Brush up!

Four questions your physician orientation should answer but might not

Dan Fisher Consultant Answering these four questions during physician orientation will guard against business, quality, and compliance hazards. What are some key characteristics of the physicians’ new patient population(s)? The challenge: Population health – the buzzword of the decade. Payers are requiring physicians to demonstrate cultural competency in their medical decision making. Physicians need to know and understand their patient populations to diagnose health outcomes, recognize possible health determinants, and coordinate care with other providers (especially in a patient centered…

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A Note to Legal Counsel – Compliance Crisis Management

    Legal Counsel may benefit from a consultant’s assistance in a compliance crisis.  The following message explains how.  We are writing to you as a healthcare attorney to share how our unique consulting approach can help you represent your healthcare clients, particularly those facing a compliance crisis.  Our assistance in crisis scenarios facilitates fact development, client self-efficacy, corrective action planning and implementation, and optimizes compliance programs, while remaining cost-effective and aligned with your representation.  Notwithstanding rapid cycle changes and…

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Have You Considered Hiring a Compliance Operations Director?

Dan Fisher, MS Consultant In one striking, but less than obvious way, the Chief Compliance Officer (“CCO”) is the most unique member of the C-suite. The CCO is both a person and a named component of a program. [Way back] in the 1990’s, the US Sentencing Commission and the HHS OIGinstructed healthcare organizations to start compliance and ethics programs with seven (7) distinct components, in short: 1) Standards of Conduct, Policies & Procedures; 2) Compliance Hotline; 3) Audit and monitoring systems; 4) Disciplinary…

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Should NBC Have Hired an External Investigator in the Matt Lauer Matter?

I have watched the Today Show for longer than the 20 years that Matt Lauer was associated with it.  Throughout Lauer’s tenure there were persistent rumors in the entertainment press about his marital infidelity and sexual indiscretions.  Lauer was publicly fired on November 27, 2017 for engaging in sexually inappropriate behavior in the workplace.  After his firing, Sarah Ellison wrote in Vanity Fair that “Lauer had been dogged by stories of [his] infidelity for years” with female interns, bookers, and…

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History reminds us that the compliance program needs to reach every corner

History reminds us that the compliance program needs to reach every corner Dan Fisher The case US ex rel. Shindler v. Valley Tumor Medical Group, et al., CV 15-2249 is an archetype of a settlement that could have been prevented if  the defendant had maintained an effective compliance and ethics program that reached every corner of its organization – a program, which is two-fold: compliance and ethics. In the case of Valley Tumor Medical Group (VTMG), the issues underlying the…

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Welcome to Brush Up!

Welcome to Brush Up! IntraVires Health Compliance Consultants offer timely articles, commentary, and opportunities for discussion and dialog. We believe that brushing up can be most helpful to compliance professionals, their counsel, and operational leaders and their teams. Please browse through Brush Up! regularly to find interesting and thought provoking posts. We look forward to seeing you!

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Publicly positioning the compliance function may be Wells Fargo’s most important step to re-establish trust in 2018 

Publicly positioning the compliance function may be Wells Fargo’s most important step to re-establish trust in 2018  By Shelley C. Koltnow,  JD, MBA, FACHE  Principal Consultant, IntraVires Health Compliance Consultants  Wells Fargo’s new advertisement expresses its desire to be trustworthy.  Its tag line:  “Established 1852.  Re-established 2018.  With a recommitment to you.”    Will this work?  Wells Fargo lost substantial trust by the “unprecedented misconduct that lasted for years,”  the Federal Reserve Board of Governors said in 2017.   Indeed, for years, the bank’s endemic cultural deficiencies and misaligned incentive compensation program allowed misconduct to thrive.  The bank’s identified…

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