JR - Health Care Compliance Association

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CONDUCTING A COMPLIANCE INTERVIEW...continued from page 17 interruption on the chance that the interviewer is not “clicking” with the interviewee intellectually. In such circumstances, letting the interviewee talk offers a greater chance for facts to spill out. While this can make interviewing tedious, the interviewer might obtain facts he or she would never have obtained if the interview was presumptively cut short. 12. Reassure the interviewee that “it’s OK” if he or she doesn’t remember Memories are not perfect. Sometimes a person’s memory needs time to “brew.” A day after the interview a person might recall with great clarity a fact that was completely lost or buried the day before. Encourage interviewees to call the interviewer if there are facts that need correcting or a discovery of a new, relevant fact. Reassure an interviewee at the end of the interview that if he or she remembers anything else, you are available to talk–and assure the person that it is OK if he or she needs to clarify or correct something said during the interview 13. Plan plenty of time for an interview–they are almost always longer than you expect Often times interviews do not go as planned. A new fact is frequently identified or an issue is raised which takes the investigation in an unexpected direction. Within reason, time must be allotted to go where the interview goes. This author’s experience is that an issue that begins an investigation rarely looks the same by the end of the investigation. 14. If interviews identify an important meeting, interview everyone at the meeting Meetings which are at the center of events should be investigated thoroughly, including interviewing everyone at the meeting. You can be sure that the government will investigate a critical meeting thoroughly, and so should you. Even if a person would not seem on the surface to hold any key information, go through the process of interviewing him or her on the events of the meeting. 15. End all interviews by asking the interviewee if there is anything else he or she wants to relay to you or any other compliance he or she wants to talk about If the interviewee answers with an answer of “I don’t know anything else,” then this puts the person on record as having told the interviewer everything he or she knows about a particular issue as well as not knowing of any other compliance problem. This is important not only to be sure that nothing else is lurking which the interviewer should know about but if there is something which is later revealed that the interviewee knew but did not disclose, then compliance personnel are insulated from accusations of lack of thoroughness or cover-up. Of course it is not uncommon for an interviewee to supply the interviewer with another wholly different compliance issue. ■ FOR CA and LA County to pay $73 million to U.S. for overbilling Medicaid program On June 20, the U.S. Department of Justice announced that the State of California and the County of Los Angles will pay the federal government $73.3 million to settle allegations that they violated the False Claims Act with August 2002 18 YOUR INFO respect to claims submitted to Medicaid. This settlement resolves allegations that the state and the county directly or indirectly billed the federal health care program for services provided to certain minors when these jurisdictions had no basis for concluding that these individuals financially qualified for Medicaid services. The services included drug and alcohol abuse, pregnancy and pregnancyrelated services, family planning, sexual assault treatment, sexually transmitted diseases, and mental health services. The Whistleblower, Singh Khalsa, an employee of the LA Department of Mental Health, will receive approximately $1.36 million of the total recovery as his statutory award. For more; http://www.usdoj.gov/opa/pr/2002/June/ 02_civ_364.htm ■
leagues. Physicians can hear the message from Physicians. CEO’s hear from CEO’s. The HCCA 2003 Compliance Institute, New Orleans, April 27-30 ROY SNELL A melting pot of compliance intellectual capital The Compliance Institute is completely geared to the needs of the Compliance Professional. It is a comprehensive program offering the latest information for all levels of experience. We are currently developing the program for the April 27-30 CI 2003, New Orleans, LA–Keeping that in mind I’d like you to answer the following questions: ■ Are you having trouble justifying your budget? ■ Is your Compliance Program stalled out or moving forward too slowly? ■ Do you hear? “I am too busy to do compliance.”? ■ Do you have someone in your organization that needs to be more committed? ■ Is there someone who needs a better understanding of compliance? ■ Are you having trouble getting your colleagues to commit the time and energy? “Yes” If you have answered “yes” to any of the above questions–and I expect that most of you have–please consider bringing a colleague to the Compliance Institute. Compliance requires all employees of the organization to pull in the same direction–and we all know how challenging that can be. However, Compliance Professionals have been pulling this off for years. Compliance professionals who have brought a colleague to one of our Compliance Institute meetings have left with an individual who has a new appreciation and commitment to compliance. Compliance Institute Getting and keeping your organization’s leadership on board with the Compliance Program is vital to the success of your organization’s program. When leadership and Board members attend the Compliance Institute, they have a better understanding of budget requests. Speakers from the enforcement community share future objectives. Department heads learn from their col- Your colleagues will leave with a renewed commitment. They gain a greater understanding and appreciation through hearing the message from their peers, the enforcement community, and others. This helps to motivate them to commit the time, resources, and energy necessary to move their piece of the organizations compliance program forward. This is all possible because the Compliance Institute facilitates a sharing of ideas between health care professionals. Speakers from all walks of health care (see pp. 20/21) share ideas in general sessions, breakout sessions, panels, networking sessions, preconference workshops, and post-conference workshops. Cross functional and cross industry compliance melting pot The Compliance Institute is a melting pot of compliance professionals. Health care executives from all segments of the industry benefit from this comprehensive and instructive program. The Compliance Institute brings us all together to learn from each other and strives to address the compliance concerns of the health care industry–as opposed to exclusive conferences where people from all one segment of health care meet. The Health Care Compliance Association does this because compliance does not operate in a vacuum; we interact with many parts of the organization. The Compliance Institute facilitates interaction between departments just as we do in our organization. At the HCCA Compliance Institute lawyers learn from consultants, who learn from compliance officers, who learn from educators, who learn from the enforcement community and visa versa. The following is a list of individuals that have attended past HCCA meetings and have left with a renewed understanding and appreciation for their role in moving the organizations compliance program forward. Compliance Professionals ■ Auditors ■ Coders ■ Educators ■ Internal Investigators ■ Billers ■ Medical Records Continued on page 20 19 August 2002
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JR - Health Care Compliance Association

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