April 1, 2014

Healthcare Compliance Requires Cooperation, Coordinated Care and Teamwork, says HHS Inspector General Levinson

By


Dan Levinson

Parrots, turtles, hawks and bees are just a few of the creatures that the Department of Health & Human Services Inspector General Dan Levinson referred to in the keynote speech he delivered to the audience of 7,000 at this week’s Health Care Compliance Association (HCCA) conference in San Diego. He also brought a few of his critter-to-compliance-officer analogies to Monitor Mondays' live HCCA broadcast on May 31.

Being that San Diego is famous for its zoo, Levinson decided to “marry up” some of the creature characteristics with advice related to healthcare compliance. Take, for example, the parrot.

“Do not parrot anyone else’s compliance program. Mitigate and resolve on a case-by-case, industry-by-industry basis,” said Levinson. “It’s vitally important to everyone” that this be done.

Then there are hawks, which experts say can see up to eight times better than the sharpest human eye. Levinson advises healthcare providers to “be on the lookout for some things coming from the OIG.”

Monitor Mondays senior correspondent and co-host Nancy Beckley, president of Beckley and Associates, reminded Levinson of the “be-on-the-lookout” analogy he shared on another Monitor Mondays broadcast, telling listeners to be on the lookout for a kinder, gentler OIG. That announcement and the OIG’s subsequent actions resulted in increased self-disclosures.

“It really is satisfying when we make the effort to better coordinate … and then get favorable response from the industry,” he said.

For this coming year, he underscores the importance of watching for several new laws that the OIG will be enforcing. One concerns the anti-kickback statute, another relates to new state harbors to update laws, and still another introduces a new package concerning civil monetary penalties. The IG promises a “unified package that will be valuable for lawyers and compliance officers.”

Another creature Levinson brought to the compliance audience was honeybees and their “team approach” to survival.

“It is something that’s very important to me and should be important to everyone who participates in this field,” he said. “In the final rules on the Medicare shared savings program, CMS suggested that compliance program providers will have to work across different lines to come up with coordinated care,” which will require coordinated compliance efforts.

For its part, the OIG will continue to focus on coordinating with law enforcement, Department of Justice, senior Medicare patrols, and others in the public and private sector. It is now working with payers to provide more data about the fraud list.

His message to compliance officers and healthcare providers: “Think about how you can reach out to peers and colleagues and think in terms of what compliance and a transformative environment would look like—a place where providers will work together…”

Although the OIG certainly has come a long way in changing its previous image as ”the bad guy,” Levinson still wants to send the following message to compliance officers.

“I want to express my deepest conviction that we are in the same business line. We need to think of ourselves as partners in making healthcare compliance more effective for our patients. It’s a team effort, and that’s what we stress on our website,” he says.

In fact, he brought the elephant, who it is said never forgets, into the picture, reminding listeners not to forget about all of the great resources and tools that are on the OIG’s website. These resources can provide compliance officers with the “optimum opportunity” to do a very important job.

“We hold in our hands the physical, mental, and financial health of the country given the stakes involved. We need to work together,” Levinson added.

In his closing thoughts to the Monitor Mondays audience, Levinson returned to an earlier discussion on Monitor Mondays with Erin Bliss from his office about the 2014 work plan. He reiterates that the work plan contains “valuable sign posts that chart where the OIG sees the risk areas.”

“We’re in the business of assessing where we should focus our own resources, which are on quality and patient safety,” Levinson said. The work plan is an “invaluable roadmap” and he encourages compliance officers to “take advantage of the contents… and use it in a proactive way.”

About the Author

Janis Oppelt is the editorial director of MedLearn Publishing, a division of Panacea Healthcare Solutions, Inc.

Contact the Author

joppelt@panaceainc.com

Janis Oppelt

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