Embed Size (px)
Citation preview
9/10/2013
1
Getting All Your Docs in a Row: Gaining Physician Buy-In to Compliance
Vicki L. Dwyer, APRN‐CNS, CPC, CHC
Compliance Officer
Vail Valley Medical Center
Vail Valley Medical CenterFounded: 1965 ‐ Not‐for‐profit 501(c)(3) organization
Accreditations:
• Level III Trauma Center, designated by the State of Colorado
• Joint Commission Certified (3 year)
Facilities: 58 bed, Rural Community Hospital
Employees:
• Regular: approximately 835
• Seasonal: approximately 100
Medical Staff:
• Approximately 325 full‐time and affiliated physicians
Vail Valley Medical CenterHospital Services:
• Beaver Creek Emergency, Avon Urgent, & Gypsum Urgent Care Centers
• Shaw Regional Cancer Center / Sonnenalp Breast Imaging Center
• Howard Head Physical Therapy / Orthopedic Sports Medicine
Vail Valley Surgery Centers – Vail and Edwards
Diversified Services (Physician Offices):
• Aesthetic & Reconstructive Surgery
• Avanti Cardiology
• Mountain Surgical Associates
• Eagle Care Clinic
9/10/2013
2
Galichia Medical Group, P.A.Founded: 1978 with 2 Physician Owners (80/20)
Accreditations: Joint Commission Certified (1994‐1999)
Employees: Approximately 200
Medical Staff (employees, non owners):
• Physicians – between 20‐35• Non‐Physician Providers – between 10‐20
Specialties:
• Cardiology, Electrophysiology & Cardiovascular Surgery• Internal Medicine & Geriatrics• Pulmonology, Neurology & Endocrinology• Podiatry
•
Galichia Medical Group, P.A.Locations/Offices :
• Wichita (Main Office, West Side (2), South (1), Central (1)) • Rural Health Clinics – Fredonia & Russell
Outreach Clinics – up to 40 locations through‐out Kansas
Services:
• CLIA Waived • Radiology• Ultrasound, including Stress Testing• Cardiopulmonary• Nuclear Medicine
The Agenda• Becoming the Leader of the Pack
– Buy‐In From the Top Down
– Marketing Yourself to Gain the Respect You Deserve
• From Herding Cats to Getting Your Docs in a Row
– Opening Lines of Communication
– Communication Strategies
• Falling Off the Turnip Truck
– Effective Audits
– Educate, Educate, Educate
9/10/2013
3
Buy-In from the Top Down
• Getting the Leaders on Board–Leadership Commitment
• Understand Compliance
• Actively Support Compliance
• Create the Environment
Leading of the Pack (Gaining the Respect You Deserve)
• Market Yourself
–1 Page Dossier • Contact Information
• Experience in Compliance
• Education
• Areas of “Expertise”
Toot Your Horn!Compliance Officer: Vicki Dwyer, RN, MN, CHC, CPC
Office Phone: 970‐477‐5197
Cell Phone: 970‐471‐3080
To Make an Anonymous Report:
Compliance Hotline: 970‐569‐7550
compliance @vvmc.com
9/10/2013
4
Toot Your Horn!Professional Background:
Education: Diploma in Nursing – St. Francis School of NursingBachelor of Science in Nursing – WSU, Wichita
Masters in Nursing – WSU, Wichita
Graduate Certificate in Healthcare Corporate Compliance – George Washington University
Nursing: Registered Nurse – 30+ years (Critical Care , Pediatrics, TJC, QI, Risk Management, Staffing, Education)
Advanced Practice Registered Nurse ‐ Clinical Nurse Specialist – 10+ years
Adjunct Faculty, WSU School of Nursing
– 20+ years
Toot Your Horn!Compliance: 15+ years as Chief Compliance Officer, Wichita, KS
Development & Implementation of Comprehensive Compliance Programs
Government Investigations / Integrity Agreements
Documentation – Evaluation & Management Services
National Speaker on Compliance
Certifications: Certified in Healthcare Compliance (CHC)
Certified Professional Coder (CPC)
Toot Your Horn!Services Available to PhysiciansEducation & Training Documentation of Evaluation & Management Services
Anti‐Kickback Statutes / Stark Law
False Claims Act
Patient Inducement Regulations
EMTALA
HIPAA / HITECH
Audits & Monitoring Evaluation & Management Services
Contracts
Medical Necessity
9/10/2013
5
For Fun – You the Person!Fun Facts:
Family Children – Jim in Wichita, Amy in DenverGrandsons – Keegan in Wichita (2), Grayden in Denver (3)Parents – Both living in Wichita, KS
Pets ‐ 3 cats (Tequila, Trouble & Velvet)
Favorite Things Playing with grandsons, Reading by the fire with a cup of tea and my cats
Favorite Colors Pink and Purple
Favorite Food Prime Rib and Lobster
Favorite Movie Sweet Home Alabama
FromHerding Cats To Ducks in A Row
Okay, More Realistic
9/10/2013
6
The Gentle Art of Herding Cats1. Cats don’t like to be herded
(in fact, you can’t really herd cats)
2. Cats prefer to herd themselves3. Cats understand that they sometimes
need to be herded (that doesn’t make them any easier to herd)
4. Cats don’t like being reminded that they are being herded.
The Gentle Art of Herding Cats4. Harsh herding has negative
consequences5. Herd gently, but firmly with affection
or fish as a reward.Remember, you are a cat, too
We all need herding, at one time or another
Open the Lines of Communication(Yay Sayer Not Nay Sayer)
• Be an Advisor & Advocate
• Be the “Go‐to‐Person”
• Be Visible & Available
– Meet with Physicians
– Attend Medical Staff Meetings
– Be in the Clinical Areas
9/10/2013
7
Communication Strategies
• Understanding Your Audience (the Physician)
– Priority is Patient Care & Focus
– Competitive Nature
– Need Immediate Feedback
– Want it to be “fast” and “efficient”
• K.I.S.S. – Keep It Short and Simple
Communication Strategies
• Keep Them in the Loop
– Physician Newsletters
– Compliance Alerts
– Special Email’s
• Communicate 3 Times, in Different Ways
– In Person
– In Writing (Newsletters, Memos, Bulletins)
Communication Strategies
• Respect Their Time
– Time is Money – Show them the Money
• Respond Promptly
• Have Your Docs (Documents) in a Row
– Verify Your Facts, Triple Check
• Don’ts– Argue or Threaten– Assume
9/10/2013
8
Communication Strategies
• Build (don’t BURN) Your Bridges– Know What’s Important to Them
– Use Their Education and Personality to Your Advantage
– Avoid Conversation Stoppers
– ALWAYS Follow‐Through
Falling Off the Turnip Truck
Falling Off the Turnip Truck
• Everyone Will Fall! ‐ EXPECT IT!
• Falls Do Not Make You a Bad Person.
• The Key:– Watch for falls (Monitor and Audit)
– Understand why they fell off (Investigate)
– Get them back on – FAST (Corrective Action)
9/10/2013
9
Staying on the Turnip Truck
• Use Staff as “Assistant Herders”
–Clinical Staff
–Coders
–Auditors
– Testing Areas
Keeping Your Turnips on the Truck
• Educate, Educate, Educate– One‐on‐One Approach
– Show What’s in it for Them
– Positive Feedback
• Let them know you are watching
– Let Them Hear it from the OIG
– One Picture is Worth a Thousand Words
Hear it from the OIG• Compliance 101 and Provider Education
http://oig.hhs.gov/compliance/101/index.asp
• HEAT Provider Compliance Training Videos
– Importance of Documentation (4:12 minutes)
– Compliance Program Basics (3:58 minutes)
– Physician Self‐Referral Law (4:21 minutes)
– False Claims Act (4:17 minutes)
– Federal Anti‐kickback Statute (4:46 minutes)
– Exclusion Authorities & Effects of Exclusion (4:25)
9/10/2013
10
One Picture is Worth a Thousand Words
HPI Blood Sugars are up (275) and down (50)on Janumet. Log
Blood pressure is okay but gets dizzy frequently. Has started am
coughing, non‐productive.
Keeping Your Turnips on the Truck, Your Cats Herded and Your Docs in a Row
• Routine Auditing & Monitoring
– Schedule It
• Schedule time for follow‐up audits
– Audit High Risk Areas
– Audit Each Provider
– Pre‐Billing vs. Retrospective Audits
Keeping Your Turnips on the Truck, Your Cats Herded and Your Docs in a Row
• Present the Audit to the Physician
– Schedule It, Make an Appointment
• Set the Tone
– It’s All About Attitude & Approach
– Have the written results
– Have the actual documentation and audit forms
9/10/2013
11
Keeping Your Turnips on the Truck, Your Cats Herded and Your Docs in a Row
• Present the Good, the Bad & the Ugly
– Be Positive, Supportive – You are there to HELP
– Review the documentation & the Audit Results
• Begin the Investigation
– Discuss and LISTEN
– Ask “Who, What, When, Where, Why & How”
Keeping Your Turnips on the Truck, Your Cats Herded and Your Docs in a Row
• Start Corrective Action
– Educate
• Show the “What if’s”
• Give Examples
– Provide Written Information
• Guidelines
• “Sheet Sheets”
– It’s okay to say “I’m Not Sure”
Keeping Your Turnips on the Truck, Your Cats Herded and Your Docs in a Row
• Start Corrective Action– Correct work‐flow / processes
– Make it the EASY thing to do
• Re‐Audit & Follow‐Up– 6 weeks
– 3 months
– 6 months
– 1 year
9/10/2013
12
QUESTIONS?
Thank – You!Vicki L. Dwyer, APRN-CNS, CPC, CHC
Compliance OfficerVail Valley Medical Center181 West Meadow Drive
Vail, CO 81632316-641-9593
