More than an important-sounding title
Compliance officer performs many duties
Ensuring compliance with proper billing and claims procedures is one of the hottest topics in health care today. One basic question practices across the country are asking is: "How should we structure our compliance program, and what kind of person should we look for to manage it?"
About 40% of all health care organizations already employ a corporate compliance officer, according to a survey by Witt/Kieffer, Ford, Hadelman & Lloyd, an executive search firm based in New York City. Of the rest, 44% said they plan to hire a chief compliance officer within the the next 12 months.
At the recent National Congress on Health Care Compliance in Washington, DC, a group of industry veterans shared their ideas on the fundamentals needed to create a successful compliance program. The group included: Greg Warner, director of compliance for the Mayo Foundation; Eileen Boyd, chief compliance officer, Stanford Health Care System; Lisa Mertha, director of the control and compliance practice for Deloitte and Touche's Philadelphia office; and Brent Saunders, senior vice president for compliance and regulatory affairs, Home Care Concepts of America. The following is a consolidation of the group's thoughts.
· Building the structure. There is no single background that makes for a good chief compli ance officer (CCO). Superior CCOs can come from any number of areas - finance, legal, or operations, to name a few. No matter the background, however, certain qualities are very important. Among the traits you want to look for: a good personality, the ability to command respect, and an excellent ability to manage their operation.
· Lines of authority. The CCO should report to the most senior manager in the practice. This keeps responsibility for compliance at the top of the organization. Some organizations have also created a dual reporting structure for the CCO, where she or he reports directly to the CEO on a regular basis, and to the board of directors at periodic intervals. Ideally, however, the CCO should not be affiliated with or supervised by the group's internal or external counsel, as this would create a conflict of interest and potentially compromise attorney-client privilege. Similarly, the CCO should not be supervised by the chief administrative or financial officer.
· Working with your lawyer. Knowing when and when not to directly involve the group's legal counsel can be tricky. The group advises that it may be best to first access potential external-based problems before delving into past internal problems in order to get the program up and running. However, not long after the compliance program is in place, the CCO should collaborate with the group's lawyers in performing a legal audit of current and past procedures.
Because one of the goals of a compliance program is to have an open and informed operation, the CCO should be apprised of which areas fall under the attorney-client mantle. This is especially important when it comes to a risk assessment process called facilitation, in which practice employees are asked to identify current and past procedures and practices they feel could put the group at risk for fraud and abuse charges.
· Determining the right number of compliance officers. While some experts feel there is a benefit to having several different compliance officers, it is still considered critical to use only one designated chief compliance officer. Larger practices with multiple offices, however, might want to consider appointing a designated compliance person who operates under the general supervision of the CCO for each location.
Another way to achieve diversity in the compliance process is by forming a compliance steering committee. The committee brings together individuals from each aspect of the practice - such as billing, accounting, records, legal, and physicians - to help the CCO create and implement the group's compliance program.
· Involving key players. When key functions like billing are delegated to outside organizations, it is vital that they be included in the group's compliance coverage. The first step is to understand what functions performed by outside contractors and agents need to be covered under compliance procedures. Third-party billers and any other outside contractors must be educated about their roles and responsibilities under the compliance procedures.
· Physician participation. It is crucial that the compliance program and CCO have the full and public backing of the group's physician leadership. As such, physicians need to be included on the compliance committee and given an active role in pointing out possible compliance programs they have encountered or noticed.
· Making it fit. Smaller organizations with limited budgets need to remember that it does not take a lot of money to implement an effective compliance program. One way to save money is stay focused on organizing and starting up the most critical elements of the program at first. It is also all right to use creative alternatives, such as using a suggestion box instead of an outside hotline for employees wanting to report possible problems.
· Getting specific. One effective way to get the practice to understand and respond to new compliance rules is to start with broad general standards that articulate the practice's attitude and policy. One such standard might be, "Fraud and abuse will not be tolerated." Then, add more specific rules and standards for each department and function.
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