This interview with Barbara J. Vimont (firstname.lastname@example.org) was conducted in June 2020 by , BBA, CHC, CHPC, Compliance and Privacy Officer, Crystal Clinic Orthopaedic Center, Akron, OH.
CC: Barb, before you became involved in compliance, I know you were working in medical records. Tell us about how that transition came about.
BV: My first role in compliance was as compliance manager in patient financial services in a hospital setting. Interestingly, when they were looking to fill the position, the hospital initially wanted a nurse. Luckily for me, a medical records consultant working with the department suggested looking for a medical records person, and that is what started me in my compliance career.
In medical records (health information management), I supervised the coding, release of information, and file room staff. Many of the skills needed to oversee those areas translated well to compliance work. Coding is a large part of compliance auditing, and release of information, while a part of compliance, took on a more significant role once Health Insurance Portability and Accountability Act (HIPAA) went into effect. I assumed that my knowledge of coding, with its direct link to billing, would be sufficient to work in the compliance world. I quickly learned that what I thought I knew only scratched the surface of the billing side. Thank goodness I had an extremely knowledgeable and patient director of patient financial services, and others in the department, who showed me the ropes.
We actually helped each other, because, as we’d come to learn, many times the coders and billers were saying the same thing but using a different “language,” leading to quite a bit of misunderstanding between the two groups. Having experience with both sides allowed me to interpret for each side and bring them closer together to ensure we were meeting the government’s rules and regulations, as well as those of commercial insurers.
The next learning curve I faced involved an increased number of rules and regulations to understand. While overseeing coding, my focus was strictly on coding rules, regulations, and guidance. Although some of the guidance came from the Health Care Finance Administration (now Centers for Medicare & Medicaid Services), it did not involve laws related to Medicare and Medicaid fraud, waste, and abuse; the Anti-Kickback Statute; the Stark Law; and others that are a significant part of compliance.
Another transition, though not as steep, came when I was promoted to compliance officer a little more than a year after taking on the role of compliance manager. I had a compliance consultant and our external counsel at the time to thank for this transition. They were able to get our CEO and other leadership to understand the need to have a compliance officer in addition to the compliance manager position, given the expansion of the health system. My new role involved not only the billing rules and other areas I’d learned as compliance manager, but also overseeing a compliance program for the entire health system that I worked for. I now was responsible for compliance activities, with the assistance of one person at each entity who wore multiple hats. I had the opportunity to learn about compliance for two acute care hospitals, one of which was under a corporate integrity agreement (my health system became responsible for that when it acquired the hospital), a critical access hospital, a home health agency, a nursing home, and a group of physician practices. Again, I had the good fortune to have excellent resources both within and outside the health system to guide me through this new adventure.
I laugh about where my career has taken me sometimes, because when I was getting my medical records degree, the part I disliked the most was the quality assurance auditing and monitoring. Whenever I talk with others about their career plan, I now always tell them, “Even if you dislike an area, be prepared—it could be where you end up, and you’ll enjoy it.”