A Day in the life of the Medicare Compliance Officer

March 19, 2012
|In Compliance
|By GHG Advisors

You have so many requirements to follow. You are charged with the interpretation and distribution of the ever-present stream of HPMS memoranda. Operational leadership does not always understand that you can give them the requirements, interpret the requirements, but it’s up to them to implement for success. Implementation takes time, often leaving employees performing manual, error-prone tasks until something can be automated. And of course, without automation, the documentation is difficult to find upon CMS request.

So begins another day in the life of the Medicare Compliance Officer: ever-changing, often thankless, and never boring. Sound familiar? In my last post, I mentioned the SCCE/HCCA joint survey on stress, compliance and ethics –take a look. The results should not be too surprising to those in the day-to-day.

Compliance Officers (and their staff) hear so many reasons for not fulfilling compliance obligations:

• We don’t agree with your interpretation
• We’ve never been cited for it before
• Our competitors do it so why can’t we
• It’s not in our budget

Talk about stress! Many Medicare Compliance Officers that I have worked with find themselves at one of two ends of a spectrum: so embedded in operational decisions that their role is often blurred, or completely carved out of the loop — isolated as demonstrated in the survey results. It is no small task to cultivate and maintain the relationships with operations to fall right in the middle.

For those who find themselves over-involved in operations, a line must be drawn. Often times, the Medicare Compliance Officer is party to decision-making in favor of non-compliant practices. To request concurrence from him or her on something which results in non-compliance is a major stressor to anyone charged with maintaining the relationship between the organization and the CMS account manager. The fact is, a blessing from the Medicare Compliance Officer does not make a wrong a right, so break the cycle if it exists in your organization.