Knowing whether or when to launch an internal investigation into compliance issues can be intimidating and confusing. Is it necessary? Who should conduct the investigation? How do you attack the problem in the most efficient, least disruptive, and most cost effective way? How do you know you’ve done a thorough job of identifying all the variables that created the problem?

The following ten-step approach asks basic questions and provides tips that should help guide you in making the right decisions. The key factors are based on the volume of the problem, the duration (pattern), the dollars involved, the scope, intent, and the level of risk to your organization or company. This approach applies whether you are the largest company or an owner who wears all the hats.

1. When is an investigation called for?

To determine the answer, ask yourself these questions:
* Is the allegation credible?
* Is this a simple error or misconduct? To understand the magnitude of the problem, determine your best estimate of the variables specified in the allegation.
* Is the problem a system wide failure or isolated to one area?
* What is the level of risk? Are there overpayments involved?
* Is this a repeat problem?
* Do you or the client currently have a Corporate Integrity Agreement (CIA)?
* Are there significant obstacles to the investigation beyond your control? For example, must you collaborate with other entities?

If you determine the allegation is credible and the problem is due to misconduct, a system-wide failure, or a recurrent problem or a pattern, or if it involves high dollars and/or long duration, then your answer is yes. Any or all of these elements call for an investigation. In addition, any entity or individual with a CIA must adhere to the conditions and thus an investigation is probably mandated.

2. Should the investigation be conducted in-house or with outside resources?

If your answer to any of the questions could undermine the credibility of your investigation, or your company’s viability is contingent on the outcome, independent experts with demonstrated expertise are indicated.
* Does the investigation require detailed, specialized knowledge?
* Do you have a conflict of interest?

It only takes a moment to plant a seed and then with the seed planted to the right depth, watered the right amount, and cultivated when necessary, a beautiful plant grows. Mentoring people works the same way. Do you take the time to mentor your employees?

I have always liked to watch my staff grow and develop. Giving them the ability to grow and reach new heights in their development makes me very proud of their accomplishments. If you don’t mentor and set reachable goals you become stagnate and complacent. Don’t be afraid to sit back and wait for the growth to start and then watch as it reaches new heights and becomes something it didn’t think it could. That is what a good owner/manager does. We develop people into what they can be and give them the chance to succeed as we watch them with enjoyment and pride.

• Spring HBMA Meeting—Orlando (April 6-8)
• IMGMA/IARHC Spring Conference Gateway Hotel Ames, Iowa (May 14-16)
• HealthMed, Inc In Service with David Jakielo (May 20-21)
• Fall HBMA Meeting—San Diego Paradise Point (Sept 10-12)

I have just returned from my fourth trip to India where I was conducting leadership and customer service seminars for managers and associates in various companies. Although I was half way around the world, the issues facing businesses in India are similar to the challenges we face here at home.

You might think that there are huge cultural differences between the two countries; however, both employees and customers in India have expectations similar to Americans. In both places, how well those expectations are met determines our success. Employees have a desire for:

* Open communications (being in the loop)
* Recognition for work well done (objective not subjective measures)
* Opportunity for advancement (if that is one of their goals)
* Continuous training (so they can improve their skill sets)
Let us expand upon the above observations.

Open communications: Many times I hear from employees that no one ever tells them what’s going on in the company. As leaders we are usually privy to what is happening. Unfortunately, we often forget that the team around us would like to be in the know, too. Keep in mind there is no such thing as excessive communication. Staff members have a desire to belong and putting them in the loop not only gives them a sense of importance, it promotes buy-in and loyalty.

Venues for communication can include regular staff meetings, email blasts, company newsletter and even informal chats.

Opportunity for advancement. A chance to move up the ladder is crucial for some employees. However, keep in mind that not every employee is a hard-driving type-A personality striving to get ahead. There is nothing wrong with a staff member who just wants to do an excellent job with his or her assigned tasks. Not everyone pines for a leadership position that makes them responsible for others; for some folks, advancement simply means learning additional job functions that they may hot be interested in. The most successful companies not only provide their employees with regular performance reviews, but also hold career counseling sessions to ensure the employees’ needs are being met. Rest assured, if you can’t meet their needs, your employees will look elsewhere.

Continuous training. This is a crucial factor in creating employee satisfaction. In today’s environment, technology and information is changing at a pace more rapidly than ever before. I’ve read that most of what college freshmen learn in their first year of college is outdated by the time they graduate. Your staff must have the ability to keep their skill sets up to date and fresh. This can be accomplished by outside or in-house seminars, distance learning via the web, industry conferences, etc.

Allowing a team member to obtain a specific certification that will enhance their career is always a good investment, and if his or her position—e.g. data entry—doesn’t have a certification program, create your own. You could establish a position in your company called “Certified Data Entry Clerk.” An employee who meets the criteria and is awarded a title will have pride in his or her job.

The key to any successful company, regardless of location, is to attract and retain valuable employees. If you cannot find them, you will need to develop your own. The bottom line is that when you do not treat your team members as well as you treat your most important customer, you will end up without neither customers nor employees.

David Jakielo, CHBME, is an international speaker, consultant, executive coach, and author, and is president of Seminars & Consulting. Sign up for his FREE weekly Success Tips at www.Davespeaks.com. Dave can be reached via email at Dave@Davespeaks.com; or by phone 412-921-0976

Handling Harassment in the Workplace
Rod Mestdagh, Partner HMI

There are definite steps an employer can take to successfully handle the issue of harassment. While nothing can prevent one person from engaging in harassing conduct against another, much can be done to control the situation when it arises and greatly reduce or eliminate the employer’s liability.

The following are steps that every employer should take:

* Education
* Establish a Company Policy Prohibiting Harassment.
* Have a Written Harassment Policy
* Review the Policy Annually
* Take Harassment Seriously
* If Sued, Defend Yourself

An employer with an effective harassment policy in place that is actually followed has an excellent chance of coming out of any harassment case in relatively good shape. The court may find that such an employer is not liable because they followed all guidelines allowed by law to prohibit such practices.

If you are following the above guidelines and making sure your staff knows the rules and the consequences for engaging in bad conduct you should be well prepared and trained for keeping this out of your offices.

SGR problem gets a Band-Aid, not a Cure

Faced with the prospects of failing to pass the legislation necessary to prevent a 10.1% cut in the physician fee schedule, Congress opted for a temporary fix to the problem rather than a solution. As in past years, Congress chose to put off long-term solution to the SGR problem; however, unlike prior years where the “patch” last a full year, this year’s patch is only for 6 months.

The failure of Congress to resolve the Medicare Sustainable Growth Rate problem for the entire year means that Congress will have to develop a more long-term solution by the end of June. Furthermore, that “solution” will also have to address the looming 15% related SGR cut that is projected for 1-1-09 because there will not be a time later in 2008 to deal with that financial Armageddon. Instead of a 10.1% cut, Congress approved a .5% increase in the Medicare Fee Schedule conversion factor. However, the cut was not eliminated but rather just postponed for 6 months. Also, the .5% increase is not permanent but again, only for 6 months.

Why Did My Physician’s payments go down?

We’ve been contacted about why certain physician payments went down, despite the fact that Congress intervened to prevent the 10.1% SGR cut and instead, authorized a .5% increase in the physician fee schedule conversion factor. In order to understand this conundrum, it is necessary to understand how the physician payment is derived. The actual payment Medicare sends to a physician for a particular service is derived from several factors. First, Medicare must determine the value of a service and to do this, the government looks at three factors: Physician Work Value, Practice Expense Value, Malpractice Expense Value. Each CPT code is assigned a point value that represents the total of these three factors. Once a value has been established it is then multiplied by the Medicare Conversion Factor to determine the reimbursement amount for the service. For 2008, The SGR formula dictated that CF go down by 10.1%. In lieu of that, Congress suspended the SGR reduction and instead, authorized a .5% increase in the CF. What Congress does not adjust was the various VALUES assigned to each code. For 2008, the physician work value and practice expense value for several codes were adjusted—some up and some down. If you work with physicians who does went down, your practice will experience net decrease despite the .5% increase in the Conversion Factor.