By Adam Turteltaub

At the 2018 HCCA Compliance Institute, Lloyd Dean, the CEO of Dignity Health wowed the crowd as he discussed his very positive perspective on compliance and the importance of compliance programs to the organization.

During his speech he shared five compliance-related questions that he always asks when evaluating a new business opportunity.  Two things were intriguing about those questions.  First, they had clearly been internalized within executive decision making.  The compliance team didn’t have to ask them;  management already did.  Second, the questions were both simple and insightful, enabling management to quickly get a sense of whether there were potential risks that would require the compliance team’s help.

Margaret Hambleton, the Vice President for Corporate Compliance and Chief Compliance Officer for Dignity Health (and current president of the Society of Corporate Compliance and Health Care Compliance Association), is the author of those questions.  They are specific to healthcare, but, as she explains in this podcast, could be customized for any industry.

* Does the idea/process/opportunity require an exchange of anything of value with a patient, physician or other referral source?

* Does it change the way services are documented, billed, coded or reimbursed?

* Are there any improper motives or conflicts for doing the planned thing, particularly those related to clinical decision making?

* Does it require sharing protected healthcare information or business confidential information outside of our network?

* Does it require evaluation by any other experts in the organization?

Listen in as she explains the genesis of the questions, how she helped management learn them, and how the right set of questions can make a big difference in how management looks at compliance.