Articles on Compliance Strategies

Monthly Contests Help Hospital Reinforce Key Compliance Concepts

Reprinted from the Nov. 20, 2006, issue of REPORT ON MEDICARE COMPLIANCE, the nation's leading source of news and strategic information on false claims, overpayments, compliance programs, billing errors and other Medicare compliance issues.

To reinforce employees' compliant behavior, Piedmont Healthcare singles out one employee every month for a special award and prize. It's one way that Chief Compliance Officer Debi Hinson keeps compliance front and center, and rewards people who act consistently within the Atlanta health system's motto: Do the Right Thing.

She began this award program on July 1 as part of her marketing strategy for compliance. "It provides an incentive to bring forth compliance issues," she contends. A trivia contest is another tool in Hinson's marketing toolbox. It helps boost awareness of the compliance program, along with the fact that attending training is a factor in employees' performance evaluations.

There's no formula for selecting the monthly winner of the "Chief Compliance Officer's Award." It's a gestalt kind of thing. But there are 10 characteristics that Hinson "takes into consideration when I choose" the winner. The following attributes have been announced and published so staffers understand what she expects in a winner:

(1) Responding to compliance questions with a pleasant and professional attitude.

(2) Seeking compliance advice when appropriate.

(3) Leading by example as a compliant/ethical employee.

(4) Reporting questionable activity or concerns to the compliance department for investigation.

(5) Always willing to assist the compliance department as requested.

(6) Responding to compliance questions/investigations, etc. in a timely manner.

(7) Using the compliance department as a resource and a consultant.

(8) "Doing the right thing" even though it means confessing an error in judgment.

(9) Offering solutions to problems, rather than just the problems.

(10) Being a team player — "One Piedmont."

There are 7,500 employees within the company, so someone really has to be special to win, says Hinson. Sometimes it's because an employee is gracious and helpful when Hinson repeatedly requests information that she needs to carry out her compliance job. For example, "there is one person I constantly have to call and ask to look up something in our information system. I always depend on her," Hinson says. "She always does it promptly, and she doesn't gossip about it" - even though it's obvious that the names she is looking up have caught the eye of the compliance department, which usually means something's afoot. Similarly, there's an employee in the governmental reimbursement department who constantly agrees, without hesitation, to help when asked, and always does it "in a very pleasant and timely manner," Hinson says.

Other examples of model behavior that garner employees points toward winning the compliance award: "If I have to contact someone with a compliance question, or someone is involved in an investigation, and they are pleasant and professional, or I witness people leading by example, such as completing training requirements in advance." Hinson says she also looks for employees to suggest solutions when they call in to report problems.

Voluntary Confessions Also Can Win Awards

She also would give the award to employees who confess an error in judgment (e.g., who inadvertently violate Medicare, HIPAA or other regulations or Piedmont rules). "They call and say, 'I realized I screwed up, and I am telling you,'" she says. "That shows me we are dealing with a compliant and ethical person." For example, "they may have realized they accidentally blurted something out they shouldn't have" (e.g., violated the Privacy Rule), "but immediately called me, or realized they were making a billing error, and let me know." Even though the employees may wind up facing a disciplinary action, such as a written reprimand, they were trying to do the right thing to make up for their mistake, she says, and corrective action is an essential part of compliance.

Winners are hailed throughout the system, so employees get the message that Piedmont values compliance, and people who do the right thing and go out of the way to set an example for others. Hinson announces the winner in the various Piedmont facilities managers' and executives' meetings, and in the compliance oversight meeting. The winner's name also is published in the employee newsletter, and he or she receives a fancy certificate and movie tickets.

The specifics surrounding why a particular employee was chosen as the winner are never specified, because Hinson would never want the award to be associated with an investigation or other compliance initiative, to protect its confidentiality. Employees could also be concerned that at least some of them would be perceived as rats who tattled on their colleagues for screwing up. "Winning is a positive thing and is viewed as honoring a model employee for their compliance efforts," she says.

At the end of one year of giving monthly awards, the compliance oversight committee will vote and select one person perceived as most compliant from the list of 12 monthly winners.

Identifying Employees With Misconceptions

Hinson also uses other methods to market compliance. There's a trivia contest every month, with a winner in every facility (three hospitals, 20 clinics). It also doubles as an education tool. The question and the answer to the previous month's question are published in the monthly employee newsletter.

Employees are encouraged to participate by sending their answers to the compliance department. Hinson then reads all answers. If an employee answers the question incorrectly, Hinson e-mails that person to thank him or her for participating, explain why the answer was incorrect and give the correct answer so he or she understands compliance concepts better. If the employee answered the question correctly, the submission is placed in a facility-specific box with all the other correct responses. Once a month, a winner from each facility is randomly selected.

Everyone has multiple chances to win because the names stay in the box, and the month's correct responses are added for the next drawing. When the question is particularly hard, there are clues to the solution in the newsletter, which forces employees to hunt for them in Piedmont polices and procedures.

An example of a trivia question: What are compliance training requirements for every employee? (Answer: All employees have to annually read and commit to the Piedmont Code of Conduct; complete an assigned privacy and information security module; and complete an annual compliance update module, plus certain assigned compliance modules that are job specific, such as coding, research, etc.)

"An effective compliance program must have everyone's participation, and we try to make it interesting and fun whenever possible," Hinson says.

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