Corporate compliance plans in health care organizations: a top-down perspective

Recently, at an all-day professional meeting that was targeted at about 100 junior-level health care financial professionals, we covered a whole spectrum of subjects. We covered topics ranging from the Hill-Burton Act to Medicare managed care organizations (MCOs) and capitation; the Stark rules on physician self-referral; the financial incentives within various payment systems for physicians, hospitals, and other providers; Medicare fraud and abuse rules; and the need for well-designed corporate compliance plans. After responding to a number of the participants' questions, I could not help but be reminded of the students every semester who ask me, "Will this be on the test?" In other words, if there are no real teeth in the subject, then they have too many other urgent priorities demanding their attention to give the issue serious consideration. Perhaps this highlights the need for taking corporate compliance planning seriously--starting at the top levels of the organization. It is well documented that leadership attitudes filter downward in any organization. If change for the better is going to take place in the area of corporate compliance, it needs to begin with each of us as individuals, from the top down.