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.

Product-line administration: a framework for redefining medical record department services.

Product-line administration is a viable approach for managing medical records services in an environment that demands high quantity and quality service levels. Product-line administration directs medical record department team members to look outside of the department and seek input from the customers it is intended to serve. The feedback received may be alarming at first, as the current state of products usually reveals a true lack of customer input. As the planning, defining, managing, and marketing phases are implemented, the road will not be easy and rewards will be slow to come. Product-line administration does not provide quick fixes, but it does provide long-term problem resolution as products are refined and new products developed to meet customer needs and expectations. In addition to better meeting the needs of the department's external customers, the department's internal customers' needs and expectations will be addressed. The participative management approach will help nurture each team member's creativity. The team members will have the opportunity to reach their full potential while reaping the rewards and benefits of providing products and services that meet the needs and expectations of all department customers. The future of the health care industry promises more changes as the country moves toward some form of prospective payment in the ambulatory setting. Reactive management and the constant struggle to catch up can no longer be accepted as a management approach. It is imperative that the medical record department be viewed as a business with product lines composed of quality products. The planning, defining, managing, and marketing components of product-line administration afford responsiveness to the current situation and the development of quality products that will ensure that medical record departments are prepared for the future.

Using the Deming quality improvement method to manage medical record department product lines.

The above application of the quality improvement cycle provides insight into the use of the Deming method to address one of several identified customer needs and expectations obtained during the managing phase of product-line administration. Implementation of the quality improvement method requires a major commitment from all team members. Process improvement requires a willingness to be detail oriented. Gathering of statistics--such as analysis turn-around time--and evaluation are critical. This objective view of processes requires accountability and a commitment to change. Improvements focus on long-term problem resolution, not the quick fixes that result from addressing symptoms of problems. True problem resolution occurs by solving the root causes of variations. Medical record departments must move from being outcome oriented to being process focused. It is no longer feasible to be constantly putting out fires in an environment that demands well-planned and well-designed products that meet customers' expectations. The long-term management of product lines requires a systematic method of planning, doing, checking, and acting. The Deming quality improvement method provides a framework for positive change that focuses on quality processes resulting in a quality product that meets consumers' needs.