The document discusses several strategies for improving ethics and compliance at healthcare organizations, including forming an in-house ethics committee, designating an ethics officer, developing medical necessity guidelines, ensuring employees understand and adhere to codes of ethics, and consulting a public relations expert when issues arise. It also stresses the importance of maintaining positive employee relations through measures like regular performance evaluations, competitive pay, and addressing grievances. Unethical behavior threatens an organization's stakeholders and can have severe financial and community impacts.

1. By: Cynthia Brown, MBA, RHIT, CCS
Owner
CyntCoding Health Information Services

2.  Form
an in-house
Ethics Committee
with key personnel
as members.
 There should be an
ethics officer in
place who has an
open door policy
and who is a
member of the
committee.

3. The role of an ethics committee was solidified in
1992 when the JCAHO mandated healthcare
organizations to develop ways to address ethical
issues in their facilities (AMA, 2008). Therefore,
if for no other reason than it will be an essential
requirement of JCAHO accreditation, your
organization would benefit greatly from the
development, implementation, and monitoring
of an in-house ethics committee. An effective
ethics committee can oversee matters involving
the false filing of claims, misleading coding, and
other financial issues of reimbursement to the
facility.

4.  Employee
Relations
is essential to
maintain a positive
and productive work
environment.
 An Employee
Relations Manager
should be included
as one of the
positions in the HR
department.

5. 
An Employee
Relations Manager
(ERM) would ensure
that there is regular
feedback between
staff and
management; which
would include
performance
evaluations and rate
of pay evaluations.


A period salary
comparison should be
made by the ERM to
ensure job rates meet
the industry standards.
An ERM working along
with a HR director,
management,
employees, and other
key personnel can help
to foresee, advise, and
resolve employee
conflicts with
management.

6. “Employee Relations involve the body of work
concerned with maintaining employer-employee
relationships which contribute to satisfactory
productivity, motivation, and morale (NASA,
2009).” Essentially, Employee Relations is
concerned with preventing and solving problems
involving individuals which arise out of or affect
work situations (NASA, 2009). Along with
providing a means of evaluating employee
performances, employee relations can be a
mechanism for solving employees issues, such as
pay increases and other grievances before they
arise.

7. Medical Necessity
Guidelines should
be developed and
implemented with a
plan in place that
ensures checks and
balances for “best
practices” and
“medical necessity”
for each inpatient
and outpatient stay
or visit to the
facility.

8. Medical necessity is
“healthcare services
that a Physician,
exercising prudent
clinical judgment,
would provide to a
patient for the
purpose of
evaluating, diagnosing
or treating an illness,
injury, disease or its
symptoms (CIGNA,
2011).”

9. The seriousness of fines, loss of reputation,
and loss of revenue through accrediting
agencies should be enough justification to
develop, implement, and monitor Medical
Necessity Guidelines. Medical Necessity
Guidelines can help to eliminate unnecessary
medical care whether intentional or
unintentional. It helps the facility meet its
“best practices” doctrine, because it makes
the provider look at the type of care they
provide. Of course, what is deemed
necessary must meet other standards set
forth by third party payors and legislation.

10. The Company should
not just have a
“Code of Ethics” in
place it should
ensure that each
employee no matter
their position knows
what it entails and
how to respond
when it is not being
adhered to.

11. The facility should
instigate
community
involvement
demonstrating the
company’s
intentions to
regain trust and
move forward with
a sincere desire to
operate ethically.

12. The violators of any
of the legal issues
adopted by the
facility should be
prosecuted and the
community and
investors alike
should be made
aware that
unethical behavior
at the facility has a
zero tolerance.

13. The Company
should also
demonstrate its
strategic plans to
improve in the
services provided
through quality
assurance,
performance
evaluations, and
peer review.

14. Lastly, a Public
Relations expert
should be
consulted.

15. When a company is publicly traded it has a
responsibility to its shareholders to operate in a
manner that does not put the dollars invested at
risk. Unethical behavior is definitely a threat to
shareholders’ investment. There are also other
major stakeholders who stand to lose when a
company is no longer soluble (i.e., employees,
suppliers, patients, and the community as a
whole). The loss in employment and the
revenue dollars generated by the business is
irreplaceable. The opportunity for education for
the physician and healthcare providers is
invaluable. The void as a result of a facility’s
demise can be potentially crippling to
communities and the economy of the nation.

16.  Cynthia
Brown, MBA, RHIT, CCS
 AHIMA approved ICD-10 CM/PCS Trainer
 CyntCoding Health Information Services
 Phone: 404-992-8984/E-Fax: 678-805-4919
 P.O. Box 3019
 Decatur, GA 30031
cyntcoder@gmail.com or cyntcoder@aol.com
 www.cyntcodinghealthinformationservices.com


17. O’Reilly, K. (2008). Willing, but waiting: Hospitals
ethics committee. Retrieved December 13, 2013
from http:/www.amaassn.org/amednews/2008/01/28/prsa0128.htm.
NASA. (2009). Employee relations: What is
employee relations? Retrieved December 13,
2013 from
http:/ohcm.gsfc.nasa.gov/employee_relations/w
hatis.htm.
CIGNA. (2011). CIGNA Healthcare definition of
medical necessity for physicians. Retrieved
December 13, 2013 from
http:/www.cigna.com/health/provider/medical/
procedural/medical_necessity.html.