P5.ppt - HCCA Official Site · Physician Perspective: Clinical Practice Guidelines and ... PPACA and Clinical Practice Guidelines PPACA and EHR: Risks, Benefits, & Complications PPACA

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Presented by

Physician Perspective: Clinical Practice Guidelines and

Quality of Care

Richard E. Moses, D.O., J.D.

D. Scott Jones, CHC

w w w . hpix-ins . c o m

Speakers’ Disclaimer● Richard E. Moses, DO, JD and D. Scott Jones, CHC do not

have any financial conflicts to disclose.

● This presentation is not meant to offer medical, legal accounting, regulatory compliance or reimbursement advice and is not intended to establish a standard of care. Please consult professionals in these areas if you have related concerns.

● The speakers are not promoting any service or product.

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Presentation Goals

● Examine PPACA and Clinical Practice Guidelines (CPGs)

● Review the impact of PPACA quality reporting mandates, timeliness, and reimbursement penalties

● Discuss the impact of CPGs and other PPACA requirements on quality of care

● Review processes to provide timely CPG, quality information, and education to physicians

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INTRODUCTION

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INTRODUCTION● Background – CPGs, Quality Reporting, and More

● PPACA and Quality Reporting

● PPACA and Physicians

● PPACA and Clinical Practice Guidelines

● PPACA and EHR: Risks, Benefits, & Complications

● PPACA and Physician Risk Education

● Building the Compliance Program of the Future

● CONCLUSIONS & SUMMARY

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PPACA: CPGs, Quality Reporting,

and More

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PPACA: Health Care Reform

● Health Care Reform Goals

• Improve Access

• Universal Coverage

• Increase quality reporting to include outcomes

• Increase integration of care through partnerships of physician networks and hospitals

• Cost control and cost reduction7


PPACA and Payments● Patient Protection and Affordable Care Act (PPACA 2010) was

amended by the Health Care and Education Affordability Reconciliation Act (HCERA 2012)• 21.3% scheduled reduction in Medicare physician pay (postponed by the

Continuing Extension Acts, 2010‐2014)

• Quality and Cost Payment (Title III, §§ 3002, 3003, 3007) – Adjusts physician payments based on quality and cost through a value‐based modifier, beginning January 1, 2015

• PQRS – penalties for not reporting beginning in 2015 up to 2% of the prevailing fee schedule

• Fee‐for‐service → value‐based reimbursement (“quality”)

8www.physiciansfoundation.org/uploads/default/Physicians_Foundation_2012_Biennial_Survey.pdf

www.ncsl.org/documents/health/ppaca‐consolidated.pdf

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PPACA and Volume

• Increase from 260.2 Million Americans with health insurance to 292.6 Million under PPACA • US Census Bureau 2012 Current Population Survey, Annual Social and

Economic Supplement

• 32‐40 Million Americans acquire new health insurance benefits with PPACA; proof of insurance required 2015

• U.S. physician workload expected to increase by 29% from 2005‐2025

• More than 50% of physicians are health system employees

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From Fee Based to Quality Based

● Fee‐for‐service → Value‐based/Quality‐based reimbursement system

• Reward doctors and hospitals for improving quality of care

• Lower demand for inpatient hospital services, higher demand for outpatient services

• Increased number of insured patients

• Improving patient experience key to preserving reimbursement

• Public outcomes reports = hospital competition on outcomes and total value

• Clinically Integrated Networks and Population Health Initiatives

10Health Affairs October 11, 2012

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PPACAand

Quality Reporting

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Hospital Value‐Based Purchasing

● PPACA Title III, Subtitle A: Transforming the Health Care Delivery System• Incentive Payments to Hospitals meeting performance standards in

MI, Heart Failure, Pneumonia, Surgery, Infections, Pulmonary Embolism and DVT Prophylaxis, Stroke

ED, Readmissions, Children’s Asthma

• Performance Scores increase/decrease DRG payments

• Incentives up to 2% of the Medicare FS by 2017

• Data and Scores on Hospital Compare Internet Site

• GAO reports October 2015 and January 2016

12http://www.medicare.gov/hospitalcompare

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Hospital Acquired Conditions Payment Reductions

● PPACA Section 3008

• FS Payments for Hospital Acquired Conditions will equal 99% of the FS

• The Secretary will determine a list of “hospital acquired conditions”

• Confidential reports to hospitals tracking conditions

• This program will be expanded to all other types of providers

• Possible CMS reports on Hospital Compare Internet Site

• Effective FY 201513

www.medicare.gov/hospitalcompare


Long Term Care, Rehabilitation, Hospice, PPS Exempt Cancer Hospitals, SNF, HHA

● PPACA Sections 3304‐3006

● Quality Reports required 2014 for all types of facilities

● CMS “Compare” Internet sites to post data

● Reduction in the “increase factor” of payments, up to 2%

● Increase Factor can = 0%, resulting in a 2% reduction

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Integrated Care Demonstration Project

● PPACA Section 2704

● Project continues through December 31, 2016

● Goal: Establish bundled payments for services and providers involving an episode of care and hospitalization

● Severity of illness adjusted payment

● Data collection monitors outcome, cost, quality

● Report to Congress: December 31, 2017

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Physician Compare Website● PPACA Section 10331(a)(1)

• PQRS Measures Reported

• Assessment of Patient Health Outcomes

• Assessment of continuity and coordination of care

• Assessment of efficiency and cost

• Assessment of patient experience

• Assessment of safety, effectiveness, and timeliness of care

• July 1, 2014: User Interface; reports published online

• January 1, 2015: CMS Report to Congress

16www.medicare.gov/physiciancompare

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Physician Compare Website

● CMS must allow physicians & other professionals to have reasonable opportunity to review their results before posting

• 30 day preview period for all measurement data

• October 2015 is next review date

● CMS details of review process

• www.cms.gov

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PPACA Section 10331(a)(2): CG‐CAHPS

● Clinician and Group Consumer Assessment of Healthcare Providers and Systems (CG‐CAHPS)• Patient surveys begin 2014…individual physician surveys by 2015

• Timely care, appointments, information

• How well doctors communicate

• Patient ratings of doctors

• Health promotion and education

• Shared decision making

• Health status/functional status as a result of care rendered

● “Certified Survey Vendor” created

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PPACA Rule CMS‐1600‐PQuality Reporting Measures

● Physician Quality Reporting System (PQRS) 2014: • 9 Measures be reported

• 3 from National Quality Strategy domains

• For 50% of the entire Medicare‐eligible patient population

● Effect of not reporting PQRS occurs in 2016

● Failure to report a selection of the measures = up to 2% reduction in prevailing Medicare FS

● Qualified Clinical Data Registries created for sub‐specialists dealing with specific diagnoses, conditions (§ 1848(m)(3)(E)(ii))

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Value Based Modifier (VBS)

● How quality data reported under PQRS equals modification to payments under the FS

● VBS use begins 2015; full implementation 2017

● Physician groups of 10 or more must report beginning 2016; expect all physicians to report by 2017

● Quality tier system results in FS reductions of up to 2%

● QRUR (Quality and Resource Use Reports) will report how the value based modifier will impact individual physician reimbursement

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National Strategy for Quality Improvement in Health Care

● PPACA Part S, Subpart I, Section 399HH(2)(B)(i‐iii)

● Calls for CMS to establish priorities that will:

• Have the greatest potential for improving health outcomes, efficiency, and patient‐centeredness…

• Identify areas…that have the potential for rapid improvement in the quality and efficiency of patient care…

• Address gaps in quality…

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National Strategy for Quality Improvement

● HHS Annual Report to Congress

● “Key Measures and Long Term Goals”

• “…reducing the harm caused in the delivery of care…reduce harm from inappropriate or unnecessary care….”

• CDC: 5% of hospital patients acquire health care associated infections

• 145 Health Care Acquired Conditions (HACs) occur per 1,000 admissions

• Agency for Healthcare Research and Quality (AHRQ): Hospital Readmissions occur at a rate of 14.4%

• Physicians and Compliance Officers are now Quality Officers 22

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PPACA and PHYSICIANS

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“No college junior studies organic chemistry and takes the MCAT planning to devote 4 years to

medical school and 3 plus years to residency and fellowship just to cheat Medicare and

Medicaid.”

Julie K. Taitsman, M.D., J.D.

CMO for the OIG, Department of HHS

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The Physicians Foundation

● National not‐for‐profit grant making organization dedicated to advancing the work of practicing physicians and to improving the quality of healthcare for all Americans

● Founded in 2003 through settlement of a class action law suit brought by physicians and state medical associations against third‐party payers

● Board of Directors: physicians and medical society leaders across the United States

www.physiciansfoundation.org 25



● 2014 Biennial Survey

• Every other national survey of physicians conducted

• Provide a “state of the union of the medical profession”

• Survey sent to over 650,000 physicians 80% of all physicians currently involved in patient care

• 20,000+ physicians responded in all 50 states

http://www.physiciansfoundation.org/uploads/default/2014_Physicians_Foundation_Biennial_Physician_Survey_Report.pdf 26

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● 2014 Biennial Survey

• Data derived from responses to > 35 questions Many questions multi‐response

• Over 13,000 written comments by physicians on current state of medical profession & healthcare system

• Data compared to 2012 and 2008 surveys

http://www.physiciansfoundation.org/uploads/default/2014_Physicians_Foundation_Biennial_Physician_Survey_Report.pdf27


Physician Opinion: Retirement 2014

I will accelerate my retirement plans 38.7%

I will defer my retirement plans 18.6%

I will not change my retirement plans 42.7%

http://www.physiciansfoundation.org/uploads/default/2014_Physicians_Foundation_Biennial_Physician_Survey_Report.pdf

Medicine and healthcare are changing in such a way that:

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Physician Opinion: PPACA

● The Physicians Foundation 2014 Biennial Report• 46% Physicians give PPACA grade of D or F

• 25% Physicians give PPACA grade A or B

• 39% Physicians are accelerating retirement plans due to PPAA

http://www.physiciansfoundation.org/uploads/default/2014_Physicians_Foundation_Biennial_Physician_Survey_Report.pdf 29


Physician Opinion: Key Findings• 81% physicians overextended or at full capacity

• Up from 75% in 2012 & 76% in 2008

• 19% have time to see more patients

• 44% physicians plan to reduce patient access to services

• Cut back visits, work part‐time, retire, close practice to new patients, seek non‐clinical jobs

• 35% physicians independent practice owners

• Down from 49% in 2012 & 62% in 2008

30http://www.physiciansfoundation.org/uploads/default/2014_Physicians_Foundation_Biennial_Physician_Survey_Report.pdf

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Physician Opinion: Key Findings● 17% physicians are in solo practice

• Down from 25% in 2012

● 69% physicians believe their clinical autonomy has been limited & their decisions compromised

● 24% physicians do not see Medicare patients or limit the number seen

● 26% physicians participate in an ACO

• 13% of this group believe ACOs will enhance quality & decrease costs



Physician Opinion: Key Findings

● Physicians spend 20% of their time on non‐clinical paperwork

● Concierge/Direct pay medicine

• 7% physicians now practice this way in some form

• 13% indicate they are planning to transition in whole or in part

• 17% physicians 45 yo or younger indicate they will transition to this form of practice


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About Doctors in General● Main Goal: Deliver quality care in effective safe manner

● Competitive, OCD, delayed gratification & clinical

● Tend to be detailed overachievers and/or survivors

● Clueless about Compliance…do not “get” it

● Think in terms of medical malpractice avoidance

● No prior training about fraud, abuse, & medical malpractice

● Inherently do not like or trust administrators

● Some people are just crooks…doctors included!

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Approaching Physician Education● One size does not fits all programs

● Each organization has unique needs

● One teaching method alone is not enough

● Areas of malpractice & compliance risks evolve and change with time

● A “check off” approach to physician education does not work

● You catch more flies with honey that you do with vinegar…PARTNER WITH YOUR DOCS!

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Things to Consider• Size of practice to be educated

• Physical location of practices

• Method(s) & venue of physician education

• Education is perpetual: not a one shot deal!

• Relevant & necessary topics • Provide education required by law first; then everything else

• OIG Work Plan

• Areas of risk that have internally or externally surfaced

• Allowable time ‐ Time is money to physicians

• Budget

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Teaching Principles

● Positive attitude – Compliment & encourage● Explain topic background & reference● Engage physicians to share experiences● Avoid confrontation with physicians, et al.● Helpful & supportive approach● Teamwork philosophy● Avoid intimidation ● Request feedback, review it, act on it!

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Teaching Principles: An Administrator and Compliance Officer’s Perspective

● Physicians are taught to assess, diagnose, implement correct treatment action, and be responsible for outcomes

● Little tolerance for ambiguity

● As scientists, respect facts and data that can be supported by research

● Understand but often dislike Peer Review

● Dislike being outliers

● Dislike being embarrassed before peers

● Generally want to do the right thing…But what is it?37


Educational Resources● “A Roadmap for New Physicians: Avoiding Medicare & Medicaid

Fraud & Abuse”• Booklet & companion slide presentation

• www.oig.hhs.gov/fraud/PhysicianEducation

● Internally Produced v. Commercial CME Programs

● Agency for Healthcare Research & Quality• http://webmm.ahrq.gov/cme.aspx

● Medscape Education• http://www.medscape.org/medscapetoday

● GOOGLE!

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PPACA and

Clinical Practice Guidelines

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New Nomenclature

● Community Based Standard/Standard of Care

● Clinical Practice Guidelines = CPG

● Evidence Based Medicine = EBM

Williams, C. 61 Wash & Lee L. Rev. 179 (2004)

Leape, L. et al. 288 JAMA 501 (2002) 40

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Standard of Care & the Expert Witness

● Standard of care → legal responsibility• Determining legal responsibility required of individual physician treating

for a unique patient is a problem in medical malpractice allegations

● Each state has its own legal definition

● General requirement:• Each physician has a non‐delegable duty to render professional services

consistent with that objectively ascertained minimally acceptable level of competence he may be expected to apply given the qualifications and level of expertise he holds himself out as possessing and given the circumstances of the particular case

41Barry Furrow et al. Liability and Quality Issues in Health Care 291 (6th ed. 2008)



● Knowledge & skills required to practice medicine lie outside realm of common knowledge

• Expert witness required

● Testify as to the standard of care

● Testify whether physician’s failure to meet that standard caused patient’s injury

● Expert’s role is to educate the court

● Allegedly honest and impar al → objec vity?

42https://www.nolo.com/legal-encyclopedia/medical-malpractice-using-expert-witnesses-30087.html

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● Our legal system requires experts be obtained by plaintiff & defendant NOT by the judge or jury

● Conflict of interest: Between expert’s opinion and interests of individual or entity who retained the expert

● Additional issues:

• Multiple treatment options available

• Questions in medicine not answered by scientific evidence

• “Art” remains critical along with science

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Clinical Practice Guidelines Evidence Based Medicine

● Institute of Medicine (IOM)

● EBM Defined:

“The conscientious, explicit, and judicious use of current best evidence in making decisions about the care of individual patients.”

Sacket, D. et al. 312 Brit. Med. J. 71 (1996)

Eddy, D. 26 J. Health Pol., Policy & L. 387 (2001) 44

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Institute of Medicine, TO ERR IS HUMAN: BUILDING A SAFER HEALTH CARE SYSTEM (1999)

Barry Furrow, et al., HEALTH LAW 267 (2nd ed. 2000)

Finder, J. Health Matrix: Journal of Law-Medicine 2000;10:67-115

● IOM

● CPGs Defined:

“Systematically developed statements to assist the practitioner with patient decisions about appropriate health care for specific clinical circumstances.”

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● ISSUE:• Can CPGs obviate the need for expert witnesses in medical malpractice

cases and for other situations?

● Purpose of CPGs• Improve effectiveness & efficiency of medial practice

• Standardize practice

• Improve healthcare outcomes

● CPGs produced by professional societies, healthcare organizations, government, international organizations

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● Published in 1970s & 1980s

● 1990s showed significant increase in CPGs

● NIH database → 6,793 English language CPGs

• 2011

● Variations in scientific validity, reliability, and usability exist across the world

• “standardization of the standards” has been advocated

47http://qualitysafety.bmj.com/content/12/1/18.full.pdf+html



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Number of English‐Language References for “Clinical Practice Guidelines” from 1974 – 2011 Per NIH Database, PubMed

Taylor C. Journal of Legal Medicine 2014;35:273-290.

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The Law & CPGs

• Evidence of customary medical practice

• Act as authoritative expert

• Used as well accepted review article

• Used by PLAINTIFFS

• Used by DEFENDANTS

Hyams A, Shapiro D, Brennan T. Medical Practice Guidelines in Malpractice Litigation: An Early Retrospective, 21 J.Health Pol., Policy & Law (1996)

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CPGs in Medical Malpractice Cases

● Already affecting settlement patterns according to survey of malpractice lawyers

● Plaintiffs have used guidelines to their advantage

● EXPERT TESTIMONY STILL NEEDED!

Hyams A, Shapiro D, Brennan T. 21 J.Health Pol., Policy & Law (1996)

Miles v. Tabor, 443 N.E.2d 1302 (Mass.1982); Basten v. U.S., 848 F.Supp. 962 (M.D.Ala.1994) 50

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CPG: Quality & Reimbursement• Measures collected under PQRS → “Quality Measures”

• Assessment of patient health outcomes & functional status of patients

• Assessment of continuity & coordination of care & care transitions

• Assessment of efficiency

• Assessment of patient experience & patient, caregiver, & family engagement

• Assessment of safety, effectiveness, & timeliness of care

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Example: CPG v. Reality

• CRC Screening Recommendations

• Cancer prevention tests should be offered first. The preferred CRC prevention test is colonoscopy every 10 years, beginning at age 50.

• Screening should begin at 45 years in African Americans.

• REALITY CHECK → insurance coverage

• Despite PPACA

Rex DK, et al. Am J Gastroenterol 2009;104:739-750.

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Example: Quality Indicators for Colonoscopy

1. Appropriate indication

2. Informed consent is obtained, including specific discussion of risks associated with colonoscopy

3. Use of recommended post polypectomy and post cancer resection surveillance intervals

4. Use of recommended ulcerative colitis/Crohn’s disease surveillance intervals

5. Documentation in the procedure note of the quality of the preparation

6. Cecal intubation rates (visualization of the cecum by notation of landmarks and photo documentation of landmarks should be present in every procedure)

7. Detection of adenomas in asymptomatic individuals (screening)

8.Withdrawal time: mean withdrawal time should be >6 minutes in colonoscopies with normal results performed in patients with intact anatomy

9. Biopsy specimens obtained in patients with chronic diarrhea

10. Number and distribution of biopsy samples in ulcerative colitis and Crohn’s colitis surveillance.

11. Mucosally based pedunculated polyps and sessile polyps < 2 cm in size should be endoscopically resected or documentation of unresectabiltiy obtained

12. Incidence of perforation by procedure type (all indications vs screening) is measured

13. Incidence of post polypectomy bleeding is measured

14. Post polypectomy bleeding managed non‐operatively

Rex DK, et al. Am J Gastroenterol 2006;101:873–885.


Colonoscopy Guidelines real time…

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CPGs Can Be Our Friends…

57Rex DK. Clin Gastroenterol Hepatol 2013;11:768-773.


Guidelines & QualityCompliance, Quality, Fraud & Malpractice

● Government Accountability Office (GAO)• “…beneficiaries…who receive healthcare from providers who adhere to

PPACA…may receive higher quality of care…Conversely, those who receive care from providers who fail to do so may receive lower quality of care.”

• “…it is possible that, if these (PPACA) standards and guidelines become accepted medical practice, they could impact the standard of care against which provider conduct is assessed in medical malpractice litigation.”

● Inadequate Quality can = Fraud and Malpractice

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Measurement is now the new normal!

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PPACA and EHR: Risks, Benefits,

& Complications

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EHR Practice Implementation 2014

2014 2012

Yes 85.2% 69.5%

No 14.8% 30.5%


Has your practice implemented EMR?

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EHR Practice Implementation 2014

2014

Improved quality of care 32.1%

Detracted from quality of care 24.1%

Improved efficiency 24.3%

Detracted from efficiency 45.8%

Improved patient interaction 4.6%

Detracted from patient interaction 47.1%

Little to no impact on the above 7.6%


If yes, how has EMR affected your practice?

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EHR & Clinical Practice Guidelines

● EHRs & CPGs are being incorporated into routine medical practice

● Synergism exists between EHRs and CPGs

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Paper DaysIf it’s not documented, you didn’t do it!

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EHR DaysYou documented it…did you do it?

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OIG EHR VULNERABILITY REPORT

● January 2014

● Objective:

• Describe how CMS & its contractors implemented program integrity practices in light of EHR adoption

● Concerned that EHRs may make it easier to commit fraud

● 2 Major areas where EHRs c/b used to commit fraud:

• Copy/Pasting

• Over documentation

66http://oig.hhs.gov/oei/reports/oei-01-11-00571.pdf

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EHR Liability Issues

● Cloning/Cut & Paste

● Did/did not perform

• Dropdowns, templates, defaults, macros

● Pre‐populated templates

● Voice recognition issues

http://oig.hhs.gov/oei/reports/oei-01-11-00571.pdf 67



● Failure to check all areas of program for results

• Scanned data v. direct drop

● Improper or incomplete scanning by support staff

● Failure to check “paper chart” or “scanned chart”

● Changing the note

● Locking the note

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● Chart inconsistencies

• History

• Exam

● Failure to read office visit notes created

● Automatic acceptance of coding engine recommendation

● Automatic acceptance of modifier recommendation

● Lack of interoperability69


EHR Liability Issues Reasons for RAC Overbilling

AHA (November 2010). RAC TRAC Survey70

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EHR Liability IssuesBreach Notification Highlights

HHS Office for Civil Rights (2010) 71


Surgical Mystery

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Where’s the HPI?

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Where’s the appropriate exam?

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Voice Recognition Error

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Voice Recognition Error

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EHR Risk Protection Strategies

● Develop a process to use EHRs to evaluate patients

● Be careful

● Take your time

● Read what you typed, dictated &/or clicked

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Risk Protection Strategies

● Stay in contact with administration & leadership re: time demands and necessary support

● Stay in contact with IT and trainers &/or super users

● Cooperate and support the Compliance Team

● Offer and take constructive criticism

● DO NOT FORGET THE PATIENT

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PPACA and

Physician Risk Education

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Areas of Risk Exposure● Medical Record Documentation

● Informed Consent Deficiencies

● Inadequate Patient Education

● Poor Physician‐Patient Communication

● Poor Physician‐Physician‐Nurse Communication

● Lack of Medical Necessity for Performed Medical Services

● Improper Performance of Medical Services/Care80

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Areas of Risk Exposure

● Overutilization or Unusual Utilization Triggers Investigation

● Investigation Leads to Publicity

● Investigations Lead to Medical Malpractice Suits

● Hospital / Physician Arrangements At Risk

● Hospital Survival At Risk

● Physician License At Risk

81Moses RE, Chaitt MM, Jones DS. JHCC 2013;15:35-40.


Risk Education Resources: CPGs● General Professional Organizations

• American College of Physicians

• American College of Surgeons

● Specialty Organizations Examples• www.gi.org (American College of Gastroenterology)

• www.gastro.org (American Gastroenterological Association)

• www.aasld.org (American Association for the Study of Liver Disease)

● U.S. Department of Health and Human Services• www.guidelines.gov

● www.google.com

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COMBINING COMPLIANCE, QUALITY OF CARE, RISK MANAGEMENT, &

MEDICAL MALPRACTICE

Building the Compliance Program of the Future

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INTERDISCIPLINARITY

● No one discipline can accomplish compliance

● Integration between compliance disciplines is necessary

● Interdisciplinarity uses integration to produce a cognitive advancement resulting in a positive and productive outcome

84

Repko AF. Interdisciplinary Research: Process & Theory. 2nd ed. Sage Publications Inc. 2012

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INTERDISCIPLINARITYPPACA

● PPACA INTERDISCIPLINARITY• Electronic Medical and Health Records

• Quality of Care Reporting

• Risk Management

• Medical Error Reduction

• Medical Error Disclosure

• Self Disclosure of Overbilling

• Patient–Staff–Physician Communications and Portals

• Quality of Care Violations/Medical Malpractice

• Physician/Medical Practice Management

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INTERSECTION: Compliance, Quality, Fraud, & Malpractice

● Government Accountability Office (GAO)• “…beneficiaries…who receive healthcare from providers who adhere to

PPACA…may receive higher quality of care…Conversely, those who receive care from providers who fail to do so may receive lower quality of care.…it is possible that, if these (PPACA) standards and guidelines become accepted medical practice, they could impact the standard of care against which provider conduct is assessed in medical malpractice litigation.”

86www.gao.gov/assests/590/589657.pdf

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Preventing Never Events

● §5001(c) of the Deficit Reduction Act of 2005 (DRA)

• Never events are not reimbursable by CMS

• Hospital Acquired Conditions (HAC’S) not reimbursable

• Implemented

Medicare 2008

Medicaid 2011

States July 2012

87www.cms.gov/Regulations-and-Guidance/Legislation/LegislativeUpdate/Downloads/Dra.pdf


Creating the Compliance Culture for the Future

● Create a Just Culture

● Create a Culture of Responsibility

● Create a Reporting Culture

● Create a Systems Culture

● Create a Quality Culture

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CONCLUSIONS &

SUMMARY

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D. Scott Jones, CHC ● Senior VP Claims, Risk Management &

Corporate Compliance – HPIX

● Leads a team managing over 700 malpractice claims

● Compliance, Risk and Claims for 3600 providers

● Former medical practice & hospital administrator

● Board Certified Healthcare Compliance Officer (CHC)

● Author, 12 nationally published books and over 50 articles on quality, practice management, and regulatory compliance

● Frequent speaker to state, regional and national organizations

● Over 1000 risk assessment service visits to healthcare organizations nationwide

● sjones@hpix‐ins.com (904) 294.563390

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Richard E. Moses, D.O., J.D.● Practicing Gastroenterologist for over 30 years

● Board Certified:

● Gastroenterology

● Internal Medicine

● Forensic Medicine

● Adjunct Assistant Clinical Professor, Temple University School of Medicine

● Adjunct Professor of Law, Temple University Beasley School of Law

● Physician Advisor Healthcare Providers Insurance Exchange

● National Speaker, Author and Consultant on Medical, Risk and Compliance education

● [email protected] (215) 742‐990091


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Presented byHealth Care Compliance Association19th ANNUAL COMPLIANCE INSTITUTE

Disney Swan & Dolphin Resort Lake Buena Vista, Florida

April 19‐22, 2015

Thank You

Documents

P5.ppt - HCCA Official Site · Physician Perspective: Clinical Practice Guidelines and ... PPACA and Clinical Practice Guidelines PPACA and EHR: Risks, Benefits, & Complications PPACA