Effective Training: Teaching Compliance to Clinicians · 2013-04-24 · Create visuals and handouts...

Effective Training: Teaching Compliance to Clinicians

The George Washington University Healthcare Corporate Compliance Graduate Certificate Program

Jane Hyatt Thorpe, JDRobert H. Ossoff, DMD, MD,CHC

Michael B. Glomb, Esq

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Today’s Program

Laying the foundation for educating clinicians Designing and facilitating adult learning Pointers and pitfalls in gaining physician buy-

in to the compliance program Some hypothetical case studies

The George Washington University Certificate in Healthcare Corporate Compliance© Feldesman Tucker Leifer Fidell LLP

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The Foundation

Compliance begins at the top “Connecting” the Board and “C” Suite to a

meaningful compliance program Legal requirements - Affordable Care Act, OIG,

exclusion of individuals, etc. Compliance as a good business practice

Risk management Quality of care issues Reputation considerations


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The Foundation

The Board and “C” Suite as “role models” Compliance message must be authentic Behavior is the message – people are watching

Getting their attention Cases, numbers, trend lines, etc. Information, not just data Spread the work – compliance committee, task group,

etc. Consider organization’s mission/priorites Be a tortoise


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Connecting to Clinicians

Clinicians’ focus Patient care Safety Quality

Life issues – career, status, compensation, etc. Compliance risk

Poor documentation Physician ownership/relationship issues Quality issues Risk management issues


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Connecting to Clinicians

Compliance risk Poor documentation Physician ownership/relationship issues Quality issues Risk management issues


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DESIGNING AND FACILITATING ADULT LEARNING


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How Adults Learn

The key to designing a successful training program for adults is to recognize that adults learn differently from children

In Understanding and Facilitating Adult Learning (1986), Stephen Brookfield stated that successful adult learning involves creating an environment in which exchange and dialogue must take place between trainers and learners


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How Adults Learn, cont.

Adult learning principles emphasize interaction between trainers and learners, rather than relying on a didactic approach (“experts” present materials using visual aids and handouts)

This interactive approach utilizes the six core principles for adult learning first described by Malcolm Knowles in 1975 in Self-Directed Learning: A Guide for Learners and Teachers


Knowles’ Core Learning Principles for Adults

The need to know The learner’s self-concept The role of the learner’s experiences Readiness to learn Orientation to learning Motivation


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Key Components of a Learning Program

Analysis Design Development Implementation Evaluation

Rosenberg, Marc J. (1982, Sept.) The ABC’s of ISD (Instructional Systems Design). Training and Development Journal, 44-50.


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Analysis What is the subject matter? Why is it important?

Who are the learners? How many people? Who are they? What are their ages and

backgrounds? What do they do? What do they already know about this topic? What do they need to know at the end of the

learning experience?


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Analysis, cont.

Are there barriers to learning that must be overcome? What is the learning timetable? How much time can be devoted to training? What is your organization’s attitude toward learning

activities? What type of technology does your organization have? Are you limited to use of existing technology or can you

experiment?


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Design

Begin with a clear purpose and specific goals What do I hope to accomplish? How can I motivate participants to learn? Think in terms of behavior and skills – what do you

want people to do differently? Include learners in designing the program Build on learner’s current knowledge and

attitudes Identify and understand obstacles to learning

(e.g., subject matter, characteristics of learners, physical barriers)


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Design, cont.

Recognize that a single method of teaching adults is not possible

Be flexible Vary activities and exercises Use technology when appropriate to enhance

learning Make sure you have broad agreement about

approach, goals, structure and content


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Development Create a strategy that uses a variety of approaches to

achieve learning goals, for instance: Lecture Demonstration Interaction Shared learning Problem solving Case study Team work Role playing Simulation


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Development, cont.

Ground exercises in real life issues and examples

Focus on what’s essential: do not try to cover too much too quickly

Create visuals and handouts that reinforce learning objectives and the emphasize practical application of subject matter

Use technology if it enhances learning


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Implementation

Create an environment for learning Physical set up of room Room temperature/lighting/noise Anticipate special needs of learners, especially

those with disabilities Minimize obvious obstacles to learning Timing and length of training session Reduce distractions (cell phones, PDAs)


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Evaluation

How to measure what was learned? Feedback Transference (can learners apply what they learned to

their jobs?) How to measure benefits to the organization?

What’s the organization’s ROI? Be sure to communicate to learners the

organization’s expectations for follow up/next steps

Actually follow through on next steps


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Bottom Line

Develop consensus around the need for and approach to training

Plan your program carefully: recognize the needs and capabilities of your audience

and potential barriers to learning involve learners in designing the program

Be sure that the physical setting for your program is not itself an obstacle to learning


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Bottom Line, cont.

Design simple, practical programs that use techniques that reflect adult learning principles and varied approaches to learning

Enhance motivation to learn by emphasizing personal and organizational benefits

Spend time in the planning process designing evaluation and follow up activities


POINTERS AND PITFALLS IN GAINING PHYSICIAN BUY-IN TO A COMPLIANCE PROGRAM


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Objectives

Improve interactions with physicians Build physician - compliance office

relationships Utilize and leverage relationships

developed with physician champions

23The George Washington University Certificate in Healthcare Corporate Compliance© Feldesman Tucker Leifer Fidell LLP

Interacting With Physicians

Know your audience Know their focus Know their compliance risk Know their characteristics


Know Your Audience

General characteristics 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


Know Your Audience

General characteristics Interested in processes that

Improve quality of patient care Improve patient safety Improve patient satisfaction Improve efficiency and productivity Improve reimbursement and cut cost


Know Your Audience

General characteristics Education

Highly educated in their field and/or specialty 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



Pointers – Build BridgesCapitalize on their general characteristics Competitive by nature

Provide data when discussing compliance concerns Compare them to their peers

Be mindful of their time Just the facts!



Pointers – Build BridgesAppeal to their interests Demonstrate how documentation can Improve the quality of care and improve patient

safety Improve overall efficiency and productivity Improve patient satisfaction Improve reimbursement and cut cost



Pointers – Build BridgesCapitalize on their general characteristics

Education Provide examples relative to their specialty 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


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Pointers-Build Bridges Conversation starters

Dr. X, the Compliance Office has identified an 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



Pitfalls – Instant Bridge BurnersDon’t start off conversations with

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

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…..


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Pitfalls – Instant Bridge BurnersPhysicians will be thinking

Here we go again, non physicians telling me 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


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Build Physician - Compliance Office Relationships

Politics play a role 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

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

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 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)


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Pointers Politics

Get buy-in from the top 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



Pitfalls Politics

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


Utilize And Leverage Relationships With Your 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 it works for 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 basic, fundamental compliance issues Teach them an abbreviated version of

Compliance 101 High altitude – be their advisor and advocate



Physician champions will need assistance from the Compliance Office 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 Major changes within CMS The new alphabet soup

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



High altitude – be their advisor and 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 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


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Sea level – be their consultant 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



How the Physician Champions help the Compliance Office There are many benefits for the Compliance Office to

utilize this approach 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



How the Physician Champions help the Compliance Office There are many benefits for the Compliance

Office to utilize this approach 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

NetworkYou are automatically “linked-in” with the Physician

Champions’ peersCreates the perception that the Compliance Office is

more approachable



PointersBe the Physician Champions’ advisor and advocate on high altitude issues

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



Pointers Capitalize on how this approach can mold and

shape your culture 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 Listen for areas of misunderstanding Anticipate potential problems



PitfallsDon’t overload or overwork your Physician ChampionsDon’t leave them on their own without your support - they need itYour Physician Champions expect you to be the compliance expert they can turn to for help

Availability, availability, availability


Conclusions

Interacting With PhysiciansKnow your audience

Appeal to their interests to improve patient care Appeal to their competitive nature

Understand how to phrase and tailor your discussions and educational efforts so that each encounter is as effective and efficient as possibleRemember, the goal of most physicians is “the patient comes first” so try to work compliance into their daily patient care routine

Link quality with complianceAbove all, most physicians want to do the right thing!!!!


ConclusionsBuild Physician - Compliance Office Relationships Buy-in is critical 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


Conclusions

Utilize and Leverage Relationships Developed With Your Physician ChampionsTie 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 routineUtilize these relationships to network and continue your “Compliance Grass Roots” movement


Robert H. Ossoff, DMD, MD, CHCSpecial Assistant to the Vice-Chancellor for Health

AffairsVanderbilt University Medical Center

Nashville, TN615/343-0429

[email protected]


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Jane Hyatt ThorpeAssociate Professor

Department of Health PolicySchool of Public Health and Health Services

The George Washington University202/994-4183

[email protected]


Michael B. GlombFeldesman Tucker Leifer Fidell LLP

1129 20th Street, NWWashington, DC 20036

202/[email protected]

57 57The George Washington University Certificate in Healthcare Corporate Compliance© Feldesman Tucker Leifer Fidell LLP

Effective Training: Teaching Compliance to Clinicians · 2013-04-24 · Create visuals and handouts...

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