Effective Healthcare Compliance Programs Drill Down To Department Operations
(RIVERWOODS, ILL., October 27, 1999) Cutting through the quagmire
of Medicare regulations and government requirements to ensure healthcare compliance is a
daunting task for healthcare systems of all sizes. By breaking the formidable task down
and understanding compliance at the department level, however, healthcare organizations
can better meet the challenge of complex regulations, according to CCH INCORPORATED (CCH),
a leading provider of healthcare law information and software and publisher of the CCH®
Healthcare Compliance Portfolio.
Effectively tackling healthcare compliance through the daily activities of individual
departments was the topic addressed by CCH and Lyndean Brick, JD, Senior Vice President,
Murer Consultants, Inc. and Michael Murer, JD, Executive Vice President and General
Counsel for Murer Consultants at a session during the Health Care Compliance
Associations Compliance Institute on Oct. 27 in Chicago. The meeting included health
system professionals from around the country who gathered to share best practices in
Departments Need to Sweat the Details
Focusing on the characteristics of effective compliance programs, Brick and Murer,
healthcare consultants and attorneys with extensive operational experience in the
healthcare industry, highlighted some of the key compliance issues that need to be watched
at the functional level.
Noting that the filing of incorrect Medicare cost reports remains a major source of
serious non-compliance, Murer said that the specter of false claims usually is raised not
because of fraudulent completion of the cost report itself, but because of inaccurate and
inconsistent cost accounting.
"Seemingly straightforward concerts of allowable costs can become cloudy in the
day-to-day realities of running a healthcare facility," said Murer. "Is the wine
and cheese reception for the MRI staff to celebrate their new facility an allowable cost?
What procedures should the department manager and the accounting department follow to
adhere to the law? Who is trained to classify expenses?"
More complex issues such as provider-based status, reserved cost reporting and
bad debt add fuel to the compliance fire, he said.
In the busy emergency room, Brick noted that from anti-dumping to ambulance restocking,
emergency services are especially problematic. Hospital and emergency physicians will only
meet their obligations under federal law, Brick said, through a focused and operational
approach to compliance in providing emergency care.
"The managed care procedures of prior authorization continue to conflict with
HCFAs clear disdain for this practice," she cautioned. "Facilities today
must be prepared to comply with the broadened off-site requirements of EMTALA."
Board of Directors
"In addition, legal deference to hospital boards of directors is
no longer the rule, and failure to follow the law can result in liability for its
leaders," Brick told attendees at the CCH-sponsored session.
Functional compliance is rooted in governance, which understands and
respects its duty of compliance, according to Brick. Board members set the compliance tone
for the organization, and the priority the board places on compliance is evidenced through
its own behavior, she said.
According to Brick, key questions to consider when assessing the board include: Does
each board member actively participate in decision-making rather than rubber-stamp
administrative recommendations? Does the board budget appropriately for compliance
efforts? Does the board regularly meet one-on-one with the compliance officer? Has the
board been thoroughly trained in its own compliance duties?
Information, Training Key to Successful Departmental Compliance
Key to the success of a functional compliance strategy are timely
access to information, effective training and accountability for actions at the department
In response to the healthcare industrys need to meet these new compliance
challenges, CCH announced at the HCCAs Compliance Institute that it will
introduce two new healthcare compliance products.
Created in conjunction with Ernst & Young LLP, CCH is introducing a new,
interactive compliance training tool a state-of-the-art, Internet-based resource
that hospitals and health systems can use to train all levels of hospital staff on a
comprehensive range of compliance issues. This flexible, customizable program provides
both in-depth compliance instruction and concise overviews of specific compliance issues
as appropriate to the needs of the hospital and the individual student.
The training tool has been designed expressly for the purpose of helping compliance
officers educate many different types of healthcare employees on the compliance issues
that impact daily work routines. Instructional overviews, case scenarios, pre and post
tests and innovative reporting and tracking software, make this training tool an
invaluable aid in establishing a program for functional, department-focused healthcare
Available in early 2000, the CCH healthcare compliance training tool will focus on
governance, coding and billing, cost reporting, the emergency department and physician
relationships. The specialized training tool will be expanded throughout the year to
include pharmacy, ambulatory providers, medical records, managed care and more. For more
information on this new training program, contact Daniel J. Weissburg, Esq., at CCH
(847) 267-2145, or firstname.lastname@example.org.
CCH will also introduce Functional and Operational Healthcare Compliance, a
two-volume print reference designed to assist compliance professionals and hospital staff
alike in creating and implementing a truly effective compliance program. Authored by
nationally-known healthcare experts and backed by the legal and regulatory expertise of
CCH, Functional and Operational Healthcare Compliance takes healthcare compliance
"to the next level" by focusing on the everyday work routines of provider staff
and identifying where in the course of those work routines the most common compliance
Included are real-world case studies, solutions and specific compliance guidance for
every functional area. Features include quick-read checkboxes of key compliance concerns
in functional areas, detailed scenarios of the common compliance situations faced by
hospital staff every day and breakout lists of the top issues every staff member should
know about compliance.
Volume One covers all major hospital units and departments with significant compliance
obligations, including hospital governance, medical records, pharmacy and emergency
medicine. Volume Two addresses all major components of the healthcare delivery system that
are not hospital-based, such as ambulatory providers, physician group practices and
skilled nursing providers.
The content of each functional area is completely explained and individually bound, so
it can be separated from the volumes and circulated to appropriate hospital staff.
Functional and Operational Healthcare Compliance is scheduled for release in
early 2000. For more information, contact Wendy Williams at CCH 847-267-2818, or email@example.com.
About CCH INCORPORATED
CCH INCORPORATED, headquartered in Riverwoods, Ill., was founded in 1913 and has served
over four generations of business professionals and their clients. For more than 50 years,
the company has regularly tracked, reported, explained and analyzed health and entitlement
law for healthcare providers, insurers, attorneys and consumers. A leading authority in
healthcare information, CCH publishes the CCH® Healthcare Compliance Portfolio,
as well as the industry standard, the CCH Medicare and Medicaid Guide. CCH is a
wholly owned subsidiary of Wolters Kluwer U.S. The CCH web site can be accessed at www.cch.com.
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