BP - Health Care Compliance Association

Meet Bill Parke ...continued from page 15
pesticides can get you into an awful lot of
difficulty, too. In an increasingly complex
regulatory environment, the Compliance discipline
we have honed over the years with its
metrics of clear standards – responsible leadership,
adequate training, internal controls,
reporting mechanisms, and corrective action
– are applicable across the entire enterprise.
Our philosophy is to make our compliance
program a resource for helping stakeholders
manage regulatory risk wherever it is found
– from EMTALA to disaster preparedness,
from HIPAA to wage and hour laws.
That doesn’t mean we “own” those operational
processes, only that we assist those
who do own them to manage them in a more
consistent manner. For example, in the last
couple years we found ourselves assisting in
matters related to governance. Specifically,
we helped our board incorporate certain
elements of Sarbanes Oxley into their committee
processes and we also helped establish
a rebuttable presumption process to protect
against excess benefit transactions. This year
we’ll be keeping up with the work being
done to comply with the new IRS Form 990
reporting requirements and, relatedly, assisting
in the refinement of the processes for the
gathering and compiling of information that
will be incorporated into our Community
Benefit program. Our assistance is pretty
much always the same, no matter what regulation
is at issue. We go back to those basic
compliance metrics and try to apply them
through the same model.
Personally, I think that Compliance will
soon become so common an expectation that
it will become essentially ubiquitous in all areas
of operations. I can envision a time when we
will no longer have discussions about what
operational process is – and what operational
process is not – included in “Compliance.”
The real discussion will be (1) What’s the
regulation? (2) How do we ensure an on-going
compliant process that meets the regulation?
and (3) How do we prove it? Much like Performance
Improvement, I think that Compliance
will ultimately be a built-in expectation.
GW: What areas of your compliance
responsibilities do you find particularly challenging
and/or rewarding?
BP: I see several emerging issues on the
horizon that are going to be challenging. I
am just now starting to sort through how to
identify my role in ensuring the integrity of
the data that RHI collects and presents to
others. In this day of reimbursements that
are linked to performance outcomes, etc.,
just how far down in the weeds should a
compliance officer go to validate the accuracy
of data being reported and to ensure that no
one has “tinkered” with it?
I also think that we’ll need to revisit data
privacy and security again soon. The electronic
world that we now live in is far different
from that of even 5 years ago. Because
potable devices and the Internet are now
pervasive everywhere in our lives (and perhaps
because we are now hiring a generation
of workers who literally grew up with them),
it is my perception that we have grown far
too casual in the use of emerging technologies.
Staff are going to need renewed privacy
and security training that has been updated
to the paradigm of smart phones, picture
phones, instant messaging, social networking,
etc. I find it inexplicable that the same staff
who would never share sensitive information
in the course of their job duties are having a
hard time seeing why it’s a problem putting
that same sensitive information on MySpace.
Likewise, our IT departments are going to
need a lot of support in painting bright–lines
as they move towards the goal of an interoperable
health record. I serve on a work group in
western North Carolina that is helping with
the development of a RHIO [Regional Health
Information Organization]. The potential
benefits are amazing, but ensuring that proper
internal controls are effectively deployed to keep
up with the rapid evolution of connectivity and
data-sharing regionally is a unique challenge.
But by far, the place where I find myself
spending the most time recently is in the area
of contracts. Like the rest of the country, our
area is experiencing a realignment of hospital
and local medical community. Through
employment and/or acquisition, RHI has
been changing the nature of our relationships
with several physicians/physician practices.
That has meant a lot of work to ensure that
every process step along the way was compliant.
Whether that step involved business
valuation, facility appraisal, pro forma development,
compensation modeling, or crafting
purchase or employment agreements, we had
a great deal of due diligence to complete.
GW: In your role as a mentor, what advice
would you give to a junior associate who is
interested in Compliance?
BP: As I said, I was fortunate to be
allowed to hire a Compliance Assistant this
year. Although she has health care experience,
none of it is in the compliance field. As we
talked about her interest in the position, I
gave her some things to think about as she
considered whether or not she wanted to
jump into Compliance as a career. First, be
patient and take it one piece at a time. There
is no way that anyone can absorb all there
is to know about health care compliance
without spending a good amount of time
in the field working and studying. No one
has it all under their belt – that is why peer
relationships are so important.
Second (and this may reflect my own
experiential bias), be willing to get out of the
office, walk around, and be visible. Get to
know health care operations whenever and
wherever you can; spend time in peoples’
work environment to get a better understanding
of what they are really dealing with.
Be curious and don’t be afraid to ask ques-
March 2009
16
Health Care Compliance Association • 888-580-8373 • www.hcca-info.org