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The Health and Human Services (HHS) Office of Inspector General’s recent initiative regarding corporate integrity agreements (CIA) once again underlines the need for providers to adequately demonstrate the effectiveness of the compliance programs. "Effectiveness equals assessments," says Deborah Joslyn, a senior manager with Ernst & Young in Iselyn, NJ. "Effectiveness equals measurement."
According to Joslyn, the programs that work are ones that use control reviews almost religiously, take the audit process very seriously, and are always looking for new ways to communicate. "Those are the best programs," she argues. "If providers think a reactive audit will suffice, I think they are wrong."
Doing a lot of hardcore chart audits is valuable, but looking at the processes from the front line is equally important in order to avoid systemic issues.
Joslyn says the best way to measure the effectiveness of a compliance program is by addressing issues not through the hotline but at "the local level." She says the question to ask is whether people are participating in risk assessments at the local level, meaning that a manager assembles his or staff to evaluate what is working and what is not and making changes.
Determining who the primary audience should demonstrate effectiveness to is another challenge. "Our audience is the OIG because we have a mandatory CIA," says Nancy Milner, chief compliance officer at Eisenhower Medical Center (EMC) in Rancho Mirage, CA. "Everybody else is a minor player in all of this."
EMC has performed external and internal audits as well, she reports. But audits are not always the best tool in demonstrating effectiveness to the OIG, she adds. "We can audit all we want, but we can’t get resolution unless our staff understand what we are talking about," she asserts.
In the first year of the CIA, the most vigorous audit was concerned with making sure that everybody had been trained, she says. One of the ways EMC accomplished that was through training surveys with its staff to determine if the education worked. "We audit so many different aspects of billing," she explains. "But we also audit compliance with how many people have signed the agreement and how many understand what a code of conduct is."
Al Josephs, director of corporate compliance at Hillcrest Health System in Waco, TX, says the most critical challenge in terms of measuring effectiveness is learning how to make it a part of an organization’s culture. "You can perform education, but the real challenge is to keep it an exciting and viable part of the organization."
Josephs says the other challenge is integrating effectiveness measures into the overall ongoing operations of the organization. "We are hearing more about quality issues in nursing homes, and I can’t help but think that will move to acute-care hospitals eventually," he asserts.
That makes it important for compliance officers to remain actively involved in the ongoing operations of the facility and coordinate what they do with other parts of the organization, such as quality management and quality improvement.
The next leap forward in this area may come through some form of standardization. Earlier this year, the Philadelphia-based Health Care Compliance Association initiated a collaborative effort to seek a measurable health care compliance program effectiveness standard. The initiative tasks a coalition of stakeholders with evaluating the results of an empirical study of compliance program effectiveness.