Compliance officer role expands to accreditation
Health care experts see inevitable merging of compliance and quality assurance responsibilities
As the role of compliance has grown within hospitals, compliance officers are taking on new and wide-ranging responsibilities in areas such as accreditation and quality assurance. Compliance officers and others say that how these new responsibilities are managed and how organizations are structured will determine their success.
Bret Bissey, chief compliance officer at Deborah Heart and Lung Association in Browns Mills, NJ, says he sees this as a growing trend. "If you have an effective compliance program, regardless of the type of organization you have, you have to step beyond the fraud and abuse issues." According to Bissey, even if compliance officers are not intimately involved in the day-to-day operations of accreditation, they should at least have an oversight role to make sure that what is happening is appropriate.
"I see this as a trend, and I think it makes sense as the compliance field grows," says Bissey. He adds that as compliance programs evolve, compliance officers will want to make sure that issues central to accreditation by the Joint Commission on Accreditation of Healthcare Organizations (JCAHO), based in Oakbrook Terrace, IL, also become part of their oversight process, even if they are not part of their direct purview.
Lisa Murtha, JD, chief compliance officer at Children’s Hospital in Philadelphia, takes a similar view: "Many of those [accreditation] people have recently been appointed as the compliance officers for their institution, which means they are inevitably going to have the quality assurance focus that goes along with what they do concerning JCAHO," she explains.
"That does not mean that regulatory requirements take a back seat," she adds. "It just means that it is incorporated into operations, as opposed to being seen as an afterthought or as merely an oversight function." In fact, she says, the most successful programs she has seen are those that incorporate compliance monitoring and training into the day-to-day operations of the organization.
Murtha also points out that both the Joint Commission and the Washington, DC-based National Commission on Quality Assurance (NCQA) have warned that failure to comply with the looming privacy requirements included in the Health Insurance Portability and Accountability Act of 1996 (HIPAA) would be considered a violation of NCQA and Joint Commission standards. "While we [view] the privacy and security aspects of HIPAA as more of a compliance-related issue, they are now being actively incorporated into the accreditation process and the quality initiative," she asserts.
Al Josephs, chief compliance officer at Hillcrest Health System in Waco, TX, says that while many organizations already have quality assurance departments, their efforts increasingly will merge with compliance efforts. Like Murtha, he says that the more he becomes involved in quality assurance, the more compliance-related activities he discovers. He also agrees that HIPAA is the "800-pound gorilla" just around the corner.
Joe Murphy, president of Compliance Systems Legal Group in Haddonfield, NJ, sees a distinct trend in health care compliance moving from a very narrow focus on areas such as coding and billing to a broader focus including values and ethics. "Fundamentally, I don’t have a problem with the compliance office dealing with issues of accreditation because that is very similar to compliance," he asserts. "My concern is whether there are sufficient resources focused on compliance."
According to Murphy, all of these issues point directly back to the debate over the appropriate role of the compliance officer. He says one facet of that debate is whether the compliance officer position should be a stand-alone position or a position combined with other functions. "HHS [Health and Human Services] has taken the position that it is better to make it a stand-alone position, but my analysis is a little different," he says. "I would rather have a compliance officer with some clout, and any time you take a compliance officer and give him a narrow compliance/ethics function, you run the risk of marginalizing that person."
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