Above reproach: developing a comprehensive ethics and compliance program.

How can a healthcare organization improve the public's confidence in the conduct of its business operations? What can it do to ensure that it can thrive despite being the subject of public and governmental scrutiny and doubt? Healthcare providers must establish standards of conduct that are above reproach and ensure that those standards are clearly articulated and strictly adhered to. This article describes the merits of a comprehensive ethics and compliance program, suggests five basic elements of such a program--organizational support/structure, setting standards, creating awareness, establishing a mechanism for reporting exceptions, and monitoring and auditing--and then demonstrates how those elements should be applied in several high-risk areas. Fundamentally, an ethics and compliance program has two purposes: to ensure that all individuals in an organization observe pertinent laws and regulations in their work; and to articulate a broader set of aspirational ethical standards that are well-understood within the organization and become a practical guideline for organization members making decisions that raise ethical concerns. Every ethics and compliance program should contain certain fundamental aspects. First, the effort must have the active support of the most senior management in the organization. To instill a commitment to ethics and compliance absent a clear and outspoken commitment to such purposes by organization leaders is simply impossible. Second, an ethics and compliance program is fundamentally about organizational culture--about instilling a commitment to observe the law and, more generally, to do the right thing. Third, ethics and compliance are responsibilities of operating management (sometimes called line management). Although staff such as compliance officers are obligated to provide the necessary resources for a successful program and to design the program, such staff officers cannot achieve implementation and execution. Only operating managers can do that. Fourth, an ethics and compliance effort should be about the conduct of individuals, not about "checking the boxes" in a model plan or generating attractive written or educational materials. Such an effort is about individuals on a day-to-day basis knowing what is expected of them and doing it and about never compromising integrity, regardless of pressures faced. A great deal of progress has been made in healthcare organizations in the development of increasingly sophisticated ethics and compliance programs. A particularly energetic focus has been placed on these programs since formal government guidance regarding compliance programs was first issued in the laboratory area about two years ago and as more sophisticated automated monitoring tools have been developed. As ethics and compliance programs have become more sophisticated, certain best practices have been established. This discussion will set forth approaches to ethics and compliance in the context of what are believed to be illustrative best practices. Much of what is described here is descriptive of the efforts of Columbia/HCA Healthcare Corporation from October 1997 to the present; however, this article has been presented not as a mere descriptive piece but rather as a set of normative guidelines. We hope that other healthcare providers will find this to be of practical use. Provider settings pose certain unique challenges that are specifically addressed in this discussion; however, many of the issues raised can be adapted to other healthcare organizations. For simplicity's sake, because the authors of this article all work on a daily basis primarily with hospitals, the article is written from a hospital perspective.

Health record completion guidelines. American Health Information Management Association.

It is a pleasure to introduce this important project report to the American Health Information Management Association (AHIMA) membership. Analyzing records for omissions, notifying physicians of needed information, counting delinquent records, and pursuing late documentation are some of the biggest chores in today's health information management departments. And they are chores that take time away from other priorities--managing, analyzing, and presenting health data, planning and implementing computerization, assessing and meeting customer needs. The heart of this statement is simple: it points out that there are other options to the traditional, detailed, record-by-record analysis. And those options may give us the results we need--timely and complete health records--while freeing up valuable staff time for other priorities. Take a serious look at the statement. If you are eager to make a change in your department's practices in records analysis and completion, it will back you up. If you are comparing the value of your department's records completion work to its benefit, this statement will give you ideas for change. And if you don't think you'd ever challenge tradition, this statement will give you food for thought. An added value to this statement is the fact that the ideas in it, and the very statement itself, are the product of our own profession. We are fortunate that leading-edge practitioners gave their expertise to the entire profession. The members of the strategy group for this project are listed above, we thank them for their wisdom.

Quality assurance not equal to quality improvement.

The intent is not to be critical and the misconceptions are easy to understand. The verbiage related to QI and QA sound alike. Quality improvement is not an easy undertaking for any industry. Some industries have tried QI and failed, while others have tried with admirable successes (e.g., Ford, Florida Power and Light, Motorola). The undertaking of the successful programs has not been easy or painless. QI requires extensive education, change of management philosophy and re-evaluation of our organizational structure. For QA professionals this transition will not be easy or painless . We must first accept that the terminology sounds similar but that the definitions are different. We must accept that our prior processes are far from perfect and can improve. As QA professionals, we must accept that the time is here to learn and to improve. We must begin by improving those processes which we own. This effort must coincide with identification of our customers and implementing systematic mechanisms for identifying their needs and expectations. Through energy expenditure and analysis of data over time, we can improve our processes and ultimately improve the output of our efforts. Only after we have learned QI processes, practiced them through daily application, and improved them can we begin to think about applications of QI to clinical process. After we expend the energy to learn about QI and apply it daily, we will be among the informed. QA professionals must prepare for and learn to value this change. Quality improvement and its technology represents a concept which may truly improve America's healthcare.(ABSTRACT TRUNCATED AT 250 WORDS)