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1 Medical Group Compliance Auditing and Monitoring Effectiveness Michael Matsumoto, MD, FAAP, Assistant Physician-in Chief for Compliance, HR, Risk, Patient Safety The Permanente Medical Group Deidre Ramsey, MBA, BSN, CHC Managing Director, Regional TPMG Compliance The Permanente Medical Group 1 October 13, 2014 9:30 – 10:30 a.m. 2 Provide an overview of Kaiser Permanente’s structure Describe the audit program and the role of the Physician for Compliance in completing audits Outline operational steps used to develop the audit plan and metrics Understand the Physician for Compliance role at the medical center Learning Objectives

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Page 1: Medical Group Compliance Auditing and Monitoring Effectiveness · 2014. 10. 2. · Medical Group Compliance Auditing and Monitoring Effectiveness Michael Matsumoto, MD, FAAP, Assistant

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Medical Group Compliance Auditing and Monitoring Effectiveness

Michael Matsumoto, MD, FAAP,Assistant Physician-in Chief for Compliance, HR, Risk, Patient SafetyThe Permanente Medical GroupDeidre Ramsey, MBA, BSN, CHCManaging Director, Regional TPMG ComplianceThe Permanente Medical Group

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October 13, 20149:30 – 10:30 a.m.

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Provide an overview of Kaiser Permanente’s structure

Describe the audit program and the role of the Physician for Compliance in completing audits

Outline operational steps used to develop the audit plan and metrics

Understand the Physician for Compliance role at the medical center

Learning Objectives

Page 2: Medical Group Compliance Auditing and Monitoring Effectiveness · 2014. 10. 2. · Medical Group Compliance Auditing and Monitoring Effectiveness Michael Matsumoto, MD, FAAP, Assistant

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Our Story of Collaboration

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Who We Are

The Audit Program

Physician Leadership

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History of Kaiser Permanente

Kaiser Permanente’s Integrated Delivery System

Regional Compliance Reporting Structure

TPMG Compliance Program Structure

Who We Are

Page 3: Medical Group Compliance Auditing and Monitoring Effectiveness · 2014. 10. 2. · Medical Group Compliance Auditing and Monitoring Effectiveness Michael Matsumoto, MD, FAAP, Assistant

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Who We AreDr. Sidney Garfield’s “Dream of Healthcare for all Americans”

Who We Are

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Kaiser Permanente Integrated Delivery System

Kaiser Foundation Health Plan

(KFHP)

Kaiser Foundation

Hospitals(KFH)

The Permanente

Medical Group (TPMG)

Page 4: Medical Group Compliance Auditing and Monitoring Effectiveness · 2014. 10. 2. · Medical Group Compliance Auditing and Monitoring Effectiveness Michael Matsumoto, MD, FAAP, Assistant

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Who We Are

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Regional Compliance Organizational Reporting Structure

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The Audit Program

Conducting a Risk Assessment

TPMG Compliance Audit Plan

TPMG Compliance Work Plan

Monitoring and Auditing

Page 5: Medical Group Compliance Auditing and Monitoring Effectiveness · 2014. 10. 2. · Medical Group Compliance Auditing and Monitoring Effectiveness Michael Matsumoto, MD, FAAP, Assistant

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Step 1:

Develop a Risk Assessment

Tool

Step 1:

Develop a Risk Assessment

Tool

2. Survey Stakeholders

2. Survey Stakeholders

3. Collect Survey Results

3. Collect Survey Results

4. Analyze Survey Results

4. Analyze Survey Results

5. Review Legislation, National and

Regional Compliance

Risks

5. Review Legislation, National and

Regional Compliance

Risks

6. Prioritize the Results6. Prioritize the Results

The Audit ProgramConducting A Risk Assessment

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Step 7:Review

Prioritized Risks with

Stakeholders

Step 7:Review

Prioritized Risks with

Stakeholders

8. Develop a Risk Profile for

Each Risk

8. Develop a Risk Profile for

Each Risk

9. Develop a Work Plan and an Audit Plan

9. Develop a Work Plan and an Audit Plan

10. Communicate Highest Risks

to TPMG Leaders and

ECC

10. Communicate Highest Risks

to TPMG Leaders and

ECC

11. Communicate

Risks to Stakeholders in Work Plan

and Audit Plan

11. Communicate

Risks to Stakeholders in Work Plan

and Audit Plan

The Audit ProgramConducting A Risk Assessment

Page 6: Medical Group Compliance Auditing and Monitoring Effectiveness · 2014. 10. 2. · Medical Group Compliance Auditing and Monitoring Effectiveness Michael Matsumoto, MD, FAAP, Assistant

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Developed from High Risks

Audits Performed by Audit Staff

Audit Results Reported to• TPMG Executive Sponsors• Medical Centers• TPMG Board

The Audit ProgramTPMG Compliance Audit Plan

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Monitoring• Department Managers/

Chiefs Review Reports

Auditing• Outside of the Department• Formal Structured Process

The Audit ProgramMonitoring and Auditing

Page 7: Medical Group Compliance Auditing and Monitoring Effectiveness · 2014. 10. 2. · Medical Group Compliance Auditing and Monitoring Effectiveness Michael Matsumoto, MD, FAAP, Assistant

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Developed Annually

Based on Survey Risks

Revise Plan as Necessary

The Audit ProgramTPMG Compliance Work Plan

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Physician Leadership

Compliance Committee Membership

Role of Physician for Compliance

Leading Compliance

Creating the Culture

Page 8: Medical Group Compliance Auditing and Monitoring Effectiveness · 2014. 10. 2. · Medical Group Compliance Auditing and Monitoring Effectiveness Michael Matsumoto, MD, FAAP, Assistant

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Physician LeadershipCompliance Committee Membership

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Leads TPMG Compliance Co-Chairs the Compliance

Committee Ensures Training for Physicians Provides Oversight for

Monitoring and Auditing

Physician LeadershipRole of Physician for Compliance

Page 9: Medical Group Compliance Auditing and Monitoring Effectiveness · 2014. 10. 2. · Medical Group Compliance Auditing and Monitoring Effectiveness Michael Matsumoto, MD, FAAP, Assistant

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Physician LeadershipLeading Compliance

Collaborate with Medical Center Leaders

Assess and Mitigate Compliance Risks

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Address Physician and Medical Group compliance issues

Interact with Leaders across the program

Model “modern” compliance in all venues

Physician LeadershipCreating the Culture

Page 10: Medical Group Compliance Auditing and Monitoring Effectiveness · 2014. 10. 2. · Medical Group Compliance Auditing and Monitoring Effectiveness Michael Matsumoto, MD, FAAP, Assistant

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Included on TPMG Compliance Wiki: Audit results for Leaders (password protected) Links to important internal and external resources Contact lists for compliance questions Training links

TPMG Compliance Wiki

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Questions

Contact Information:

Michael Matsumoto, [email protected]

Deidre Ramsey [email protected]

Page 11: Medical Group Compliance Auditing and Monitoring Effectiveness · 2014. 10. 2. · Medical Group Compliance Auditing and Monitoring Effectiveness Michael Matsumoto, MD, FAAP, Assistant

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Appendix

Physician for Compliance Role Description 1

Regional TPMG Compliance Audit Plan 3

Regional TPMG Compliance Work Plan 4

Individual Medical Center Audit Results 5

Audit Executive Summary 6

Annual Audit Results 7

Physician for Compliance Role Description

Appendix 1

1. Compliance Program Oversight

2. Train Physicians and Employees

Co-Chair and attend the Medical Center Compliance Committee Meetings.

Participate on other committees addressing compliance issues as needed.

Ensure that TPMG department auditing results and corrective action plans, as needed, are submitted to the Medical Center Compliance Committee, reviewed and discussed with the appropriate action taken.

Provide leadership, resolve issues locally and report systemic problems or unresolved issues to Regional TPMG Compliance.

Provide consultation on compliance issues.

3. Standards of Conduct/Policies and

Procedures

Principles of Responsibility is supplemented by the TPMG Physician Policy Manual.

Ensure Regionally-approved policies are adopted locally, as needed.

Ensure that policies and procedures are updated and followed or modified as needed.

Ensure staff and physicians receive all appropriate compliance training (general as well as specialized).

Deploy required annual Physician Compliance Training.

Conduct the in person Physicians for Compliance training at the Medical Center sites.

Participate in the development and modification of the annual Physicians for Compliance training.

Page 12: Medical Group Compliance Auditing and Monitoring Effectiveness · 2014. 10. 2. · Medical Group Compliance Auditing and Monitoring Effectiveness Michael Matsumoto, MD, FAAP, Assistant

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4. Perform Monitoring and Auditing

5. Reporting and Investigation

• Encourage staff and physicians to first report concerns or questions to their manager and chief, working their way up to the next level of management, as necessary.

• Physicians and staff have access to the compliance hotline which is answered 24 hours a day.

• Work with Physician HR and Compliance as appropriate in investigating complaints.

Performance Monitoring/Risk Assessment Annually evaluate the effectiveness of the

medical center compliance program with the Service Area Compliance and Privacy Officer.

Conduct risk assessments at the Medical Center, as needed.

Actively participate in the annual TPMG Compliance Risk Assessment.

Escalate compliance issues to the Medical Center Compliance Committee when remediation is ineffective.

Prepare for survey readiness by: Reviewing department monitoring Ensuring training and competencies are

completedAuditing Ensure that audits are completed and results

reported timely to the Medical Center Compliance Committee and Regional TPMG Compliance as needed.

Review auditing results from departments and ensure timely completion of corrective action plans.

6. Taking Corrective Action

• Facilitate resolution of compliance issues.• Work with the Service Area Compliance & Privacy Officer to ensure consistency of

policy interpretation.• Work with the Physician Human Resource Consultant (PHRC) to ensure all

investigations and resolutions are communicated to the PIC• Ensure that discipline is fair and consistent

Review, approve and ensure the timely completion of Corrective Action Plans, as described in the annual Regional TPMG Compliance Audit Plan and Work Plan; and other CAPs impacting TPMG as directed.

7. Enforcement and Discipline

Physician for Compliance Role Description

Example3

2014 Regional TPMG Compliance Audit Plan

Page 13: Medical Group Compliance Auditing and Monitoring Effectiveness · 2014. 10. 2. · Medical Group Compliance Auditing and Monitoring Effectiveness Michael Matsumoto, MD, FAAP, Assistant

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Example4

2014 Regional TPMG Compliance Work Plan

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Individual Medical Center Results

Page 14: Medical Group Compliance Auditing and Monitoring Effectiveness · 2014. 10. 2. · Medical Group Compliance Auditing and Monitoring Effectiveness Michael Matsumoto, MD, FAAP, Assistant

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6

Audit Executive Summary

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Annual Audit Results