From scheduling patients to care delivery to reimbursement, healthcare is an industry functioning on a daily basis under a mountain of Federal, state, and local regulations in the United States. To help navigate this mountain, many healthcare organizations have adopted corporate compliance programs (compliance programs) based on guidance from the Federal government.[1] A key element to the operation of a compliance program is the appointment of a compliance officer.
A common reality to the compliance officer profession is the fact that the business of healthcare is political. To be clear, when I say the business of healthcare is political, I’m not referring to the politicization of healthcare (i.e., healthcare being argued as a right or privilege). I am talking about the industry’s business environment. More specifically, the individuals working inside the industry and their various self-interests.
As we will explore in this new blog series, there are a number of key individuals a compliance officer has to work with on a daily basis. These individuals include healthcare executives, physicians, administrative and clinical workers, government agencies, third-party contractors, as well as patients and their families.
As with any self-interest, there will be times when they align with the organization’s compliance program, and times when, well…they will not. If you have ever advised a leader not to engage in certain conduct, only to find out he or she did it anyway, then you know what I mean.
When I think back on my life before my career, I had no idea there was a whole other world that existed in healthcare unknown to the general public. A world where physicians fight with each other over patients. A world where hospitals fight with physicians over compensation. A world where healthcare workers fight with each other over workflow issues impacting patient care. And a world where everyone is fighting the government over increasing bureaucracy and decreasing reimbursement.
It is this “other world” where you find the politics of healthcare alive, impacting how care is delivered. For you, the compliance officer, it impacts how you operate the compliance program. More specifically, it affects how you advise healthcare leaders on proposed business deals. It affects how you educate staff on regulatory or policy requirements. It affects how you conduct investigations, perform audits, and implement corrective action. There is no element of a compliance program immune to the politics of healthcare.
Going forward, I will discuss some strategies and insights to help the compliance officer navigate these self-interests and become more politically adept in the organization. While not a compliance program element per se, becoming politically adept, will help you carry out each of the seven elements more effectively.
So why is healthcare political?
Stay tuned and we’ll cover that topic in the next article.
[1] See “An Open Letter To Health Care Providers”, June Gibbs Brown, Inspector General, February 1997. See also, Office of Inspector General, Compliance Guidance, https://oig.hhs.gov/compliance/compliance-guidance/index.asp
[2] See Sections 6102 and 6401 of the Patient Protection and Affordable Care Act of 2010 (Pub. L 111-152).