Twelve years ago, two compliance officers were having a phone conversation when the subject turned to networking and the value of gaining an education from ones peers. The pair decided to hold a compliance officers meeting in Minneapolis to see if others would be interested in forming an organization, and though 30 people were invited, 60 people showed up. Since that time, the Healthcare Compliance Association, or HCCA, has grown to include 5,600 members from 25 countries around the world.
“The HCCA has grown like crazyweve got a wide variety of members from all aspects of healthcare including compliance officers, in-house and outside counsel, consultants and vendors as well as people from other industries interested in compliance including educators, auditors, investigators, generalists and more,” said CEO Roy Snell, one of the organizations founding members. “We had 2,300 people in attendance at our last annual meeting.”
With so many different aspects to compliance, its important that those in the healthcare industry, as well as those in other industries, understand the complexities involved. “Compliance is based on U.S. sentencing guidelines, which judges use to determine the size of fines and penalties for those who have broken the law,” explained Snell. “The basic elements of compliance include auditing, monitoring, education, having an anonymous reporting mechanism, reporting to the board, investigations, discipline, and policies and procedures.
“These tools are used to find and fix regulatory problems such as incorrectly billing Medicare, following EMTALA laws on emergency room operations and Stark laws regarding physician ownership of facilities to which they refer work,” he added. “If you have the basic elements of a compliance program in place and theres a problem, fines and penalties may be smaller.”
While most large healthcare facilities have a compliance officer, this position may be held part-time by someone in another area of a smaller facility, such as a nursing home. “Smaller organizations cant justify a full-time position, so they may give the role to a human resources person or another department as a slash job, such as HR/compliance officer,” said Snell. “As in any profession, its extremely helpful for compliance officersespecially those who may be new to the jobto gain education and networking opportunities with their peers.”
HCCA publishes a monthly magazine with a number of how-to articles in it, as well as holds 35 compliance conferences a year for those in the field. “Some of these are local and fairly inexpensive, and others are sub-industry specific and geared to subjects such as research, quality of care, physicians practices and Medicare Part D,” explained Snell. “Our annual meeting features more than 100 different sessions covering all aspects of healthcare compliance.”
HCCA also provides certification programs to recertify compliance professionals as well as hosts a week-long Compliance Academy to help members get ready for certification examinations. This is not only important to the members themselves, but also to the organizations where they are employed.
“If I were the CEO of a healthcare facility, I would want to make sure that our compliance officer knew enough about current issues to be aware of when he or she should react, and also knew enough not to overact and waste resources on every issue that came along,” said Snell. “For example, right now the Office of the Inspector General, the Department of Health and Human Services and the Department of Justice are all focusing on quality-of-care compliance issues. If an organizations compliance officer is one of our members, he or she is aware of the current enforcement initiative and has the necessary knowledge and tools to assess their facilitys readiness for ongoing enforcement activities.
“Officers who are active in the compliance community have a more balanced, informed perspective about whats going on,” he added. “They know to worry about the right things.”
While compliance functions are often scattered in an organization, Snell believes that soon all regulatory compliance issues will be consolidated into a central office in order to facilitate the sharing of resources while creating efficiencies. He also believes that compliance officers will begin looking for higher-level certifications than the basic certification level. To this end, HCCA is rolling out the first “Certified in Healthcare Fellow” program, which requires officers to have greater experience in compliance and ensures employers that their compliance personnel are adequately informed and trained.
“Its important to know that a compliance professional is knowledgeable and effective, and that an organizations compliance program is robust,” said Snell. “CEOs, boards and administrative leadership need to ensure that they are creating and maintaining an ethical environment.”
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