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 Association’s Compliance Institute on Oct. 27 in Chicago. The meeting included health system professionals from around the country who gathered to share best practices in healthcare compliance.

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.

Cost reporting

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.

Emergency medicine

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 HCFA’s 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 Strategy

Key to the success of a functional compliance strategy are timely access to information, effective training and accountability for actions at the department level.

In response to the healthcare industry’s need to meet these new compliance challenges, CCH announced at the HCCA’s 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 compliance.

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 weissbud@cch.com.

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 pitfalls lie.

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 williamw@cch.com.


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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