By Marlin Martin, SVP of Regulatory Affairs/Program Sponsor
“The Compliance Department is not the department of ‘no.’ It’s the department of ‘know’.’”
Roy Snell
This wise, simple statement by Roy Snell, cofounder and former CEO of the Health Care Compliance Association and the Society of Corporate Compliance and Ethics, sums up best what our compliance team is all about. In today’s constantly-changing and increasingly-complicated healthcare regulatory environment, leaders and organizations are under more scrutiny than ever. That’s why BHG enlisted Ankura, a global consulting firm with deep healthcare experience, to assess the effectiveness of our already-strengthened Compliance Program so that we can continue to save lives by proactively maintaining efficient, ethical, quality care and operations – not just for BHG patients, but for all patients. Together, we are building a best-in-class Compliance Program that is influencing our industry.
As BHG continues to grow, add third-party payors into the mix and implements the new, highly-nuanced IDCM, all of us are having to know more and do more to prevent fraud, waste and abuse so that we can continue to restore lives, strengthen families and rejuvenate communities. As a social worker by training, I want people to do well and meet goals and I have to apply that mindset to our corporate culture. We must be a part of the solution to the crisis with accountability and responsibility, and a modern healthcare Compliance Program helps us do that.
What is compliance?
We have many new colleagues and some who are not yet deeply informed about compliance. To level set for us all, here’s a good explanation from “Compliance 101,” 4th edition by Debbie Troklus and Sheryl Vacca.
“On a very basic level, it is about prevention, detection, collaboration and enforcement. It is a system of policies, procedures and processes developed to assure compliance with and conformity to all applicable federal and state laws governing the organization. A compliance program should never be just a piece of paper or a binder on a shelf; it is not a quick fix to the latest hot problem; it should not be hollow words. A compliance program — an effective compliance program — must be an ongoing process, a part of the fabric of the organization, a commitment to an ethical way of conducting business, and a values-based system for doing the right thing.”
Ankura’s scope
To ensure BHG is operating in a manner that conforms to best practices and is effectively structured to address identified risks, Ankura has been working through a three-part review of our Compliance Program for the past couple of months. Their review process is designed to assess whether or not our effectiveness is consistent with the Federal Sentencing Guidelines for Organizations and relevant Department of Justice and OIG Compliance Program Guidance documents.
Phase I (complete): off-site compliance program document review
Phase 2 (complete): on-site (or virtual) 45-minute interviews with 33 key compliance BHG staff and board members
Phase 3 (in progress): analysis of our observations, report writing and recommendations based on Ankura’s findings.
We will make the report and recommendations available to you by the end of September or early October. You can look forward to an ongoing environment of trust and information sharing so that you know the direction we’re taking and attempts we’re making to build on our past success. The only way we can do this is by being open, transparent and sharing information with the entire organization.
Moving forward
I am so proud to work for an organization that is committed to being a good corporate citizen and whose people are dedicated to real recovery — not just to people getting sober, but through behavior modification and social support. It’s because we’ve been hyper-focused on compliance that we get to roll out exciting, new developments like IDCM. To keep us on the right path to leading the way in recovery, here’s our commitment:
Exceed standards. As we continue to focus on meeting people where they are in their recovery and providing more access to care, it’s extremely important to always meet and exceed compliance excellence. I’ve been in the field and done a lot of lobbying for Medicare and Medicaid as we’ve been moving from predominantly self-pay to third party. We’re now seeing the benefits of everything we’ve worked hard for to legitimize our gold standard of service.
Keep the big picture in mind. How we address the issues at hand and enforce our compliance culture throughout our organization and treatment centers is not just about the people we’re serving today. It’s about leading the way for what real recovery should be now and in the future. Our platform is built to look beyond just being in compliance. We want to be the standard. We want others in the industry to look at us and think, “They’re ethical and doing good work for our entire industry.”
Lead with transparency. Moving forward, we will do and publish an annual risk assessment and compliance work plan. We will always be looking for ways to refine and do things better and keeping you informed every step of the way.
Please reach out to me any time if you have ideas, questions or concerns. Thank you for all that you do to help us cultivate a best-in-class culture of compliance.
