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The Art of Communication and the Compliance Message

Posted By: Bret S. Bissey, MBA, FACHE, CHC, CMPE / September 18, 2015

HCCA LogoIn the August 2014 issue of Compliance Today, Bret S. Bissey, MBA, FACHE, CHC, Senior Vice President, Compliance Services with MediTract authored an article about the impact of today’s communication message and methods on compliance programs.

As a former compliance officer (with over 10 years experience), I am asked frequently about the seven elements of compliance and specifically, which is the most important? My response is that you really cannot do effective and impactful compliance without all seven being in place. Some like to refer to each of the elements as the “blocking and tackling” of your compliance program. To further explain and demonstrate the point, it is like asking a college football coach which is the most important aspect of their program—is it offense, defense, special teams, line play, the quarterback, the fullback, recruiting, etc.—hopefully you get the point: If one element fails, your program probably isn’t ever going to reach its full potential.

But there is one compliance program element, education and training, that I would like to analyze as it relates to today’s evolving methods of communication (sometimes impersonal) and the impact it has on your compliance program. So let’s go way back to the beginning of compliance guidance from the Office of Inspector General’s Model Compliance Program for Hospitals (1998) and review the direction given regarding education and training, as follows:

  • The proper education and training of corporate officers, managers, employees, physicians, and other healthcare professionals, and the continual retraining of current personnel at all levels, are significant elements of an effective compliance program.
  • A variety of teaching methods, such as interactive training and training in several different languages, particularly where a hospital has a culturally diverse staff, should be implemented so that all affected employees are knowledgeable of the institution’s standards of conduct and procedures for alerting senior management to problems and concerns.
  • The OIG suggests that all relevant levels of personnel be made part of various educational and training programs of the hospital. Employees should be required to have a minimum number of educational hours per year, as appropriate, as part of their employment responsibilities.

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Bret S. Bissey, MBA, FACHE, CHC, CMPE

Prior to joining MediTract, Mr. Bissey was the SVP, chief ethics and compliance officer at UMDNJ, where he successfully led the compliance program to adherence with a rigorous five-year Corporate Integrity Agreement with the DHHS/OIG that occurred following a Deferred Prosecution Agreement. Prior to UMDNJ, Bissey served as the director of the Regulatory Compliance Practice at IMA Consulting, the chief compliance and privacy officer at Deborah Heart and Lung Center (operating under a CIA) and the VP of compliance at Cabot Marsh/QuadraMed. Mr. Bissey earned a Bachelor of Science in business administration and marketing from Shippensburg University of Pennsylvania and an MBA in marketing and healthcare administration from Wilkes University. Mr. Bissey is a frequent national speaker on healthcare compliance and is the author of The Compliance Officer’s Handbook. He is a Fellow of the American College of Healthcare Executives and a member of the Health Care Compliance Association (CHC), American College of Medical Practice Executives and the Healthcare Financial Management Association.