Pointers And Pitfalls In Gaining Physician Buy-In To A Compliance

Program

Pointers And Pitfalls In Gaining Physician Buy-In To A Compliance

Program

Robert H. Ossoff, D.M.D, M.D.

Assistant Vice Chancellor for Complianceand Corporate Integrity

Vanderbilt University Medical CenterNashville, TN

2009 THA Fall Compliance Conference

October 21, 2009

Robert H. Ossoff, D.M.D, M.D.

Assistant Vice Chancellor for Complianceand Corporate Integrity

Vanderbilt University Medical CenterNashville, TN

2009 THA Fall Compliance Conference

October 21, 2009

Pointers And Pitfalls In Gaining Physician Buy-In To A Compliance

Program

Pointers And Pitfalls In Gaining Physician Buy-In To A Compliance

Program

Interacting with physicians

Building physician - compliance office relationships

Utilizing and leveraging relationships developed with physician champions

Interacting with physicians

Building physician - compliance office relationships

Utilizing and leveraging relationships developed with physician champions

Objectives

Interacting With Physicians

Interacting With Physicians

Know your audience Know their focus

Know their compliance risk

Know their characteristics

Know your audience Know their focus

Know their compliance risk

Know their characteristics

Interacting With PhysiciansInteracting With Physicians

Know your audience What is their main focus?

Patient Care and patient safety

What is their compliance risk? Documentation problems

– Billing for services• Not Documented

• Poorly Documented

– Up-coding and/or down-coding

– Risk management issues

– Incorrect reimbursement issues

– Increased cost to correct mistakes

Know your audience What is their main focus?

Patient Care and patient safety

What is their compliance risk? Documentation problems

– Billing for services• Not Documented

• Poorly Documented

– Up-coding and/or down-coding

– Risk management issues

– Incorrect reimbursement issues

– Increased cost to correct mistakes

Interacting With PhysiciansInteracting With Physicians

General characteristics Usually competitive in nature

Like to be the best or a leader in their field

Compete with their peers as well as themselves– High school to college

– College to medical school

– Medical school to residency and fellowship

– Residency and fellowship to private or academic practice

Like challenges

Desire perfection

Want to be correct

General characteristics Usually competitive in nature

Like to be the best or a leader in their field

Compete with their peers as well as themselves– High school to college

– College to medical school

– Medical school to residency and fellowship

– Residency and fellowship to private or academic practice

Like challenges

Desire perfection

Want to be correct

Interacting With PhysiciansInteracting With Physicians

General characteristics

Interested in processes that

Improve quality of patient care

Improve productivity

Improve patient satisfaction

Improve efficiency

Improve reimbursement and cut cost

General characteristics

Interested in processes that

Improve quality of patient care

Improve productivity

Improve patient satisfaction

Improve efficiency

Improve reimbursement and cut cost

Interacting With PhysiciansInteracting With Physicians

General characteristics Education

Highly educated in their field and/or specialty

Usually interested in advancing their understanding of the healthcare industry– Specifically interested in understanding outside factors

that may impact them

Personality All walks of life but share common traits such as:

– Want to do the right thing

– Analytical thinkers

– Usually collaborative

– Research, science and fact based oriented

– Entrepreneurial

General characteristics Education

Highly educated in their field and/or specialty

Usually interested in advancing their understanding of the healthcare industry– Specifically interested in understanding outside factors

that may impact them

Personality All walks of life but share common traits such as:

– Want to do the right thing

– Analytical thinkers

– Usually collaborative

– Research, science and fact based oriented

– Entrepreneurial

Interacting With PhysiciansInteracting With Physicians

Capitalize on their general characteristics

Competitive by nature

Provide data when discussing compliance concerns that compare them to their peers, locally, regionally, and nationally, if possible

Be mindful of their time

– Just the facts

Capitalize on their general characteristics

Competitive by nature

Provide data when discussing compliance concerns that compare them to their peers, locally, regionally, and nationally, if possible

Be mindful of their time

– Just the facts

Pointers – Building Bridges

Interacting With PhysiciansInteracting With Physicians

Capitalize on their general characteristics

Appeal to their interests

– Demonstrate how documentation can

• Improve the quality of care and decrease safety risks

• Improve overall productivity and efficiency

• Improve patient satisfaction

• Improve reimbursement and cut cost

Capitalize on their general characteristics

Appeal to their interests

– Demonstrate how documentation can

• Improve the quality of care and decrease safety risks

• Improve overall productivity and efficiency

• Improve patient satisfaction

• Improve reimbursement and cut cost

Pointers – Building Bridges

Interacting With PhysiciansInteracting With Physicians

Capitalize on their general characteristics Education

Provide examples relative to their specialty

Provide data from their specialty organization

Explain how this helps them to be in the top of their profession and how compliance impacts their specialty

Personality

Ask for their input on how to better improve compliance

Provide facts about what needs to be improved and why

Explain why this is the right thing to do

Capitalize on their general characteristics Education

Provide examples relative to their specialty

Provide data from their specialty organization

Explain how this helps them to be in the top of their profession and how compliance impacts their specialty

Personality

Ask for their input on how to better improve compliance

Provide facts about what needs to be improved and why

Explain why this is the right thing to do

Pointers – Building Bridges

Interacting With PhysiciansInteracting With Physicians

Conversation starters Dr. X, the Compliance Office has identified

an opportunity you can use to

Improve patient care and patient satisfaction

Reduce risk to patient safety

Ensure your documentation can be utilized more efficiently by yourself and other practitioners

Ensure your documentation reflects the excellent care you provide to your patients

Conversation starters Dr. X, the Compliance Office has identified

an opportunity you can use to

Improve patient care and patient satisfaction

Reduce risk to patient safety

Ensure your documentation can be utilized more efficiently by yourself and other practitioners

Ensure your documentation reflects the excellent care you provide to your patients

Pointers-Building Bridges

Interacting With PhysiciansInteracting With Physicians

Generally, don’t start off conversations with In accordance with the law you

must ....

The OIG said….

CMS Billing Manual citation….

Penalties under the False Claim Act are….

Generally, don’t start off conversations with In accordance with the law you

must ....

The OIG said….

CMS Billing Manual citation….

Penalties under the False Claim Act are….

Pitfalls – Instant Bridge Burners

Interacting With PhysiciansInteracting With Physicians

While these are great ways for Compliance Professionals to discuss compliance issues, physicians may be thinking

Here we go again, non physicians telling me how to practice medicine

This person doesn’t care about the patient

Great, more work for me to do because some clipboard-carrying administrator or blue-suit behind a desk feels my job isn’t difficult enough already

Who are you in Compliance to tell me how to run my practice

While these are great ways for Compliance Professionals to discuss compliance issues, physicians may be thinking

Here we go again, non physicians telling me how to practice medicine

This person doesn’t care about the patient

Great, more work for me to do because some clipboard-carrying administrator or blue-suit behind a desk feels my job isn’t difficult enough already

Who are you in Compliance to tell me how to run my practice

Pitfalls – Instant Bridge Burners

Interacting With PhysiciansInteracting With Physicians

Appeal to their interests to improve patient care

Appeal to their competitive nature Understand how to phrase and tailor your

discussions and educational efforts with physicians so that each encounter is as effective and efficient as possible

Remember, the goal of most physicians is “the patient comes first” so try to work compliance into their daily patient care routine

Above all, most physicians want to do the right thing!!!!

Appeal to their interests to improve patient care

Appeal to their competitive nature Understand how to phrase and tailor your

discussions and educational efforts with physicians so that each encounter is as effective and efficient as possible

Remember, the goal of most physicians is “the patient comes first” so try to work compliance into their daily patient care routine

Above all, most physicians want to do the right thing!!!!

Summary

Building Physician - Compliance Office

Relationships

Building Physician - Compliance Office

Relationships

Politics

Developing physician champions

Who, what, where, when, why and how

Theory to implementation

Vanderbilt approach

Politics

Developing physician champions

Who, what, where, when, why and how

Theory to implementation

Vanderbilt approach

Building Physician - Compliance Office

Relationships

Building Physician - Compliance Office

Relationships

Politics do play a role You need buy-in from the top

CEO, CFO, COO

– These individuals have a significant, vested interest in compliance. It is these individuals with whom you discuss increased efficiency, decreased risk of penalties, fines, and so forth

– If these individuals are on board with the compliance program, it should make it easier to get physician buy-in and involvement

– These individuals may be able to help encourage physician interaction with the Compliance Office

Politics do play a role You need buy-in from the top

CEO, CFO, COO

– These individuals have a significant, vested interest in compliance. It is these individuals with whom you discuss increased efficiency, decreased risk of penalties, fines, and so forth

– If these individuals are on board with the compliance program, it should make it easier to get physician buy-in and involvement

– These individuals may be able to help encourage physician interaction with the Compliance Office

Building Physician - Compliance Office

Relationships

Building Physician - Compliance Office

Relationships

Develop your Physician Champions Where to start?

Respected physicians you know may be sympathetic to the goals and objectives of the Compliance Office

Grass roots approach– Which physicians are already involved in compliance-

related areas• Risk management

• Quality measures

• Patient safety

• CMO and COS

• Accreditation and Joint Commission

• Physicians with prior experience of an OIG investigation or a CIA

• Other

Develop your Physician Champions Where to start?

Respected physicians you know may be sympathetic to the goals and objectives of the Compliance Office

Grass roots approach– Which physicians are already involved in compliance-

related areas• Risk management

• Quality measures

• Patient safety

• CMO and COS

• Accreditation and Joint Commission

• Physicians with prior experience of an OIG investigation or a CIA

• Other

Building Physician - Compliance Office

Relationships

Building Physician - Compliance Office

Relationships

What will the Physician Champions do once the relationship is developed?

They are eyes and ears among their physician colleagues

Report on areas of concern from a physician’s point of view

They serve as advocates for the Compliance Office They may be the ones to carry the “compliance torch” among

their peers

Most importantly, they are your liaison between the medical staff and the Compliance Office and can be instrumental in advocating for change within an organization

Assist with breaking down the us vs. them mentality

Encourage reporting of violations and suspected violations

Influence physician participation in educational programs

What will the Physician Champions do once the relationship is developed?

They are eyes and ears among their physician colleagues

Report on areas of concern from a physician’s point of view

They serve as advocates for the Compliance Office They may be the ones to carry the “compliance torch” among

their peers

Most importantly, they are your liaison between the medical staff and the Compliance Office and can be instrumental in advocating for change within an organization

Assist with breaking down the us vs. them mentality

Encourage reporting of violations and suspected violations

Influence physician participation in educational programs

Building Physician - Compliance Office

Relationships

Building Physician - Compliance Office

Relationships

Theory to implementation - Vanderbilt approach

Several years ago implemented a program involving physicians to advocate for compliance

Designated Coding Experts (DCE) and Designated Coding Advocates (DCA)

– Compliance liaisons for faculty physicians and Compliance Office

– Meet monthly to discuss changes related to coding, compliance, proposed regulatory changes and changes to the healthcare industry in general

– Representatives from all specialties are involved

– Supported by leadership (CEO, COO, CFO)

Theory to implementation - Vanderbilt approach

Several years ago implemented a program involving physicians to advocate for compliance

Designated Coding Experts (DCE) and Designated Coding Advocates (DCA)

– Compliance liaisons for faculty physicians and Compliance Office

– Meet monthly to discuss changes related to coding, compliance, proposed regulatory changes and changes to the healthcare industry in general

– Representatives from all specialties are involved

– Supported by leadership (CEO, COO, CFO)

Building Physician - Compliance Office

Relationships

Building Physician - Compliance Office

Relationships

Politics Get buy-in from the top

Learn the landscape and develop your Physician Champions

Implement a program with your Physician Champions that works for your organization

Remember these Physician Champions are your greatest advocates to facilitate delivery of your compliance message to the medical staff throughout your organization

Politics Get buy-in from the top

Learn the landscape and develop your Physician Champions

Implement a program with your Physician Champions that works for your organization

Remember these Physician Champions are your greatest advocates to facilitate delivery of your compliance message to the medical staff throughout your organization

Pointers

Building Physician - Compliance Office

Relationships

Building Physician - Compliance Office

Relationships

Politics Buy-in can not come by compromising on ethics

or integrity Result in less than favorable participation from

your Physician Champions

Devalue your program and set you up for failure

Failure to know your audience is a disaster waiting to happen

Not all models work for every organization Monitor the compliance message your

Physician Champions are communicating to the medical staff

Politics Buy-in can not come by compromising on ethics

or integrity Result in less than favorable participation from

your Physician Champions

Devalue your program and set you up for failure

Failure to know your audience is a disaster waiting to happen

Not all models work for every organization Monitor the compliance message your

Physician Champions are communicating to the medical staff

Pitfalls

Building Physician - Compliance Office

Relationships

Building Physician - Compliance Office

Relationships

Buy-in is critical

Have to understand your corporate culture to select and develop your Physician Champions

Build something that works for your organization

Be sure to communicate and monitor the compliance message being delivered by your Physician Champions

Buy-in is critical

Have to understand your corporate culture to select and develop your Physician Champions

Build something that works for your organization

Be sure to communicate and monitor the compliance message being delivered by your Physician Champions

Summary

Utilizing And Leveraging Relationships With Your

Physician Champions

Utilizing And Leveraging Relationships With Your

Physician Champions

How can the Compliance Office help the Physician Champions?

Think macro and micro

DCE and DCA - Vanderbilt’s approach

Make it work for your Physician Champions and you

Think win-win

How can the Compliance Office help the Physician Champions?

Think macro and micro

DCE and DCA - Vanderbilt’s approach

Make it work for your Physician Champions and you

Think win-win

Utilizing And Leveraging Relationships With Your

Physician Champions

Utilizing And Leveraging Relationships With Your

Physician Champions

How can the Compliance Office help the Physician Champions? These Physician Champions will

receive questions from their peers so it is critical that they understand some basic high level compliance issues

Macro level – be their advisor Physician Champions will need

assistance from the Compliance Office

How can the Compliance Office help the Physician Champions? These Physician Champions will

receive questions from their peers so it is critical that they understand some basic high level compliance issues

Macro level – be their advisor Physician Champions will need

assistance from the Compliance Office

Utilizing And Leveraging Relationships With

Your Physician Champions

Utilizing And Leveraging Relationships With

Your Physician Champions

How can the Compliance Office help the Physician Champions? Physician champions will need

assistance from the Compliance Office

• Understand the Compliance Program Plan

– Why we have one in place and how it impacts the daily lives of their physician colleagues

– Conflict of interest

– Fraud and abuse laws (Anti-kickback, False Claims, and Stark)

How can the Compliance Office help the Physician Champions? Physician champions will need

assistance from the Compliance Office

• Understand the Compliance Program Plan

– Why we have one in place and how it impacts the daily lives of their physician colleagues

– Conflict of interest

– Fraud and abuse laws (Anti-kickback, False Claims, and Stark)

Utilizing And Leveraging Relationships With

Your Physician Champions

Utilizing And Leveraging Relationships With

Your Physician Champions

How can the Compliance Office help the Physician Champions?

Physician Champions will need assistance from the Compliance Office

– Major changes within CMS (FI and Carrier change to MAC, PSC to ZPIC, RACs and MICs)

• Understanding the acronyms, alone, may be overwhelming!!!

• Major proposals such as the elimination consultation codes and how this will impact their organization and practice

How can the Compliance Office help the Physician Champions?

Physician Champions will need assistance from the Compliance Office

– Major changes within CMS (FI and Carrier change to MAC, PSC to ZPIC, RACs and MICs)

• Understanding the acronyms, alone, may be overwhelming!!!

• Major proposals such as the elimination consultation codes and how this will impact their organization and practice

Utilizing And Leveraging Relationships With

Your Physician Champions

Utilizing And Leveraging Relationships With

Your Physician Champions

How can the Compliance Office help the Physician Champions?

Macro level – be their advisor Assist with annual compliance

training

– Helps with both clinical and non-clinical staff to see that the Compliance Office is utilizing physicians to assist and provide guidance with training

How can the Compliance Office help the Physician Champions?

Macro level – be their advisor Assist with annual compliance

training

– Helps with both clinical and non-clinical staff to see that the Compliance Office is utilizing physicians to assist and provide guidance with training

Utilizing And Leveraging Relationships With Your Physician

Champions

Utilizing And Leveraging Relationships With Your Physician

Champions

Micro level – be their consultant Individual physician audits

Utilize your Physician Champions to help explain audit findings

– Less intimidating for the audited physician

– Helps transform the audit into a collaborative approach to address the findings, mitigate the risks, and improve patient care

Specialty compliance training

Training is provided by someone in the specialty practice

– Peer to peer training

Provide real-world insightful examples and commentary on why compliance is necessary within the specialty

Micro level – be their consultant Individual physician audits

Utilize your Physician Champions to help explain audit findings

– Less intimidating for the audited physician

– Helps transform the audit into a collaborative approach to address the findings, mitigate the risks, and improve patient care

Specialty compliance training

Training is provided by someone in the specialty practice

– Peer to peer training

Provide real-world insightful examples and commentary on why compliance is necessary within the specialty

Utilizing And Leveraging Relationships With Your

Physician Champions

Utilizing And Leveraging Relationships With Your

Physician Champions

Micro level – be their consultant Billing, coding, documentation and

operational issues The Physician Champions encounter the

same issues all physician’s encounter so they can provide assistance with resolving these issues as they arise

Leverage their “referral” behavior and training

The Physician Champions can “refer” their peers to the Compliance Office to assist with questions or concerns

Micro level – be their consultant Billing, coding, documentation and

operational issues The Physician Champions encounter the

same issues all physician’s encounter so they can provide assistance with resolving these issues as they arise

Leverage their “referral” behavior and training

The Physician Champions can “refer” their peers to the Compliance Office to assist with questions or concerns

Utilizing And Leveraging Relationships With Your Physician

Champions

Utilizing And Leveraging Relationships With Your Physician

Champions

DCE/ DCA – how the Physician Champions help the Compliance Office There are many benefits for the Compliance

Office to utilize this approach

Impact to the organization’s culture

– Physicians participate with the Compliance Program so they too want to see it succeed

– It’s our program, not just the Compliance Office’s program

– Compliance is seen as part of the job – part of the daily routine

– Are we perfect? No, but non-compliance is seen as imperfection and culturally we strive for perfection

DCE/ DCA – how the Physician Champions help the Compliance Office There are many benefits for the Compliance

Office to utilize this approach

Impact to the organization’s culture

– Physicians participate with the Compliance Program so they too want to see it succeed

– It’s our program, not just the Compliance Office’s program

– Compliance is seen as part of the job – part of the daily routine

– Are we perfect? No, but non-compliance is seen as imperfection and culturally we strive for perfection

Utilizing And Leveraging Relationships With Your

Physician Champions

Utilizing And Leveraging Relationships With Your

Physician Champions

DCE/ DCA – How the Physician Champions help the Compliance Office

There are many benefits for the Compliance Office to utilize this approach Education

– Changes to CMS requirements that involve changes to physician documentation is far more easier to implement

– Education, is easier because the Compliance Office has excellent access to various committees through the Physician Champions

Network

– You are automatically “linked-in” with the Physician Champions’ peers

– Creates the perception that the Compliance Office is more approachable

DCE/ DCA – How the Physician Champions help the Compliance Office

There are many benefits for the Compliance Office to utilize this approach Education

– Changes to CMS requirements that involve changes to physician documentation is far more easier to implement

– Education, is easier because the Compliance Office has excellent access to various committees through the Physician Champions

Network

– You are automatically “linked-in” with the Physician Champions’ peers

– Creates the perception that the Compliance Office is more approachable

Utilizing And Leveraging Relationships With Your Physician

Champions

Utilizing And Leveraging Relationships With Your Physician

Champions

Be the Physician Champions’ advisor on macro level issues

Major changes or proposed major changes that will impact their area or the entire organization

Be the Physician Champions’ consultant on micro level issues

Know their specialty and issues that impact their area

Be their consultant for complex compliance issues

Involve the Physician Champions in education as often as possible when conducting training sessions with their peers

Be the Physician Champions’ advisor on macro level issues

Major changes or proposed major changes that will impact their area or the entire organization

Be the Physician Champions’ consultant on micro level issues

Know their specialty and issues that impact their area

Be their consultant for complex compliance issues

Involve the Physician Champions in education as often as possible when conducting training sessions with their peers

Pointers

Utilizing And Leveraging Relationships With Your

Physician Champions

Utilizing And Leveraging Relationships With Your

Physician Champions

Capitalize on how this approach can mold and shape your culture

Leverage this relationship to network, engage, and build relationships with other physicians

Utilize the Physician Champions to make the Compliance Office more approachable

Utilize the Physician Champions to break down barriers and silos

Capitalize on how this approach can mold and shape your culture

Leverage this relationship to network, engage, and build relationships with other physicians

Utilize the Physician Champions to make the Compliance Office more approachable

Utilize the Physician Champions to break down barriers and silos

Pointers

Utilizing And Leveraging Relationships With Your

Physician Champions

Utilizing And Leveraging Relationships With Your

Physician Champions

Don’t overload or overwork your Physician Champions

Don’t leave them on their own without your support-they need it

Your Physician Champions expect you to be the compliance expert they can turn to for help Give them the same level of expertise

and perfection that you expect of them

Don’t overload or overwork your Physician Champions

Don’t leave them on their own without your support-they need it

Your Physician Champions expect you to be the compliance expert they can turn to for help Give them the same level of expertise

and perfection that you expect of them

Pitfalls

Pointers And Pitfalls In Gaining Physician Buy-In To A Compliance

Program

Pointers And Pitfalls In Gaining Physician Buy-In To A Compliance

Program

Interacting with physicians The ability to understand their focus

and avenues to relate or communicate is critical.

Building physician - compliance office relationships This is critical for the success of your

Physician Champions program as well as for the overall success of your compliance program

Interacting with physicians The ability to understand their focus

and avenues to relate or communicate is critical.

Building physician - compliance office relationships This is critical for the success of your

Physician Champions program as well as for the overall success of your compliance program

Conclusions

Pointers And Pitfalls In Gaining Physician Buy-In To A Compliance

Program

Pointers And Pitfalls In Gaining Physician Buy-In To A Compliance

Program

Utilizing and leveraging relationships developed with your Physician Champions Tie everything together you have learned

from interacting with physicians and building your Physician Champions program to help mold and shape your entire organizational approach to compliance.

Leverage these relationships to integrate compliance into their daily routine

Utilize these relationships to network and continue your “Compliance Grass Roots” movement

Utilizing and leveraging relationships developed with your Physician Champions Tie everything together you have learned

from interacting with physicians and building your Physician Champions program to help mold and shape your entire organizational approach to compliance.

Leverage these relationships to integrate compliance into their daily routine

Utilize these relationships to network and continue your “Compliance Grass Roots” movement

Conclusions

Pointers And Pitfalls In Gaining Physician Buy-In To A Compliance

Program

Pointers And Pitfalls In Gaining Physician Buy-In To A Compliance

Program

Questions?Questions?