AT: I have to admit that I’ve met a lot of compliance people through the years but few with as broad a background in healthcare. You have a doctor of medicine degree. You worked in internal audit and coding, and you have deep training experience both from work internally and outside of your day-to-day work. Let’s go through each of these. As someone who earned an MD, what insights does that provide you into the thinking of doctors that compliance professionals should be more aware of?
CJW: Well, I of course will be generalizing here, so I apologize to those physicians who don’t fit this description, but:
Most physicians expect a lot from themselves. Frequently, they have a “perfectionist” personality, so they might expect this of others, including their compliance colleagues. So, make sure you have your ducks in a row. Be prepared and excel at what you do in compliance, know your stuff, and admit it when you don’t know. For example, having a regulation or requirement’s chapter and verse on hand can demonstrate your competence.
Physicians have been trained to anticipate what might go wrong. You might be able to earn their trust and respect when you anticipate their compliance needs. Look at compliance from their perspective. They didn’t go to medical school and residency to spend their day on compliance. That doesn’t mean they don’t want to comply; it means they are busy with other things, such as patient care. Make complying as easy as possible for them and you can convert them to compliance deputies on the front lines.
Physicians tend to rely on scientific outcomes and data. Try to incorporate objective data when dealing with compliance issues. Maybe it is as simple as sharing national coding and billing data compared to their own billing data or recent enforcement actions that are on par with the issue at hand. I’ve spent some time in the conflict-of-interest world. Rather than lecturing to physicians, it might be beneficial to share objective studies on conflicts of interest in clinical practice, such as those found in The Journal of the American Medical Association’s May 2, 2017, issue or the studies of Amarnath Annapureddy et al.; William Fleischman et al.; and James P. Orlowski and Leon Wateska.
Physicians are often competitive by nature. I once was asked to attend a medical department’s monthly department meeting to share recent coding audit results with the department’s physicians. The physicians wanted to know how well they performed compared to their colleagues. After getting permission to share the results within the department, the discussion was almost completely taken over (in a good way) by the physicians. They wanted to know what they had to do to have the best results in the department, etc. Each month I would go back to the department meeting, and there was a friendly competitive spirit that led to marked improvement in all the physicians’ coding and documentation.
AT: You left the practice of medicine to work in administration. How did that change your perspective on the provision of healthcare?
CJW: My perspective changed dramatically. I soon gained some inside knowledge on payer contracts, legal issues, and reimbursement rules. But I feel like I never lost sight of what the overall mission was—that is, to take care of patients. I tried to combine my knowledge of the healthcare system with improving the delivery of healthcare services. I prided myself in trying to present compliance and reimbursement issues in a way that would make sense to clinicians. I wanted to ease their compliance burden as much as possible, knowing full well there would be many compliance responsibilities only they could address. Building relationships of trust was my focus, and it resulted in better communication and, I believe, in better compliance overall.