From the September 2017 issue of HealthCare Business News magazine
• The organization does not believe it will ever be investigated for noncompliant actions.
Try to understand the origin of this argument and confront it. Numerous case studies reveal stories of hospitals and health care organizations that thought they would never be investigated. Present these case studies in a factual manner so that the audience can understand the risk. Remind them of the possibility of whistleblowers and how an effective compliance program mitigates the risk. Historical observation has shown that, at times, those who push the “it can’t happen here” rhetoric may actually stand to gain from an investigation. This could include work being generated for outside consultants or outside counsel. Determine if there are any potential conflicts of interests associated with your decision-makers that could taint their support of your compliance program. This can be accomplished via a thorough conflict-of-interest disclosure process.
• The organization believes it can defend against claims of noncompliance.
Defending yourself is expensive. Lawyers and compliance consultants are just the beginning of the costs. A negative public image could be even more expensive. Common sense says it's cheaper to mitigate the risk of noncompliance, rather than defend yourself after the fact.
• Management decides that it must cut compliance resources to protect the organization’s financial health.
This is a shortsighted strategy. Cutting aspects of the compliance program (staff, technology, consultants) tells a future investigator or whistleblower that the organization knew the risk, as demonstrated by previous expenditures for the compliance program, but were not committed to the same level of compliance in the future.
Health care organizations have one of the most complicated business models ever created. Hospitals are difficult to organize and manage in the best of situations, but even more so under the stringent financial pressures they currently face. However, a critical component of the long-term viability of these organizations is a proactive compliance program that is appropriately supported with the proper resources. Demonstrate and “sell” to the C-suite and executive team that compliance is an investment and not an expense. When you invest in a strong compliance program, you are helping protect the long-term health of our organizations and communities.
About the author: Rebekah Sharpe joined MediTract in 2000 and is vice president of operations.
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