BlickenWolf - Our Team

Carmen R. Wolf has managed and conducted a broad range of healthcare investigations as well as providing fraud awareness and prevention methods to clients. Carmen specializes in assisting providers with risk assessments as part of the overall development and implementation of corporate compliance programs. She has also done extensive work related to Corporate Integrity Agreements including annual compliance audits and mandatory training. Carmen has assisted numerous providers in identifying underlying operational issues that lead to non-compliance and has assisted in re-tooling those processes to ensure compliance going forward.

Carmen is a registered nurse and recently jointly formed BlickenWolf LLC after spending over six years at Deloitte & Touche. Prior to that, she was a manager at the Milwaukee Heart Institute and a staff nurse at St. Luke’s Hospital, Aurora Health Care.

Integrity and Investigative Services Experience

Led voluntary disclosures where providers have found billing and coding issues that could have led to false claims issues. Assisted in the development of disclosure to the Office of Inspector General and/or Fiscal Intermediaries as deemed appropriate by counsel. Utilized the OIG’s voluntary disclosure protocol including performing claims sampling and analyses.
Led several internal investigations for integrated delivery systems, physician groups, pharmacies, payers including performing interviews, analyzing records and assisting counsel in case development.
Provided litigation support to attorneys under the attorney-client privilege to assist in case development, record analysis, expert report compilation, and preparation of expert witnesses.
Served as the Independent Review Organization for companies that have been subject to settlements with the Department of Justice regarding violation of federal and State false claims statutes. Have performed compliance, billing and systems engagements as outlined in subsequent Corporate Integrity Agreements.
Developed educational compliance presentations for several organizations subject to Corporate Integrity Agreements and have taught over 200 training sessions regarding compliance, billing, coding, false claims, fraud, abuse, and government intervention activities to providers, attorneys, and device manufacturing companies.
Implemented corporate compliance programs for consortium of 15 anesthesiology groups.
Coordinated the development of Codes of Conduct, Program Guidelines including policies and procedures around each of the seven essential elements. Performed risk analysis and medical record reviews. Provided educational training to anesthesiologists and CRNAs regarding CPT (including E/M) and ICD-9 coding.
Performed an audit of ER documentation, CPT coding, and billing in connection with an internal investigation in response to a hotline call. Potential effect on reimbursement as a result of coding changes performed. Recommendations given for follow-up education, process improvement, and procedure implementation. Worked with legal counsel to develop an action plan for reporting overpayments.
Structured and implemented a compliance program for third-party billing company, including identification of potential exposure areas, development of a Code of Conduct, policies and procedures related to background checks, hotline operation, ongoing audit plan, training/education, and investigation performance.
Directed the implementation of a compliance program for integrated delivery system (acute care hospital, home health agency, physician practices). Performed a detailed risk assessment based on OIG identified risk areas, developed a code of conduct, rolled out the compliance training/education program to 700 system employees, designed program for performing background checks, assisted human resource department to incorporate compliance responsibility into job descriptions at all levels of the organization and to incorporate failure to comply language into system-wide disciplinary process. Also investigated questionable hospital billing practices in light of regulatory guidance and gave recommendations for change in operational policy and ongoing monitoring for compliance.
Assisted in the billing practice investigation and analysis of national for-profit healthcare system. Analysis included charge description master review.
Assisted a rural medical center in analyzing the feasibility of development of a PPS exempt rehabilitation unit. Analysis included forecasting market demand and reimbursement trends. Several financial scenarios were developed and presented. The project included operational analysis regarding staff qualifications and development.
Assisted a hospital-owned physician network in operational improvement of their business office procedures. Analyzed work flow and staffing mix. Formed an operations improvement task force to analyze work steps, identify inefficiencies, and develop an efficient flow of work in order to improve days in accounts receivable.
Managed a strategic options assessment for a large multi-specialty clinic. Analysis included market demand, managed care penetration, and subsequent community needs. Options were analyzed based on financial considerations, professional practice development, and integration needs with both a large medical center and managed care organization.
Assisted a medium-sized medical center in an enterprise-wide software selection study. Coordinated the operational analysis, vendor selection, and demonstration. Assisted in facilitating consensus among management team regarding selection and assisted with contract negotiation.