The Inspector General of Health and Human Services discusses the importance of compliance


[ Applause ]>>Thank you. Thank you, thank you and good morning.>>Good morning.>>Is there a compliance officer in the house? Wow, it’s so nice to be here with
you at our Orlando, Florida meeting. There is just something magical
about being in Orlando. Believe me, I was shocked, I was surprised
when I showed up last night just before dark in the cab, checked in to the hotel and there
in front of the hotel is this humongous pyramid and the first thought I had was, wow, I hope
the hotel didn’t go to too much trouble to work with my slide presentation but it’s an
incredible coincidence and it’s a reminder of how much we human beings like
pyramids and the interesting thing about pyramids is they represent,
I think, stability. It’s difficult to topple over, you know. They don’t come and go. They tend to be very permanent and that
is I think a very important message to convey this morning, the permanence
of compliance and so what I want to do this morning is actually go
into our compliance pyramid and think about the five major building blocks
that make for the compliance pyramid. Let’s go in to the, I guess, the
bottom left part of the pyramid. We’re now talking the foundation of what
we do, two parts to that foundation. The part on the left is establishing
an effective compliance program. Let’s go into that. Setting a tone that may look like I
just wanted to have something at the top but setting a tone is so terribly important. If’ there’s one takeaway this morning is that
what you do is extremely important but is not about us, it’s about our function, it’s
about the purpose of what we do so we need to incorporate that in everything that we do. We don’t need to take ourselves seriously but we
certainly need to take the function seriously. So we set a tone by understanding that we
really are very important to the enterprise. Strangely enough, there are
plenty of organizations still that don’t understand the
importance of compliance. If it’s important, it’s not important just
to us, it’s most important that it be shared and that it be shared in ways that are
understandable to everybody, so we need to focus on our plain English in providing useful and
relevant and applicable codes and policies. They’re written out. People can read them and understand them. Training and outreach, it doesn’t
matter if we have in the books if people aren’t given an opportunity
to read and then to engage with them, to understand how they work in practice. So we devote a lot of attention, don’t we, to
training people and to providing the outreach so that every corner of the
organization is aware of what we’re doing. We’re there to address problems. We’re not a problem for our enterprise. We’re there to address the problems that the
enterprise faces and it faces them everyday. These are institutions that are
operated by us imperfect human beings. We’re there to help them address problems
and we keep things clean and operational by engaging an internal auditing and monitoring. Utilize available resources. If one half of our foundation is
establishing an effective compliance program, the author half is making sure that we’re
taking advantage of all of the tools necessary. Compliance program guidelines, most
of you perhaps with the exception of some newbies are familiar with the facet that OIG has been promulgating
compliance program guidance since 1999 and those guidances are on our web site, they cover nearly every corner
of the healthcare industry. Everything for nursing homes, to
hospitals, to physicians, you name it. There is a compliance program guidance that
you can find easily available on our website. Also on the website, advisory
opinions, fraud alerts, open letters. We note especially in this
part of the pyramid May 18th because we’re gonna be doing a national webcast
that will allow everybody, you don’t have to be in Baton Rouge, you don’t have to be in any
particular city that we’re holding this series. You’ll be able to take advantage of what
we’re doing just by going on the web and of course it’s very important to
keep up with all of the resource guides, a recent publication which again
is available on our website that is what we call a physician’s guide to
avoiding medicare and medicaid fraud and abuse. Let’s move up to the middle area of the pyramid
and this is where we’re looking at the things that are coming around the
bend now, the new staff. We have our foundation of a compliance program
that we know is permanent, permanently based and is critical to the organization. We know how to take advantage of the
resources that are available both within our office and externally. Let’s look at some of the new
challenges that we all face in our field. Uh! We’re definitely on a government page. Yeah we see the eagle, the eagle
side of the seal of the United States so there must be some government stuff here. So let’s look at these points,
the Affordable Care Act. The Affordable Care Act has a lot of
new requirements coming down the road. We all need to be familiar with it. Let’s capture the idea in the three key words
– transparency, compliance, and accountability. I note the shift from pay and chase. As many of you know, especially the veterans,
for many, many years we have had a system that was too relaxed and the mandatory
compliance, well as I said earlier, it’s one of the key reasons why we’re
engaged in such aggressive outreach on compliance training is that looking down the
road not just the larger players in our field but nearly everyone has to be thinking about how
to structure an effective compliance program. We’ll move over to the left side
of the middle of our pyramid and that’s understanding the
consequences of noncompliance. We’re working on getting the
right stuff done in the right way and we also have a good understanding
of the consequences of noncompliance. Handcuffs, that’s a little bit
overly dramatic from this audience. I think we’re trying to come up with
a visual that would gain attention, be relevant to at least of the points. That is not a point of intimidation
but we did want to give me a chance to note how actually pleased
we are with the successes of our Medicare Fraud Strike Force work
’cause over the last several years, we have really through better data
collection and realtime data use, we’ve really been able to
make substantial inroads. We have brought to the treasury billions
of dollars over the last several years. Not just millions but billions of dollars. On false claims act liability and
director and officer accountability, we note that because again mistakes if anything
are getting higher when it comes to insuring that compliance is done appropriately. You know, with a requirement now that
overpayments be accorded within 60 days of their having been found it’s more important
than ever to understand that a failure to be active on the compliance front has
significant false claims act exposure. So we need to be on top of that. On self-disclosure protocols and corporate
integrity agreements, there’s a certain yin and yang there because I do
think it’s better to self-report to have an effective compliance
program that finds the overpayment, that finds the improper claim that can
find these issues before government needs to detect them and at the top
of our pyramid our purposes to maintain an ethical and healthy organization. That’s what is really the umbrella for what
I’ve been talking about this morning is that you’re thinking comprehensively and when I say you’re thinking comprehensively
these are the four elements that we think of when we go into the top of our pyramid. We’re thinking of training not as a one time
exercise but as something that’s ongoing and I was really struck when I said
that there were 52 conferences, that’s essentially a conference a week
that HCC has held over the last year. That’s a good example I think of
organizations thinking about the importance not of just doing a training session and then
checking that box but thinking of training as something that needs to go on all the time. It’s very, very dynamic. Best practices really is
tied to the ongoing training because it really gives you the
opportunity to think about how to develop your compliance program in a
way that is optimum and you do that really by attending the training and by putting
on the training and then by making sure that everybody is communicating with everybody and when I say internal communications
what I’m talking about is using communications horizontally,
vertically, diagonally, using the new social that is now available whether
it’s twitter or facebook or stuff that is certainly beyond my capacity to
understand but it’s everything can go viral in a very good way when it comes to compliance
so take advantage of internal communications and the last point, acknowledging
compliance excellence. You know, that again is not a throw away point. I have no doubt that there are very, very
effective capable people certainly in this room but in your organizations back home as well
who should be recognized for their excellence in this compliance professional field and
I am not in a position to recognize them. I’m just the inspector general but you can
do it and that brings us to the very tiptop of our pyramid and lo and
behold we have another pyramid. Where have you seen that pyramid? [ Inaudible Remarks ]>>Oh, you know that it’s on there. So when you go back to the office and
they say, what did the IG talked about, you can say, he showed us the money. Well, he showed us part of the money. He showed us part of the money. It’s on the left side of the
greenback part of the dollar bill. You know, earlier, we saw the eagle of the seal
and this is something that Franklin Roosevelt who actually put this on the
dollar bill really appreciated. The seal of the United States is like
a coin really and so the eagle is where the president’s profile would be. If you turn the seal over, it’s the pyramid. What’s the pyramid doing there? Well, it’s an ancient symbol. I see there’s a Latin there. That Latin actually dates
back to Virgil and the Aeneid. The bottom of the seal is loosely interpreted
as a new order for the ages and it was meant when it was designed in the
18th century by the founders to say young American republic
getting on without kings and queens. It’s a new order for the ages and
I think it has some relevance to us because with the affordable care act
and now quality involved with payment. We have something of a new order for the
ages and if we look up at the top we see– well, we see eye and you know 3000
years ago an ancient Egyptian seeing that eye would have assumed you
were talking the eye of Horus, H-O-R-U-S which was a divine
presence for Egypt but that was– that symbolism was reinterpreted
in the 18th century. There is certainly a lot of
freemason involvement with it as well but it was reinterpreted in the 18th century
as the eye of providence and what I would like to do this morning with you is to
reinterpret it for the 21sth century as the eye of compliance and who is the eye of compliance. You are the eye of compliance,
you are the eye of compliance. [ Applause ]>>You have that eye, you are aware of
what it’s taken to get us to this point and you have a great sense of where we’re
gonna need to be as healthcare reform unfolds and the field gets complicated but as important
as ever as far as what we do so you are the eye of compliance and that Latin
expression on the top. In the 18th century, it was meant to say the
Almighty has favored our undertaking and I would in a sense reinterpret that for our 21st
century to say that in whatever capacity and whatever power I have as the IG you should
know that this morning we favor your undertaking as effective and empowered compliance officials
and with that thank you again for inviting me. I always love to be here and best
wishes for continued success. Thank you. [ Applause ]>>Thank you.

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