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OIG Speaks to Importance of Compliance in Changing Health Care Environment

on Friday, 3 May 2019 in Health Law Alert: Erin E. Busch, Editor

At this year’s Health Care Compliance Association Compliance Institute, Joanne Chiedi, Principal Deputy Inspector General of Health and Human Services (“HHS”) spoke about innovation in health care and the important role of compliance, recommending that compliance have “a seat – and a voice – at the innovation table.”

Ms. Chiedi noted that in today’s health care environment, patients and their families are becoming more empowered as consumers, and are able to use technology to find and receive services, access their own medical records, and collect health and wellness data from health-related wearables and apps. Providers and payers are rethinking how to deliver care, with initiatives focused on value over volume. Innovators are developing new health technologies, changing care delivery models, and advancing clinical treatments. Finally, Ms. Chiedi emphasized that compliance also has a role to ensure that the rules of the road are followed, that patients are protected from harm, and that dollars earmarked for innovation are well spent.

Ms. Chiedi shared the following four strategies to ensure success in the compliance landscape of the future:

  • Agility and Adaptability: Being nimble in adapting to change will be critical. As an example, Ms. Chiedi stated that the OIG has a multidisciplinary workforce that uses data and technology to look for program vulnerabilities. In this time of innovation in health care, compliance programs should look at staffing and be sure staff has the right mix of skills to oversee a changing health care environment.
  • Continuous Prioritization: To respond to rapid change, compliance professionals should develop a list of priorities and then engage in a continuous process of review and reassessment of those priorities. Compliance professionals must scan the environment often and from multiple viewpoints to evaluate both the current state of affairs and to identify emerging issues on the horizon. Compliance should be supportive of an organizational culture that allows for experimentation, and not be a roadblock to innovation.
  • Compliance Leadership: Compliance leaders should develop a clear vision and be passionate about compliance so that others see that compliance cares about the success of the organization and its efforts at innovation. Compliance should not be an afterthought; ensuring compliance has a seat at the table will help avoid costly mistakes and retrofitting down the road. As a first step, compliance professionals should seek a meeting with those in their organizations involved in data and technology and ask to be included at the development stage to ensure innovations are rolled out in a compliant manner.
  • Strategic Partnerships: Partnerships are more important than ever in today’s health care environment. Ms. Chiedi counseled compliance professionals that it is “not healthy or sustainable to go at it alone”. To develop better partnerships, she recommended compliance get to know the department heads within their organizations (starting with IT), and reach out to the compliance staff of other entities partnering with your organization in innovations.

Ms. Chiedi stated that “[b]usinesses that plan to be around for more than 15-20 years will embrace change” and will have compliance “working shoulder to shoulder with their disruptive innovators”. Ms. Chiedi compared how a good compliance program will be similar to innovation programs themselves, by ensuring that compliance efforts do not become stagnant and evolve to be successful in the new health care environment.

Ms. Chiedi will become acting Inspector General of HHS in June of this year when current Inspector General Daniel Levinson retires at the end of May.

Kimberly A. Lammers

1700 Farnam Street | Suite 1500 | Omaha, NE 68102 | 402.344.0500