Health care Management

BHA 3002, Health Care Management 1

Course Learning Outcomes for Unit IV Upon completion of this unit, students should be able to:

4. Outline the characteristics of the executive office. 4.1 Detail the key elements of an effective compliance plan for a healthcare facility. 4.2 Explain the importance of internal audits and project management in compliance plan creation

and implementation in a healthcare facility.

8. Evaluate ways to improve the quality and economy of patient care. 8.1 Describe the key biological, physical, and foodborne hazards in healthcare facilities. 8.2 Outline the importance of medical nutrition therapy and food safety for patient recovery in

various conditions.

Course/Unit Learning Outcomes

Learning Activity

4.1 Unit Lesson Chapter 8 Reading Unit IV Essay

4.2 Unit Lesson Chapter 8 Reading Unit IV Essay

8.1 Chapter 7 Reading Unit IV Essay

8.2 Chapter 7 Reading Unit IV Essay

Reading Assignment Chapter 7: Institutional Food Services Chapter 8: Compliance Plans

Unit Lesson Compliance in Health Care In this unit, you are reading about compliance in health care, which is a very important topic for all healthcare leaders and aspiring healthcare leaders to understand. What compliance really means is trying hard every day to do things the right way, showing integrity in all that we do in our healthcare facilities. Compliance should be all about ethics and operating within state, federal, and local laws. The opposite of compliance is fraud, false claims, embezzlement, kickbacks, and other actions that truly could shut a healthcare facility down, ending its ability to provide care for the community it serves. As we begin, let’s consider an example of why this topic is so important today. There have been many abuses of our healthcare system over the recent decades. It simply boggles the mind. For example, it was proven in court that Dr. Spyros Panos faked surgeries and billed Medicare for them (Neporent, 2014). Panos made false representations of various techniques that he performed in surgery and performed medically unnecessary procedures. He also saw as many as 90 patients per day. It would be a practical impossibility for an orthopedic surgeon to see that many patients in a day. Panos has been ordered to pay back $5 million to the federal government, and he has surrendered his medical license following charges of medical misconduct by the Medical Board of New York (Neporent, 2014). The remarkable thing is that Panos actually got away

UNIT IV STUDY GUIDE

Healthcare Food Services and Compliance

BHA 3002, Health Care Management 2

UNIT x STUDY GUIDE

Title

with such behavior from 2007 through 2011, racking up nearly $35 million in payments from insurance companies and government programs (Neporent, 2014). Panos likely will never practice medicine again, and there are more than 260 civil lawsuits against him initiated by patients, families, and other payers (Neporent, 2014). Another glaring example that many Americans will perhaps relate to due to heavy television advertising is the Scooter Store. Perhaps you will remember the commercials starring Tom Kruse, inventor of the Hoveround electric wheelchair. It certainly seems like a great idea to help our elderly patients, and the commercials were friendly and upbeat. The Scooter Store is now closed, shut down by Medicare for billing roughly $400 million to the Medicare programs for Hoverounds that were not medically necessary (“Justice Department Lawsuit,” 2005). Many of the complaints that led to this action by Medicare actually came from doctors who felt that they were being bullied into prescribing Hoverounds for patients who had no legitimate need for them at all. Dr. Panos and Hoveround are not the only examples of compliance violations in American health care over recent years, but they certainly make the point. We need a process in place for all healthcare providers to make sure that we are operating ethically and legally. That is what a compliance plan is all about. Compliance plans encourage everyone associated with a healthcare organization to report problems when they are observed, not years later, and they create a mechanism for constant monitoring of processes to identify issues early and to deter non-compliant behavior. Benefits of Solid Compliance Plans Compliance plans do many good things for a hospital or clinic. They increase awareness of key compliance issues among board members, administration, staff, vendors, physicians, and other providers. They help to quickly prevent and detect violations. They reduce liability for the hospital in the event of a serious compliance problem, and they enhance the reputation of the facility by showing that due diligence is being undertaken. It is fair to say that if the hospitals where Dr. Spyos Panos was practicing and doing his fraudulent surgeries, while seeing 90 patients per day, had a good compliance plan in place, he would not have gotten away with such conduct for four years. Someone would have spoken up and simply said that this does not seem right. Compliance Officer and Compliance Committee Someone in a leadership role within the healthcare organization needs to take ownership of compliance. In large healthcare organizations, the position of compliance officer is a full-time job, and the individual in that role will be either an attorney or a manager with special training in compliance. In smaller healthcare organizations, the compliance officer role is taken by one of the hospital department directors, and special outside conference training and in-house in-service training is provided for that individual. Regardless of how the position is filled, all accredited hospitals in America must now designate a compliance officer to take responsibility for creating and implementing a compliance plan. There must also be a compliance committee with representatives from throughout the organization to help the compliance officer and to provide input on key issues that come before him or her. Employee Training It is crucial that all staff members of a hospital or clinic be trained on the compliance plan and then annually updated to make sure that they understand the plan’s purpose and their role if they identify or suspect a problem. A key aspect of this training is the anonymous whistleblower hotline. The hospital or clinic must provide a toll-free hotline that any employee can call if he or she suspects that a compliance violation may be taking place. Some pretty interesting calls are made to those hotlines. Some of them lead to correction of a problem before it becomes serious, some of them lead to a provider being disciplined or removed from the staff, and some of them are actually based on misunderstandings that can be corrected. Importantly, no employee can be retaliated against for reporting a problem. That is a crucial aspect of compliance. Employees must feel safe in coming forward and reporting a problem without fear of losing employment or being treated adversely for speaking up. Elements of a Compliance Plan There are seven fundamental elements of an effective compliance program that are presented in your textbook:

BHA 3002, Health Care Management 3

UNIT x STUDY GUIDE

Title

 implementing written policies, procedures, and standards of conduct;

 designating a compliance officer and compliance committee;

 conducting effective training and education;

 developing effective lines of communication;

 conducting internal monitoring and auditing;

 enforcing standards through well-publicized disciplinary guidelines; and

 responding promptly to detected offenses and undertaking corrective action (Safian, 2014). Auditors and accreditation surveyors will be looking for a compliance plan, which should be approved by the board of directors of the facility and updated annually. All seven elements need to be included. Conclusion Perhaps you will have the opportunity to serve on a compliance committee at your own healthcare facility at some point in your career. If this area of health care interests you, perhaps you will seek an opportunity to be appointed compliance officer for a medical organization. Notes Please remember to work steadily on your management action plan (MAP) problem or scenario as you move through the course. Time flies as you are learning more about the fascinating world of medical leadership. Be sure to contact your instructor if you have any questions about the MAP.

References Justice Department lawsuit alleges Scooter Store defrauded Medicare. (2005, April 29). San Antonio

Business Journal. Retrieved from http://www.bizjournals.com/sanantonio/stories/2005/04/25/daily39.html

Neporent, L. (2014, March 7). Judgment day for surgeon who admitted to fake surgeries. Retrieved from

http://abcnews.go.com/Health/judgment-day-surgeon-admitted-fake-surgeries/story?id=22814868 Safian, S. C. (2014). Fundamentals of health care administration. Upper Saddle River, NJ: Pearson.