The result of a Compliance Effectiveness Roundtable held January 17, 2017 in Washington DC is the, “Measuring Compliance Program Effectiveness – A Resource Guide” (https://oig.hhs.gov/compliance/101/files/HCCA-OIG-Resource-Guide.pdf).
The Guide, released March 27, 2017, describes seven core elements of a compliance program and suggests ideas about what and how to measure the effectiveness of compliance programs. The hundreds of options take into consideration the broad range of organizations and respective sizes, shapes, styles, practice types, and resources.
Participants of the roundtable included compliance professionals and staff from the Department of Health and Human Services, Office of Inspector General (OIG).
The suggestions are abundant but can be confusing when arranging in order of natural sequence and priority. As legacy experts in the screening, monitoring and compliance space in health care, Verisys can help compliance officers establish and maintain a best-practices organization in line with the effectiveness measurement suggestions.
As an example of the natural confusion and inherent risk born of what is required of a compliance program; element three is centered on: “Screening and Evaluation of Employees, Physicians, Vendors and other Agents.” Subcategory items include the verification of background/sanction checks and monitoring.
In most cases, the various departments engaged in screening will use different databases or screening services with vastly disparate levels of accuracy and integrity. The human resources department may use a third-party screening service, the credentialing department may be required to work through a state CVO and the compliance department may rely on the OIG search service plus the National Provider Data Bank (NPDB).
There are no guidelines suggesting the use of the highest quality data and solid verification standards. Verisys’ proprietary database, FACIS (Fraud Abuse Control Information System) dates back to 1993 and has more than 4 million reports informed by actively tapping 5,200 primary sources and continuously monitors 5 million providers for sanctions.
This is compared to the OIG searchable database that at any given time dates back five years and relies on reporting for its content. The use of NPDB is mandated, yet it contains a fraction of the amount of records contained in FACIS. Without using FACIS, the screening and verification process is checking against data that leaves huge gaps inviting exposure to waste, fraud and abuse, patient endangerment, as well as legal issues with corrective, remedial and dismissal processes and procedures.
“Scamming the health care system is endemic and drives up the cost of health care, eliminating fraud would be a giant step toward achieving Congress’ goal of affordability,” says John Benson, Verisys CEO. “It would require massive changes to existing flawed systems and challenging the CMS contractors whose very expensive systems just add more cost by engaging in the pay and chase game. We need to have an honest discussion about prevention and it starts with a solid gatekeeping and monitoring strategy, something that Verisys delivers in the commercial sector today. The government needs to stop spending money on magic bullets and start applying common sense solutions.”
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Written by Verisys Verisys transforms provider data, workforce data, and relationship management. Healthcare, life science, and background screening organizations rely on our comprehensive solutions to discover their true potential. Visit verisys.com to learn how we turn problems into power.
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