Open lines of communication
Cooperation avoids duplication of efforts
By Roy Snell
Chief Compliance Officer
University of Wisconsin Hospitals, Clinics, and Medical Foundation
Madison, WI
Debbie Troklus
Director of Compliance
University of Louisville (KY) School of Medicine
Compliance programs are no longer optional; they are mandated as essential to your organization's health. The implementation of an effective program can be a challenge. Providers across the country are scrambling this year to develop plans and appoint their compliance officers.
The Federal Sentencing Guidelines provide the basic elements that should be included in a compliance program. One of these elements states that a high-level person should be responsible for overseeing compliance. Along with the title of compliance officer come extensive duties:
· Work with an attorney to develop and implement the program. Whether counsel is internal or external, he or she must be accessible and familiar with your organization's history. Day-to-day operations of a compliance office depend on a close relationship.
· Communicate the program and its goals to everyone in the organization. Each individual must understand the goals of the plan and make them part of everyday activities. Everyone must feel the responsibility to be compliant.
· Develop procedures and benchmarks to constantly monitor the effectiveness of the program. The program must be effective, and only by closely monitoring and constantly changing it can you continue to ensure its effectiveness.
· Become the authority on standards of conduct and identified risk areas. The compliance officer must understand the intricacies of the program as well as its risk areas. Continual education is vital because changes in these areas are frequent.
· Coordinate and develop training for physicians, residents, billing staff, and agents who may work on your behalf. Training is the key to the program. Everyone needs training on what is expected. To impose sanctions on physicians, they have to know the rules up front. Education should be mandatory.
· Develop and implement a reporting system. A system is needed to accurately report the findings of a chart review. The reporting system should be refined constantly to provide the information needed by physicians to change behavior and be in compliance.
· Be consistent. All sanctions and reviews must be conducted in a consistent manner. Consistency lends to credibility, and credibility is essential.
· Collaboration avoids duplication of efforts. The compliance officer has to ensure collaboration between the hospital and physician; investigations usually involve both outpatient and inpatient services.
· Communication in all forms is important - written, verbal, and face-to-face. If the hospital is under investigation, the physicians can only be supportive if there's been open communication.
· Access to medical records - make sure physicians and coding staff know systems and procedures. Quick access to the medical record is critical. Physician documentation supports both hospital and outpatient claims.
· Education is a key to the communication process and the entire program. Physicians and hospital staff must understand the rules of documentation.
· Joint coding of hospital outpatient facilities is efficient and ensures Part A and Part B match. Why code a single visit twice?
· Unified efforts are impressive to investigators and also present a clearer picture. Joint efforts ensure that compliance issues don't go unnoticed.
· Medical necessity reviews are most successful when done in a collaborative manner with physician leadership and peer-to-peer reaction.
· Support of the program by everyone leads to greater credibility for the organization and its program.
[Editor's note: Roy Snell is president of the Health Care Compliance Association in Madison, WI, and Debbie Troklus is second vice president of the Association.]
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