litigation and response to legal inquiries

However, one of her greatest contributions to CCi and the hospitals we serve is the implementation of a corporate-wide Compliance Management System. The beauty of the CMS is that, regardless of the strong assets we may hold in human capital (and we really do think Dawnielle is “stellar”) a well-defined and documented systems serves as a lasting foundation that will serve in perpetuity. It is an infrastructure that not only guides and executes how we maintain compliance but also helps align the operations around patient communication with CCi’s mission and values.
 
In a recent Sales Meeting, Dawnielle presented the following outline of the CCi Compliance Management System.


A cornerstone value at CCi is to surpass the highest standards of ethical, professional, and business conduct with customers, patients, and partners. As a policy, we maintain full compliance with all industry federal and state laws. To fulfill these commitments, CCi has a comprehensive Compliance Management System (CMS), overseen by our in-house General Counsel & Compliance Officer. The CMS ensures that we exceed the expectations of each of our valued clients as we partner together to serve the community. Three fundamental programs contribute to the infrastructure and the processes that help us execute the objectives of the CMS: the Compliance Program, the Patient Communication Program, and the Annual Audit & Risk Assessment.


COMPLIANCE PROGRAM

In accordance with the compliance guide published by the Office of the Inspector General (OIG), a division of the Department of Health and Human Services (HHS), our Compliance Program consists of:

  • Designation of a Compliance Officer, Security Officer, and Compliance Team
  • Development of written standards, policies, and procedures to promote compliance
  • Regular, effective education and training programs for all CCi staff
  • A process to receive complaints concerning possible Compliance Program violations
  • A process to respond to allegations of improper activities
  • A process for investigating and resolving any identified problems
  • The enforcement of appropriate disciplinary action
  • Methods to monitor compliance and assist in the reduction of problems
  • Overseeing Industry Regulatory Compliance
    • Health Insurance Portability and Accountability Act of 1996 (HIPAA)
    • Telephone Consumer Protection Act of 1991 (TCPA)
    • Fair Debt Collection Practices Act (FDCPA)
    • Fair Credit Reporting Act (FCRA)
    • Payment Card Industry Data Security Standard (PCI-DSS)

PATIENT COMMUNICATIONS PROGRAM

To ensure that each CCi communication that touches a patient is reflective of CCi’s commitment to excellence in the healthcare field, our Patient Communications Program consists of:

  • Biennial Review (and re-alignment if needed) of:
    • All 1st and 3rd party calls, including, but not limited to:
      • 1st party IVR calls
      • Agency IVR calls
    • CCi’s website including client and patient portals
    • Annual Call Quality Audits
      • Review of two calls per service representative on an annual basis (outside of the context our daily call quality reviews)
  • Annual Bureau for Consumer Financial Protection (BCFP), formally the CFPB, Internal Compliance Management Review

ANNUAL AUDIT and RISK ASSESSMENT

Conducted for:

  • HIPAA security and privacy
  • PCI-DSS compliance
  • Patient satisfaction and complaint monitors

EXPERTISE AT YOUR FINGERTIPS

Our resource is our customers’ resource. Dawnielle Y. Grace, JD MBA, is a licensed attorney serving as CCi General Counsel & Compliance Officer. She is always happy to join a call, discuss compliance strategies, or explore solutions with the hospitals and healthcare organizations that we serve.
 
We are a proud member of ACA International and, as of September 2018, Attorney Grace will hold the ACA’s Credit and Collection Compliance Officer (CCCO) designation.
 
Please feel free to contact Dawnielle if you have compliance questions or need assistance.
Dawnielle Y. Grace, JD MBA
Secretary, General Counsel & Compliance Officer
1-800-942-2995
dgrace@cciws.com

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