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Meet Rita A. Scichilone ...continued from page 15 bring to the workplace with employees of the organization How about with management and the governing authority of the organization CG: My supervisors have expressed appreciation for my CHC certification. They have confidence that when I say to them that we need to develop a new compliance tool or add something to our quality checklists, I have a good reason. My supervisor told me that although the Mental Health Board has always been concerned about compliance, prior to my joining the organization no one had this level of certification. He and the executive director have been supportive as we develop our compliance program. The MHB Board of Directors attends training sessions on compliance during the national conferences they attend. They, too, are supportive, and recently they approved a new compliance position to enhance our program. GI: Would you recommend that your fellow compliance professionals seek CHC certification If so, why What did you do to become eligible for the CHC, and how did you prepare for the certification exam CG: I would certainly recommend that compliance professionals seek the CHC. As the government sends out more auditing groups, certification is going to become increasingly important, because CHC provides a comprehensive base for learning about compliance. Additionally, certification boosts credibility, not only for compliance professionals, but also for the organizations that employ them. To be eligible for certification, a person must be an active compliance professional and meet the guidelines presented in the CHC handbook. Before deciding to work for certification, I became quite familiar with the HCCA website. The more familiar I became with the information on the website, the more I realized the value of CHC. The certification exam was quite extensive. Before the test, I read everything available on the HCCA website; I scoured the Internet for information on compliance; I looked at federal OIG guidelines on health care compliance; and I brushed up on HIPAA information. I attended the academy the week before the test. Those attending the academy attended classes during the day, and continued to review and read the material on our own into the evenings. On the day before the test, we finished at noon and continued to study through the evening. When you sit through that exam, and then finally learn that you have passed it, you can be proud. When I got that letter informing me that I passed the exam and earned certification, I was happy, proud, and relieved. GI: Please tell us how compliance and quality are managed in your organization, since you are the Compliance and Quality Assurance Manager for McHenry County Mental Health Board. CG: At the Mental Health Board, we have a strong Leadership Team that meets bi-weekly. During these meetings, we discuss risk issues, compliance issues, and set a course of action to resolve any problems that we have. If specific issues arise that require immediate action, those in the need to know are informed of the problem. Decisions are made and acted upon by the Leadership Team, which monitors the situation to ensure that the problem gets resolved. Staff members come to me, as the compliance officer, with questions and concerns, and I confer with the deputy director, executive director, or legal counsel as needed for resolution. In addition, as the compliance officer, I do have access to the board of directors, and the executive director reports to the board on a monthly basis. The McHenry County Mental Health Board is unique in that we provide coordination and access to services; we also fund agencies to provide treatment services. This means that we not only have to ensure that we are in compliance with all funding requirements, but we also have to be sure that our funded agencies comply with federal, state, and county funding requirements, including coordination of benefits. As Compliance Officer, I conduct internal as well as external audits. As a funder, the Mental Health Board has an obligation to the constituents of the county to ensure that quality services are provided. GI: Do you believe the quality of health care in an organization is a compliance issue CG: I absolutely believe that quality of health care is a compliance issue. When I conduct audits of providers, I am very aware of the types of services provided, and the quality of care that is extended to the populations that are served. Many of our organizations utilize an outside firm to collect discharge satisfaction data, and when we receive a call that someone is dissatisfied, that information is followed up on immediately. I also receive calls from individuals who are unhappy with services they are receiving from providers. These complaints are documented and followed up on, and if need be, we bring the client and the team together to resolve the problem. GI: What advice would you give to someone just starting out as a compliance professional and setting up a compliance program CG: The first bit of advice I would offer is to ask questions. Reach out to other compliance professionals in the specific field and seek their input. Know that one person does not have to reinvent the wheel. Others have developed policies and procedures, compliance programs, and risk management plans. Read as much information as possible October 2008 16 Health Care Compliance Association • 888-580-8373 • www.hcca-info.org
and get linked up with e-newsletters and the federal OIG Public Affairs updates. Reading industry journals is critical. Another very important piece of advice is to maintain a sense of humor. Things come up; people make mistakes; and sometimes, it all happens at once. Take a deep breath and move on. GI: Having an “effective” compliance program is critical for health care organizations. How would you define compliance effectiveness CG: An effective compliance program starts at the top. It acknowledges that events will occur, corrective action will take place, and both will be reported immediately as required. The compliance process requires careful and complete documentation every step of the way. GI: What do you feel have been major challenges for the health care compliance industry What do you believe will be the challenges for the future CG: The most recent challenges have included the new auditing bodies coming out of the federal government – ZPICs [Zone Program Integrity Contractors], RACs [Recovery Audit Contractors], MIPs [Medicaid Integrity Progam contractors], and the lack of communication between the federal auditors and state programs. I don’t see things changing in the foreseeable future in this area. I do believe that more states will follow New York and Texas and develop state OIG programs. The biggest challenges for the behavioral health care compliance industry – and the biggest vulnerabilities – are in documentation. About a year ago, the State of Illinois made significant changes in Illinois Medicaid Rule 132, and recently it made more changes. Health care workers are not confident that they are capturing everything that is required in their case notes. Behavioral health care bills Medicaid using medical codes. Practicing the science of physical medicine is much more exact than working in behavioral health care. An x-ray verifies a broken arm, and a cast is part of the treatment. Healing generally takes place within a period of six weeks. Diagnosis and treatment of behavior health issues is much less black-and-white. It is much more difficult to define in medical terms the need to teach someone to balance a checkbook or to maneuver in a grocery store while hearing voices in their heads. Documentation is crucial. Treatments can be quite varied, and all treatments need to clearly relate to the diagnosis. Behavioral health care professionals not only need specialized training in their field, they also need continued training in meeting compliance requirements. Providers in McHenry County are committed to quality and collaboration. For example, they recently committed to working with an independent national consultant hired by the Mental Health Board to receive additional training in federal and state compliance regulations. GI: What tools does the McHenry County Mental Health Board have in place to help with compliance issues CG: Our compliance program includes open discussion of ethical dilemmas, questions, and concerns at monthly staff meetings, or if an employee prefers, privately with a supervisor. Difficult questions are encouraged. We strive for an environment in which people feel comfortable coming forth with their concerns. We have worked to create trust between coworkers. Additionally, we provide regular compliance training during these monthly meetings, and we offer access to Webinars and teleconferences as they become available. GI: How do you capture staff support for compliance CG: By creating an environment of trust. At the MHB, starting with the board of directors on down, issues of compliance are taken very seriously. Our leadership team is dedicated to an effective compliance plan that includes an open door to communication. We send out ongoing e-mail alerts that offer new information. We focus on doing the right thing rather then centering attention on what is wrong. We work hard to incorporate compliance in a manner in which people are not threatened, fostering an environment of openness. GI: Is the board of directors trained in issues of compliance CG: We have developed training for the MHB Board of Directors as well as for the boards of our funded agencies. They attend conferences that offer a wealth of information and opportunities to network with people across the country. Members of our board of directors participate in our compliance committees, which include an ethics committee and a finance committee. n Contact Us! www.hcca-info.org info@hcca-info.org Fax: 952/988-0146 HCCA 6500 Barrie Road, Suite 250 Minneapolis, MN 55435 Phone: 888/580-8373 To learn how to place an advertisment in Compliance Today, contact Margaret Dragon: e-mail: margaret.dragon@hcca-info.org phone: 781/593-4924 Health Care Compliance Association • 888-580-8373 • www.hcca-info.org 17 October 2008
Page 1 and 2: Volume Ten Number Ten October 2008
Page 3 and 4: INSIDE Publisher: Health Care Compl
Page 5 and 6: which ensures that the understandin
Page 7 and 8: Table 1: 14 CLAS Standards U.S. Dep
Page 9 and 10: Scholarship Recipients The Four Dua
Page 11 and 12: and need emergency care (e.g., an i
Page 13 and 14: Court analyzes first case under Sta
Page 15: It was established in 1969 in respo
Page 19 and 20: Social networking Many compliance p
Page 21 and 22: Focus on Organizational Compliance
Page 23 and 24: Medicare’s medical necessity crit
Page 25 and 26: Is no notice enough notice Legal pr
Page 27 and 28: Exploring the question: Does this r
Page 29 and 30: “Does this really make a complian
Page 31 and 32: Certification - the recognized mark
Page 33 and 34: suffice. This potential error can b
Page 35 and 36: Introducing Compliance & Ethics Soc
Page 37 and 38: who typically sell multiple plans o
Page 39 and 40: n State OIG that fight Medicaid fra
Page 41 and 42: Coordinating external requests for
Page 43 and 44: The what, why and how of Medicare C
Page 45 and 46: The what, why and how of Medicare C
Page 47 and 48: to hear the message first. Educatin
Page 49 and 50: COMPLIANCE ACADEMIES February 2-5 S
Page 51 and 52: or whistleblower lawsuit. Moreover,
Page 53 and 54: SEC Disclosure: Managing informatio
Page 55 and 56: Upcoming Regional Conferences Octob
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PHI under false pretenses, that per
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Improving competitiveness and compl
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Speakers Sharon Anolik Blue Cross B
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commitment to overhaul deficient co
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e g i s t e r n o w f o r HCCA’s
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New principles can help advance ind
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New principles can help advance ind
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When to use a monitor Although some
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ASKLEADERSHIP John asks the leaders
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Enforcement actions in health care
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Corruption enforcement actions targ
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“I am a compliance professional a
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n M. Michelle Walker, LifePoint Hos
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600 U.S. BANK PLAZA SOUTH 220 SOUTH
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