COMPLIANCE & THE C SUITE

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1 COMPLIANCE & THE C SUITE HCCA S 18 TH ANNUAL COMPLIANCE INSTITUTE MARCH 31 APRIL 2, 2014 SAN DIEGO, CA SESSION HIGHLIGHTS UNDERSTANDING A CEO S EXPECTATION OF COMPLIANCE IN A HIGHLY REGULATED ENVIRONMENT COMMUNICATING COMPLIANCE ISSUES TO THE EXECUTIVE BRANCH IMPLEMENTING COMPLIANCE TO A HOSPITAL S VISION, MISSION & VALUES 1

2 TRANSFORMATION OF HEALTHCARE INCREASEDNUMBER OF REGULATIONS ADAPTATION TO CHANGE IN ORDER TO: PROVIDE HIGHQUALITY SAFECARE MANAGE NEWILLNESSES EMBRACE SCIENCE & TECHNOLOGY DEPENDENCY OF COMPLIANCE PROGRAMS IN THE FACE OF INCREASED ENFORCEMENT CEO S CHIEF OBJECTIVES: TONE AT THE TOP ENSURE BEST QUALITY & SAFESTCARE GIVE THE HOSPITAL ACOMPETITIVE ADVANTAGE SERVICE EXCELLENCE DEVELOPING THE RIGHT ORGANIZATIONAL CULTURE HIRING EMPLOYEES WITH THE BEST CHARACTER & PERSONALITY 2

3 CHARACTER & PERSONALITY CHARACTERISTICS NECESSARY TO ACHIEVESUCCESS AS COMPLIANCE PROFESSIONALS CHARACTER & PERSONALITY ALLOWS COMPLIANCE PROFESSIONALS TO: ADVANCE THE INSTITUTION S MISSION; AND ENGAGE & COLLABORATE WITH EMPLOYEES OF ALL LEVELS CHARACTER & PERSONALITY ALWAYS LOOK TO HELP EMPLOYEES WELCOME OPPORTUNITIES TO BE BETTER ENGAGES EMPLOYEES RALLIES EMPLOYEES ENGAGE IN AN EFFORT TO PROTECT BE BOLD BELIEVE IN YOUR OPINIONS BUILD TRUST 3

4 KNOWLEDGE KNOW YOUR FIELD RESEARCH READ BUILD RELATIONSHIPS KNOW THE IMPACT YOUR RECOMMENDATIONS HAVE DETERMINE OPERATIONAL SOLUTIONS TO KEEP DEPARTMENTS ON THE RIGHT PATH TO SUCCESS KNOWLEDGE COMPLIANCE OFFICERSHAVE AN ENORMOUS RESPONSIBILITY BE THEMORAL BACKBONE OF YOUR ORGANIZATION UNDERSTAND HEALTHCARE TO GUIDE THE ORGANIZATION TOWARDS WHAT IS RIGHT 4

5 KNOWLEDGE IMPROVES RELATIONSHIPS WITH: CHIEFOPERATING OFFICER (COO) CHIEF FINANCIAL OFFICER (CFO) CHIEF MEDICAL OFFICER (CMO) CHIEFNURSING OFFICER (CNO) LEGAL COUNSEL COUNSEL INTERPRETS LAW COMPLIANCE KNOWS THE OPERATIONAL IMPACT DRIVES SUCCESS IN ALL OTHER FACTORS SUCCESSFUL IS DETERMINED BY YOUR ABILITY TO BE EFFECTIVE & TIMELY WITH YOUR MESSAGE RECITATION OF STATUTES WILL NOT ENGAGE IT WILL NOT CONVINCE TELL ASTORY GIVE REAL EXAMPLES FROM YOUR INSTITUTION 5

6 EXECUTIVE & BOARD LEVELREPORTING NO SURPRISES COMMUNICATE WITH PURPOSE KNOW WHAT CEOS NEED TO KNOW IMMEDIATELY KNOW WHAT CAN WAIT KNOW YOUR BOARD UNDERSTAND THEIR FIDUCIARY & JUDICIARY RESPONSIBILITIES COMMUNICATE WITH A CEOS EXECUTIVE TEAM FIRST COMPLIANCE IS PART OF THIS TEAM EXPECTATION OF A CEO THAT THIS TEAM TO MITIGATE ISSUES OF NON COMPLIANCE 6

7 PRIVACY INCIDENTS: NOTIFY CEO KNOW ALL THE FACTS NOTIFY LEGAL, HR & PATIENT RELATIONS DO YOU HAVE A BREACH? EXCLUDED PROVIDER: NOTIFY CEO HAVE A CORRECTIVE ACTION PLAN READY NOTIFY COO, LEGAL, CFO, CMO, CNO & HR DO YOU HAVE A POSITIVE MATCH? 7

8 CMS NOTIFICATION OF OVERPAYMENT: NOTIFY CEO HAVE A CORRECTIVE ACTION PLAN READY INTERNAL INVESTIGATION TO DETERMINE EXPOSURE NOTIFY CFO, CMO & LEGAL MEANINGFUL USE AUDIT: UPDATE WITH CMS FINDINGS NOTIFY YOUR BOARD NOTIFY CEO, COO CFO, & LEGAL ONCE NOTICE OF AUDIT IS RECEIVED 8

9 BOARD REPORTING: QUARTERLY REPORTING AT MINIMUM PROVIDE THEM THE INFORMATION TO HELP THEM MEET THEIR RESPONSIBILITIES EDUCATE PROMINENT COMMUNITY MEMBERS, NOT NECESSARILY WELL VERSED INHEALTH CARE OPERATIONS MOTIVATION OPTIMIZE THE PERFORMANCE OFYOUR DEPARTMENT LEARN THE DIRECTION HEALTHCARE & YOUR ORGANIZATION IS MOVING IN PROVIDE RELEVANT GUIDANCE 9

10 MOTIVATION TRIPLE AIM CURRENT APPROACH TO PROVIDING HEALTH CARE INCREASEDLONGEVITY OF AGING POPULATION CHRONIC HEALTH PROBLEMS NEWDEMANDS MOTIVATION FULFILLING THIS AIMREQUIRES: FOCUS ON INDIVIDUALS & FAMILIES REDESIGN PRIMARY CARE SERVICES & STRUCTURES MANAGE POPULATION HEALTH CREATE ACOST CONTROL PLATFORM; AND SYSTEM INTEGRATION & EXECUTION 10

11 MOTIVATION COMPLIANCE INVOLVEMENT INTRIPLE AIM ACCOUNTABLE CAREORGANIZATIONS BUNDLED PAYMENTS INNOVATIVE FINANCIAL APPROACHES NEWPRIMARYCARE MODELS PATIENT CENTERED HOMES SANCTIONS FOR AVOIDABLE EVENTS INTEGRATION OF INFORMATION TECHNOLOGY MOTIVATION PAY FOR PERFORMANCE FINANCIAL INCENTIVES TO HEALTH CAREENTITLES MEASURED BY: PROCESS MEASURES OUTCOME MEASURES PATIENT EXPERIENCE STRUCTURE MEASURES 11

12 MOTIVATION PATIENT EXPERIENCE & PATIENT SATISFACTION STRIVE TO EXCEEDPATIENT EXPECTATIONS COMPLIANCE OFFICERSSUPPORT PATIENT SATISFACTION ROUND UNIT FLOORS TO: ENGAGE FRONT LINE STAFF EDUCATE FRONT LINE STAFF PERFORM HIPAA SAFEGUARD REVIEWS MOTIVATION PATIENT EXPERIENCE & PATIENT SATISFACTION STRIVE TO EXCEEDPATIENT EXPECTATIONS COMPLIANCE OFFICERSSUPPORT PATIENT SATISFACTION ROUND UNIT FLOORS TO: ENGAGE FRONT LINE STAFF EDUCATE FRONT LINE STAFF PERFORM HIPAA SAFEGUARD REVIEWS 12

13 LEADERSHIP COMPLIANCE OFFICERSMUST BE LEADERS CEOS SET THE TONE OF THE ORGANIZATION CEOS HIRE INDIVIDUALS TO LEAD THEIRDEPARTMENT BE THE CEO OF YOUR DEPARTMENT 13

14 QUESTIONS SPEAKERS FRANK CORVINO PRESIDENT & CEO GREENWICH HOSPITAL; EXECUTIVEVICEPRESIDENT YALE NEW HAVEN HEALTH SYSTEM FAHAD AHMED COMPLIANCE & PRIVACY OFFICER, BRIDGEPORT & GREENWICH HOSPITAL; DIRECTOR COMPLIANCE & PRIVACY, YALE NEW HAVEN HEALTH SYSTEM 14