Annals of Health Law
READY OR NOT
to varying extents and from different perspectives with the quality
mission.257 The health care reform agenda involves efforts to transition our
fragmented care delivery system to an efficient, well-integrated delivery
model.258 Operating in “silos” threatens to prevent hospitals from
delivering coordinated care that is necessary to meet quality and cost
demands of reform.259 The OIG Chief Counsel Lewis Morris has eschewed
the “siloing of responsibility” and underscored the importance of “the
different components of a health care organization need[ing] to
communicate and exchange information with each other.”260 If it is not
feasible to combine these departments, compliance professionals should
consider seizing upon the opportunity to facilitate greater collaboration to
accomplish objectives related to quality improvement.261 VBP reforms
could greatly benefit from departmental collaboration, under the leadership
of compliance professionals, as the new payment model undoubtedly
depends on coordinated care to reach its quality improvement potential.
B. Compliance Role in Quality Data Management
Several of Levinson’s directives urge compliance professionals to be
involved in the data management aspects of their VBP program. For
example, he suggested that compliance departments ensure that the
organization’s system for charting, collecting and reporting quality data and
clinical documentation is accurate, complete and justifies payment.262
Moreover, he asked if hospitals are using data mining and other techniques
to detect improper claims.263 The message is clear that the marriage of
payment and quality under VBP now requires that compliance monitoring
reach into the unchartered compliance territories of patient outcomes and
257. See id.
258. Sabrina Rodak, Breaking Down Silos to Improve Patient Flow, Hospital Efficiency,
BECKER’S HOSPITAL REVIEW (Mar. 12, 2012), available at http://
260. Anderson & Nedza, supra note 8, (quoting Lewis Morris, Chief Counsel to the
See Jones, supra note 255.
See COMPLIANCE REPORT, supra note 250.