Little C to Big C
Compliance and business integrity, what do these terms mean?
We see them in action every day across VHA. They are schedulers who make appointments for Veterans and are careful to protect their privacy. They are Medical Center Directors who meticulously examine hospital spending to make sure tax dollars are never wasted. They are members of credentialing boards who carefully review the job applications and certifications of applying physicians to ensure they meet VA's high standards for medical providers.
At VHA, compliance and business integrity includes all of us. "We are all one team who take care of Veterans," says Shelly Hepler, Compliance Officer at the VA Medical Facility in Martinsburg, West Virginia. As Hepler describes, compliance and business integrity reflects the work of every employee at every level—from the housekeepers to medical directors—living out VA ICARE values in their daily work, showing patients and colleagues the meaning of integrity, commitment, advocacy, respect, and excellence.
Hepler works under VHA's Office of Compliance and Business Integrity (CBI), which is in the midst of a big transformation. When VHA stood up CBI in 1999, compliance was seen through a "little c" framework. This meant CBI was responsible for one key duty: fiscal oversight. CBI's bread and butter was assuring VA obtained third party insurance reimbursement from Veterans who had outside health insurance.
As of 2018, CBI began operating with a new "Big C" compliance model. "We now believe we should focus on the biggest legal risks to the agency," says Matt Tuchow, Chief Compliance Officer at VHA, Mr. Tuchow describes "Big C" compliance as a comprehensive framework for promoting integrity, not just in regard to insurance reimbursement, but focusing on any law or regulation where VHA's compliance may be a big concern.
"We want Veterans to choose VA for their health care," Tuchow says. "That means we must do everything we can to support VHA employees in being the law-abiding, ethical, compassionate, workforce that we are so Veterans trust they will receive the best care and treatment when they walk into our facilities."
"Whether you are a Red Coat volunteer, a physician, or an auditor, there are rules and regulations that apply to everyone's work," describes Tracy Davis Bradley, Deputy Chief Compliance and Business Integrity Officer at VHA. "Our role as compliance officers is to be the subject-matter experts on those laws and regulations so we can support employees in taking the right actions that ultimately reduce legal or regulatory risk to VHA," Davis Bradley adds.
Ultimately, "Big C" is also aimed at changing culture. "We want everyone at VHA to feel empowered to speak up," says Davis Bradley. She adds that it is not just reporting on situations where someone might be breaking the rules, but also feeling comfortable contacting the local compliance officer—in a proactive way—to see how their work can better comply with VHA's rules, regulations, and federal law.
"If we intend to deliver high-quality care and adopt the model of a high-reliability organization (HRO), we must immediately address any fear of reprisal among our workforce and work diligently to promote a just culture that embraces problem-solving, supports whistleblowers, and encourages proactive risk mitigation," Davis Bradley adds.
To help employees identify what legal and regulatory risks look like, as well as how and where to raise concerns and report violations, CBI created The VHA Code of Integrity as a comprehensive resource for VHA employees across all levels. "It's a one-stop-shop reference to figure out where to report concerns," says Matt Tuchow. "Whether it's a matter of quality, patient safety, patient privacy, or an issue related to fraud, waste, and abuse, all employees should feel protected in stepping forward, and this document is a great place to start," he adds.
To learn more about VHA's Office of Compliance and Business Integrity and their new "Big C" approach to compliance across the VHA enterprise, visit the CBI Intranet site. Also, if you have a concern about a potential breach of integrity and feel uncomfortable addressing it with your colleagues or supervisors, you can always speak with your local Compliance Officer or report it confidentially to the CBI HelpLine at 1-866-842-4357.