How the model came about
The PWC/UCLA project began two years ago with a standard research protocol that included a literature review of 18,381 current articles relating to compliance. The review covered both health care and nonhealth care industries and yielded 593 compliance principles that two expert panels then developed into 137 indicators of effectiveness.
Then, data-collection instruments were created:
- The Indicator Questionnaire. Face-to-face interviews with up to seven senior management representatives were used to determine the existence of defined attributes prescribed by the Federal Sentencing Guidelines.
- The Employee and Physician Awareness Questionnaire. Self-administered question sets were used to gauge the level of employee and physician knowledge about his or her organization's compliance program and his or her substantive knowledge about compliance.
- The Billing Accuracy Review database. Coders conducted a retrospective billing review of 100 inpatient and 100 outpatient claims for selected Medicare and Medicaid services. Both types of visits were evaluated for coding appropriateness and claims accuracy.
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