Pointers And Pitfalls In Gaining Physician Buy-In To A ... · November 12, 2010. Pointers And Pitfalls In Gaining Physician ... Desire perfection Want to be correct. Know Your Audience

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


Robert H. Ossoff, DMD, MD, CHCAssistant Vice Chancellor for Compliance

and Corporate IntegrityVanderbilt University Medical Center

Nashville, TN

Robert H. Ossoff, DMD, MD, CHCAssistant Vice Chancellor for Compliance

and Corporate IntegrityVanderbilt University Medical Center

Nashville, TN

Anna M. Grizzle, Esq.Bass, Berry & Sims PLC

Nashville, TN

HCCA South Central Regional Annual Conference

Nashville, TN

November 12, 2010

Anna M. Grizzle, Esq.Bass, Berry & Sims PLC

Nashville, TN

HCCA South Central Regional Annual Conference

Nashville, TN

November 12, 2010



� Improve interactions with physicians

� Build physician - compliance office


� Build physician - compliance office

Objectives

� Build physician - compliance office relationships

�Utilize and leverage relationships developed with physician champions


�Utilize and leverage relationships developed with physician champions

Interacting With PhysiciansInteracting With Physicians

�Know your audience

� Know their focus

�Know your audience

� Know their focus

� Know their compliance risk

� Know their characteristics

� Know their compliance risk

� Know their characteristics

Know Your AudienceKnow Your Audience

� Main focus

� Patient care

� Patient safety

� Main focus

� Patient care

� Patient safety

� Quality of care

� Compliance risk

� Poor documentation

� Incorrect billing

� Risk management issues

� Incorrect reimbursement

� Relationships

� Quality of care

� Compliance risk

� Poor documentation

� Incorrect billing

� Risk management issues

� Incorrect reimbursement

� Relationships


�General characteristics

� Usually competitive in nature


� Usually competitive in nature� Usually competitive in nature

� Like to be the best or a leader in their field

� Compete with their peers as well as themselves

� Like challenges

� Desire perfection

� Want to be correct

� Usually competitive in nature

� Like to be the best or a leader in their field

� Compete with their peers as well as themselves

� Like challenges

� Desire perfection

� Want to be correct



� Interested in processes that


� Interested in processes that� Interested in processes that

� Improve quality of patient care

� Improve patient safety

� Improve patient satisfaction

� Improve efficiency and productivity

� Improve reimbursement and cut cost

� Interested in processes that

� Improve quality of patient care

� Improve patient safety

� Improve patient satisfaction

� Improve efficiency and productivity

� Improve reimbursement and cut cost


� General characteristics

� Education

� Highly educated in their field and/or specialty

� Usually interested in advancing their understanding of the

� General characteristics

� Education

� Highly educated in their field and/or specialty

� Usually interested in advancing their understanding of the � 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

– Research, science and fact based oriented

– Entrepreneurial – like to think outside of the box and challenge Dogma

� 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

– Research, science and fact based oriented

– Entrepreneurial – like to think outside of the box and challenge Dogma


� Capitalize on their general characteristics� Capitalize on their general characteristics

Pointers – Build Bridges

� Competitive by nature

� Provide data when discussing compliance concerns

– Compare them to their peers

� Offer “win-win”

� Be mindful of their time

– Just the facts!

� Competitive by nature

� Provide data when discussing compliance concerns

– Compare them to their peers

� Offer “win-win”

� Be mindful of their time

– Just the facts!


�Appeal to their interests

� Demonstrate how documentation can

�Appeal to their interests




�Improve the quality of care and improve patient safety

�Improve overall efficiency and productivity

�Improve patient satisfaction

�Improve reimbursement and cut cost


�Improve the quality of care and improve patient safety

�Improve overall efficiency and productivity

�Improve patient satisfaction

�Improve reimbursement and cut cost


� Capitalize on their general characteristics

� Education

� Provide examples relative to their specialty

� Capitalize on their general characteristics

� Education




� 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

� Provide facts about what needs to be improved and why

� Explain why this is the right thing to do

� Ask for their input on how to better improve compliance


� 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

� Provide facts about what needs to be improved and why

� Explain why this is the right thing to do

� Ask for their input on how to better improve compliance


� Conversation starters

� Dr. X, the Compliance Office has identified an opportunity you can use to

� Conversation starters

� Dr. X, the Compliance Office has identified an opportunity you can use to

Pointers-Build Bridges

opportunity you can use to

� Improve patient care, patient safety and patient satisfaction

� Improve the quality of your care

� 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

opportunity you can use to

� Improve patient care, patient safety and patient satisfaction

� Improve the quality of your care

� 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


� Don’t start off conversations with

� Under the False Claims Act of 1863 you are…..

� Don’t start off conversations with

� Under the False Claims Act of 1863 you are…..

Pitfalls – Instant Bridge Burners

� According to hospital policy HR – 40.02 you must…..

� I’ve seen kindergarteners that had better documentation than yours and.....

� If you expect to get paid you will do…..

� According to hospital policy HR – 40.02 you must…..

� I’ve seen kindergarteners that had better documentation than yours and.....

� If you expect to get paid you will do…..


� Physicians will be thinking

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

� Physicians will be thinking

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

Pitfalls – Instant Bridge Burners

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

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


� Know your audience

� Appeal to their interests to improve patient care

� Appeal to their competitive nature

� Know your audience

� Appeal to their interests to improve patient care


Summary


� Understand how to phrase and tailor your discussions and educational efforts 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

� Link quality with compliance

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


� Understand how to phrase and tailor your discussions and educational efforts 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

� Link quality with compliance

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

Build Physician - Compliance Office Relationships


� Politics play a role

� You need buy-in from the top

� Politics play a role

� You need buy-in from the top� 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

� 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



� Develop your Physician Champions

� Where to start?

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

� Develop your Physician Champions

� Where to start?

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

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



� 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

� 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� 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

� 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



� Theory to implementation - Vanderbilt approach

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

� Theory to implementation - Vanderbilt approach

� Several years ago implemented a program involving physicians to advocate for compliancephysicians 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)

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)



� Politics

� Get buy-in from the top

� Learn the landscape and develop your

� Politics

� Get buy-in from the top

� Learn the landscape and develop your

Pointers

� 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

� 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

� Buy-in can not come by compromising on ethics or integrity

� Politics

� Buy-in can not come by compromising on ethics or integrity

Pitfalls

Buy-in can not come by compromising on ethics or integrity

� 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

Buy-in can not come by compromising on ethics or integrity

� 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



� Buy-in is critical

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

� Buy-in is critical

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

Summary

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

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

Utilize And Leverage Relationships With Your Physician Champions


�How can the Compliance Office help the Physician Champions?

�How can the Compliance Office help the Physician Champions?

� Think high altitude and sea level

� Make it work for your Physician Champions and you

� Think high altitude and sea level

� Make it work for your Physician Champions and you

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

� These Physician Champions will receive questions from their peers so it is critical that they understand some it is critical that they understand some basic, fundamental compliance issues

� High altitude – be their advisor and advocate

it is critical that they understand some basic, fundamental compliance issues

� High altitude – be their advisor and advocate



� Physician champions will need assistance from the Compliance Office

� Understand the Compliance Program Plan

� Physician champions will need assistance from the Compliance Office

� Understand the Compliance Program Plan� 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)

� 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)



� Physician Champions will need assistance from the Compliance Office

� Physician Champions will need assistance from the Compliance OfficeOffice

� Major changes within CMS

� The new alphabet soup

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

Office

� Major changes within CMS

� The new alphabet soup

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



�High altitude – be their advisor and advocate

�High altitude – be their advisor and advocateadvocate

� 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

advocate

� 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



� Sea level – be their consultant

� Individual physician audits

� Utilize your Physician Champions to help explain audit findings


� Individual physician audits

� Utilize your Physician Champions to help explain audit findingsfindings

– 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

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




� Billing, coding, documentation, and operational issues


� 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

� 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



� DCE/DCA – how the Physician Champions help the Compliance Office

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

� DCE/DCA – how the Physician Champions help the Compliance Office


� 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

� 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


� Education

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


� Education� Education

– Changes to CMS requirements that involve changes to physician documentation are far more easy 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

� Education

– Changes to CMS requirements that involve changes to physician documentation are far more easy 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



� Be the Physician Champions’ advisor and advocate on high altitude issues

� Major changes or proposed major changes that will impact

� Be the Physician Champions’ advisor and advocate on high altitude issues

� Major changes or proposed major changes that will impact

Pointers

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

� Be the Physician Champions’ consultant on sea 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

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

� Be the Physician Champions’ consultant on sea 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



� Capitalize on how this approach can mold and shape your culture

� Leverage this relationship to network,

� Capitalize on how this approach can mold and shape your culture

� Leverage this relationship to network,

Pointers

� 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

� 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

Utilize And Leverage Relationships With Your Physician ChampionsUtilize And Leverage Relationships With Your Physician Champions

� Don’t overload or overwork your Physician Champions

Don’t leave them on their own without your

� Don’t overload or overwork your Physician Champions

Don’t leave them on their own without your

Pitfalls

� 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 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




� The ability to understand their focus and


� The ability to understand their focus and

Conclusions

� The ability to understand their focus and avenues to relate or communicate is critical


� This is critical for the success of your Physician Champions program as well as for the overall success of your compliance program

� The ability to understand their focus and avenues to relate or communicate is critical


� This is critical for the success of your Physician Champions program as well as for the overall success of your compliance program



� Utilize and leverage relationships developed with your Physician Champions

� Tie everything together you have learned from

� Utilize and leverage relationships developed with your Physician Champions

� Tie everything together you have learned from

Conclusions

� Tie everything together you have learned from improving interactions 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

� Tie everything together you have learned from improving interactions 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



Questions?

Robert H. Ossoff, DMD, MD, CHC

Questions?

Robert H. Ossoff, DMD, MD, CHCRobert H. Ossoff, DMD, MD, CHC

615-343-0429

[email protected]

Anna M. Grizzle, Esq.

615-742-7732

[email protected]

Robert H. Ossoff, DMD, MD, CHC

615-343-0429

[email protected]

Anna M. Grizzle, Esq.

615-742-7732

[email protected]

Documents

Pointers And Pitfalls In Gaining Physician Buy-In To A ... · November 12, 2010. Pointers And Pitfalls In Gaining Physician ... Desire perfection Want to be correct. Know Your Audience