I knew they would disregard each and every word of the Corporate Integrity Agreement. I said so right here, the very day it was announced. As for the $24 million paid to the Federal government, and just over $2 million to the state of New York, to them it was going to be nothing more than the cost of doing business. Pay to play-simply another business expense. Hey, do they get to deduct that from their income tax return?
The current CSHM crew took over the operation of the Small Smiles dental clinics after they purchased all of them in the fall of 2006-actually they hired the old bunch to do it for a while.
The arrogance shined like a beacon from the start. The investigation by the Justice Department started in the fall of 2007, just about the time
Alberto Gonzales resigned. All the while, thumbing their very long-and continually growing-nose directly at the entire United States Department of Justice, the US Attorney General and about 23 state Attorneys General and the public at large. No settlement was announced and signed until January 2010. During which time, they didn’t slow down, skip a beat, miss a step-or any other idiom you want to use. The child abuse and Medicaid fraud continued-business as usual.
I originally planned to take all 65+ of the Corporate Integrity Agreement (CIA) that Church Street Health Management (CSHM)- formerly FORBA – signed in January 2010 and mark all the ways, I knew for sure, CSHM had violated said agreement.
I had not got past Section III before I was overwhelmed. No, that’s not right, I was pissed off! Why? Because of the continued arrogance.
So I decided to pick out my top
five
1. Continue with bonus program that is based on “production” or in CSHM speak, “Collections” To this day, everyone gets bonus if they meet “collections” goals, and it gets bigger if they meet set intervals, no max they can make. See below. BTW the Lead Dentist gets 12.5 times the said amount. Lead Dental Assistant gets 1.5 times set amount.
2. They are not supposed to base any compensation that would create an atmosphere for overtreatment and fraud, i.e. no % based pay. Well, continuing with the bonus program didn’t thumb their nose to the CIA enough, no, they created a whole new contract for new and current dentists called “Collection Based Compensation”. It’s all set out in a 30+ page contract that most CPA’s can’t figure out.
3. Compliance Officer is not supposed to be the Chief Financial Officer – so they put the SVP of Financial Operations, Lorri Steiner in that position. No, she’s not the CFO, but c’mon!
4. Appoint Compliance Liaisons at each center who are not afraid to report compliance breach to the board of directors, the compliance officer or anyone else. So, what dose CSHM do, they make the Compliance Liaison the Office Manager! Guess who gets a nice size bonus if all things go well at the center and they make their production goals, yep, the Office Manager!!!
5. Hire an Independent Monitor to “monitor” their misbehaving. So what does CSHM do, they have amazing made sure that N. Sue Seale, DDS, a great buddy and colleague of their Chief Financial Officer, Steven Adair, is the “pediatric dental professional” to check in on things with the Independent Monitor. Reports to me are Sue and Steven come to some of the centers together and are quite cozy!
There you have it, my top five. Well, the top five I picked out in the first few pages of the CIA anyway.
