Process improvement program evolves into compliance program at an integrated delivery system.

Abstract

An integrated delivery system discovered questionable practices when it undertook a process-improvement initiative for its revenue-to-cash cycle. These discoveries served as a wake-up call to the organization that it needed to develop a comprehensive corporate compliance program. The organization engaged legal counsel to help it establish such a program. A corporate compliance officer was hired, and a compliance committee was set up. They worked with counsel to develop the structure and substance of the program and establish a corporate code of conduct that became a part of the organization's policies and procedures. Teams were formed in various areas of the organization to review compliance-related activities and suggest improvements. Clinical and nonclinical staff attended mandatory educational sessions about the program. By approaching compliance systematically, the organization has put itself in an excellent position to avoid fraudulent and abusive activities- and the government scrutiny they invite.