RJ - Health Care Compliance Association

SPECIAL GROUPInvestigations:issue, you need to adopt a specificmindset. You must be extremely curi-Some ous and extremely open to new information.lessons fromEspecially when issues are pre-small screen detectivessented to you by other humans, sinceBy Glenna S. Jacksonthey tend to be packaged with a pointof view. Your job is to differentiate theEditor’s note: Glenna S. Jackson has been facts from the point of view. The greatVice President of Compliance fordetectives of television can be your roleMedStar Health, Inc. for five years. models.Before joining MedStar, she developed aReimbursement Compliance Program for Columbo: “Could you just help methe Blue Cross and Blue Shieldunderstand how?”Association Federal Employees Program. It is very instructive to know a lotShe can be reached at 202/877-3868. about an issue already and then asksomeone else to explain how it worksAs a Compliance Officer, investigating from their point of view. This approachissues reported to you can be the most may seem disingenuous, but youinteresting, frustrating, dangerous, and inevitably learn something key aboutrewarding part of your job. In general, the operation that you did not knowissues arise in any one of a number of before; or you learn something aboutways: through the hotline, through the person describing the process. Onedirect contact by an employee, as a byproducttechnique that I use is to ask three peo-of reviews, or during the ple the same question. Of course, youcourse of an exit interview.need to ask each one separately–out ofhearing by the others. The differencesTypically, very few issues come through between the answers are fascinating andthe hotline. Compliance Officers report often hold the key to the real problemthat, as they expand their training and and perhaps the solution as well.review activity, employees get to know Callers have their own perspectives on athem and will simply approach them problem. A unit clerk and the departmentwith questions, problems, and potentialmanager may both give highlyissues to investigate. Other issues arise accurate descriptions of the sameduring the course of a review. At process that sound totally different. TheMedStar, we choose to log them in our key to the problem lies right at thetracking system to ensure that we followpoint where the explanations differ. Itup in a timely, organized way, may be a matter of terminology or inaccording to the protocol we’ve developed.understanding how the system works.(See Sidebar1)Investigations: Willing suspension ofdisbeliefIf you determine that the complianceoffice is responsible for investigating anKojak: “Who loves you, baby?”It is also important to put people atease. Most employees want to do agood job; most want the organizationto succeed. Some however, may be wor-H EALTH C ARE S YSTEMried about their own small errors andmissteps. You may even interview anemployee who actually has somethingto hide. The employee may be nervousand evasive, but their discomfort maynot relate to your area of inquiry. Workhard to calm their anxiety about theirown performance, so that it doesn’t getin the way of your learning about thebroader issues.Dragnet: “Just the facts, ma’am”It is important to separate how peoplefeel about an issue and the conclusionsthey leap to from the actual facts of anissue. Comb through the informationyou have and consciously test each itemto determine if you have informationthat is opinion, hearsay, or fact. Lookfor corroborating data. Refrain fromtaking sides in an issue. Complianceofficers owe as much respect to the personor department accused of wrongdoingas they do to the person calling thehotline.Also remember that not everyone isarticulate about the facts as they understandthem. Employees may not understandhow a process works; they mayonly know about their own piece of thesystem. Doctors, for example, are skilledat helping patients describe their symptomsand make observations about theirown health. Compliance officers needthe same skills at drawing out callers tothe hotline about the facts of an issueand the symptoms of the problem inorder to reach an accurate diagnosis.Law & Order: Remember, there isalways a twist.Rarely does a compliance issue resolveContinued on page 16October 200215