Ensuring Integrity and Trust at VA Nebraska-Western Iowa Health Care System

Karen Bartholomew is the Chief Integrity and Compliance Officer for VA NWIHCS. In this position, she is responsible for maintaining the organization's integrity and trust through a combination of rigorous assessments, policy clarifications, and ethical oversight. 

Bartholomew's role is integral to the VA NWIHCS's mission of building trust and ensuring resources are used appropriately. 

"My role is to help build Veteran trust with the VA by ensuring internal controls are in place to use our resources as they are intended, for our Veterans and Veteran’s programs," she said. Additionally, she provides an avenue for Veterans, their family members, and VA staff to report and investigate those concerns transparently and without bias.

It's often a huge job. It’s also a job that Bartholomew feels she is particularly well-suited for.

"I previously was chief of Non-VA Care (now called Care in the Community), and we had recently gone through the Veterans Choice implementation," she said. "I became interested in the compliance position when it opened because I worked with the compliance officer in creating action plans for deficiencies in inpatient payment audits that were conducted in our service line."

The opportunity to learn and develop relationships with other areas in the VA and being part of improvement processes significantly influenced her decision. "I liked the idea of being able to learn and develop relationships with other areas in the VA as related to compliance, following guidance and policy, and being part of improvement processes," says Bartholomew. Bartholomew said she finds great fulfillment in serving Veterans and being part of a military-related community. 

"I am a spouse to a retired Navy Chief Petty Officer, and I have worked in and around Naval bases in Norfolk (VA), Mayport/Jacksonville (FL), Sicily, Omaha, and England," she said. 

Her connection to the military community drives her commitment to serving Veterans. "My Grandfather was a Purple Heart World War II Veteran who received his care at the Grand Island VA until he passed away in the late 1990s. I want to serve the Veterans as I would my own family.”

Bartholomew's typical day is a blend of addressing various inquiries and conducting detailed audits. "Typically, my day as Chief Integrity and Compliance Officer is answering inquiries and concerns that revolve around policy clarifications, Conflict of Interest concerns, and the occasional allegation of wrongdoing," she said. These allegations often require face-to-face interviews for fact-finding investigations.

In addition to handling these concerns, Bartholomew is deeply involved in auditing and reviewing revenue and funding processes, erroneous co-pay billing to Veterans, and potential separation of duty violations. It’s a job that requires an amazing level of policy awareness, attention to detail and the ability to develop relationships and work well with others.

"Most recently, I have been ensuring we are following the directive regarding background checks for contractors," she said. Bartholomew also assists the VA’s Office of General Counsel Ethics Specialty Team (EST) in responding to less complex Government Ethics questions about the Standards of Ethical Conduct for Federal Employees.

Among her many roles, Bartholomew is particularly proud of her contributions as the program officer for Health Care Ethics. 

"In this role, I provide education and administrative support to our Health Care Ethics Consultation Service," she said. 

One of the key initiatives she has spearheaded is the Health Care Ethics book club, which she has been facilitating since 2022."We currently are on a quarterly rotation of titles that cover anything from ethical boundaries with patients to Alzheimer and dementia-related topics talking about the patient’s right to choose how they want treatments or end-of-life care as well as bias and diversity in health care," she said. The book club started with around 20 participants and has grown to 70.

"I’m very proud of the growing interest in the book club. We’ve even had the opportunity to have one of the authors participate in our discussion," Bartholomew said.

Throughout her career, Bartholomew has achieved several notable milestones. She received her Certificate in Healthcare Compliance in 2017, OGC Ethics Advisor Training in 2022, and VA Law Enforcement Fact-Finding training also in 2022.  These qualifications have equipped her with the necessary skills and knowledge to carry out her responsibilities effectively.

Bartholomew acknowledges that her role comes with its fair share of challenges. 

"One of the biggest challenges is that people have a real fear in reporting non-compliance or wrongdoing," she said. 

To address this, she provides information and education regarding retaliation and whistleblowing protections to help ease that fear. "I want people to feel ‘heard’ and safe while building trust with them and organizational leadership to address the concerns appropriately," Bartholomew said.

Another challenge is the resistance she sometimes encounters from service areas or processes under audit. "The reviews or audits are supported by policy and, or, directives, and I default to the services to develop their action plans to reach compliance by providing policy guidance as a resource," she said. Building relationships and working collaboratively to reach common goals is a key strategy she employs.

"The audits conducted on the revenue side certainly can impact the Veterans financially. The audits are built to protect the Veterans from erroneous billings," she said. Further, investigating non-compliance, fraud, waste, or abuse makes the VA safer for Veterans and employees alike.

Another significant contribution is her oversight of the Insurance Capture Buffer (ICB) and Telephone Encounters. "Collecting third-party insurance from patients allows the VA to refund or cancel co-payments for that care when insurance pays," she said. This oversight helps prevent erroneous billing and ensures Veterans are not financially burdened due to administrative errors. Bartholomew hopes to be more widely recognized as a resource for identifying and mitigating organizational risks.