SCALE Case Study:

SCALE Portfolio Services: Compliance

Client Profile

  • Number of Portfolio Companies:
    4
  • Fertility:
    7 patient facing brands across 12 states
  • Long Term Care Pharmacy:
    Serving >319 client locations
  • Primary & Urgent Care:
    26 practice locations across 2 states
  • DME:
    15 sites

Services Deployed

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Foundational Assessment

Program Development

Advisory & Auditing

High Risk P&P

Compliance Software

Situation

SCALE was engaged by a middle market private equity firm ($2B in committed capital), whose goal was and remains to drive transformational growth, as well as to work in an efficient and coordinated manner across its existing healthcare portfolio companies.

There was a need to rapidly and cost effectively develop a robust and scalable compliance program to sustainably maintain high quality compliance oversight.

  • While compliance was a key focus area for the portfolio companies’ internal management teams, institutional-grade compliance programs had not been developed.
  • Management previously consulted with outside counsel reactively on individual compliance matters, and desired to transition to a more proactive, integrated and operationally focused approach to compliance.
  • Management teams lacked the bandwidth and specialized expertise across the holistic compliance & risk management ecosystem to build and manage their individualized compliance programs.

The private equity sponsors desired to approach compliance across its portfolio on a coordinated basis to benefit from shared best practices, shared program development, cost efficiencies and user-friendly centralized reporting.

Execution Approach

To address compliance development and oversight objectives holistically, SCALE deployed a team of specialized resources across:

  • Clinical Compliance
  • Regulatory Compliance
  • State Privacy & HIPAA / Hi-tech Compliance
  • High Risk Area Policies & Processes
  • Coding & Clinical Documentation Compliance

The Client was pleased with the individualized approach SCALE took and the outcome achieved through the following strategies:

The Client was pleased with the individualized approach SCALE took and the outcome achieved through the following strategies:

Foundational Compliance Assessment

  • Formalized risk identification and avoidance strategy via gap assessment & due diligence audit of each company’s systemic compliance risk to ascertain overall foundational risk universe and state of compliance
  • Examined compliance issues to mitigate any potential financial and operational loss
  • Uncovered vulnerabilities and established workplan to implement plan of correction

On-going Compliance Oversight

  • Established a fractional Compliance Officer role
  • Implemented processes to detect and/or prevent regulatory mishaps
  • Developed fraud, waste & abuse (“FWA”) training for Board of Directors
  • Led various training & education programs related to pertinent compliance topics

Compliance Program Development

  • Implemented robust compliance tracking tool that enabled real-time updates for C-suite, Board of Directors and Owners
  • Established multi-disciplinary Compliance Committee
  • Updated and expanded upon key policies & procedures to ensure regulatory compliance and mitigate regulatory risk

Results

Program Development

  • Provided stakeholders with trusted partnership and realtime updates via engaging tracking tool on organizational compliance efforts and regulatory risks.
  • Established and attended monthly compliance committee meetings with key stakeholders of the collective companies’ management team.

Compliance Program Improvement Identification & Remediation

  • Mitigated various regulatory issues as they arose, providing recommendations for remediation
  • Provided holistic program oversight via fractional Compliance Officer role
  • Worked collaboratively with the portfolio healthcare companies’ teams to implement an organizational compliance program which complies with OIG’ s 7 elements, building annual workplans specific to their industry risk.
  • Worked collaboratively with the client companies’ respective teams to implement an effective and sustainable privacy program which complies with state and federal requirements.
  • Addressed high risk area policies, providing recommendations related to internal controls that adequately measure and manage risk through auditing and self-monitoring functions
  • Completed various training & education programs related to pertinent compliance topics

Company, Sponsor-Level & Board Compliance Reporting

  • Developed materials for reporting compliance functions to Board.

Add-on Acquisition Diligence

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