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At the April 11 communications meeting Ms. Reece Smith, Medical Center compliance officer, reported on MUSC’s institutional compliance agreement with the federal Office of the Inspector General (OIG) of the Department of Health and Human Services. The agreement requires a significant amount of training, as described below, and the required “integrity obligations” will remain in effect until June 30, 2005.

The problems cited by the OIG occurred prior to 1997, before UMA and the Medical Center implemented a formal compliance program. The planning for our compliance program began in 1997 and the program (including the Compliance Policy, Code of Conduct, training and hotline) was implemented in 1998. The OIG uses the UMA and Medical Center compliance programs as the structure for implementing various provisions of the agreement.

It is very important that managers and employees involved in rendering medical care and in preparation of claims, as explained below, successfully complete the required training. Moreover, good documentation must be maintained of all training including names of attendees.

The penalty imposed by the OIG was stiff, although not as severe as some other teaching hospitals have experienced. We must take this matter very seriously and ensure that we follow through and fulfill all requirements of the agreement with the OIG.

At our April 18 communications meeting we will discuss with the managers plans for the Authority Paid Time Off (PTO) policy. It is requested that only managers and directors attend the meeting since our discussion will serve as an initial training session for managers. The April 25 communications meeting will include a follow-up discussion on PTO, and afterward departmental meetings concerning PTO will begin.

As previously communicated, no one will lose any accrued annual or sick leave. All accrued leave can transfer into the PTO plan.

Thank you very much.

W. Stuart Smith
Vice President for Clinical Operations and
Executive Director, MUSC Medical Center

OIG has more oversight over MUSC's, UMA activities

  • Reece Smith announced that as a result of the  billing lawsuit settlement, the Office of the Inspector General (OIG) now has more oversight over MUSC’s and UMA’s activities. As a result, while all MUSC Medical Center employees must complete a certain level of compliance training, a five-year institutional compliance agreement stipulates that all “clinical personnel who render medical services and personnel involved in the generation, preparation or submission (including documentation) of claims on behalf of MUSC” must complete two hours of general compliance training and two hours of billing training within the next 90 days. All Medical Center employees must complete the de’Medici compliance module.
  • The OIG will audit MUSC to determine if the provisions of the institutional compliance agreement are properly met. Fines will be levied if compliance training as required by the agreement is not completed on schedule.
  • Each manager will soon receive an E-mail asking for names of employees who may not be covered by the OIG training requirement as quoted above. Also, managers will be asked if they have provided any compliance training since October 1999 which may be credited toward part of the required training.
  • Additionally, within the next two weeks managers will receive a list of detailed instructions on completing and documenting this training. Each manager will be responsible for ensuring that employees receive the required training. This will be a labor intensive undertaking and everyone’s cooperation is needed to avoid penalties. If you have any questions please call the Compliance Office at 792-6128.
  • Smith also announced that the final regulations for ambulatory payment classifications were recently published. MUSC is putting together a committee to address the regulations, which take effect July 1.
de’Medici
  • Mary Allen, R.N., coordinator of Environment of Care,  with assistance from Neil Black, CCIT, and Mary Grady, statistical analyst, gave an overview of how to access de’Medici educational programs. De’Medici is available on MUSC Medical Center computers and at the MUSC library. If the computer you are using does not have the de’Medici icon, you can access the program through the MUSC web site at http://demedici.musc.edu/tweb20/index.cfm.  If you have a Point-to-Point Protocol (PPP) account with MUSC, you can access de’Medici from your home computer. Once online, you can reach de’Medici through the MUSC web site.
  • Programs have been reviewed and revised for content and ease of use. Staff should complete their annual educational requirements now for 2000. Once program agendas have been completed, individuals can print their reports from the report tool on the main menu. Reporting features are being customized so that managers can pull up a master list of their employees and program completion data.
  • The following de’Medici mandatories are available online: blood borne pathogens (AIDS and hepatitis), infection prevention, back safety, electrical safety, fire safety, hazardous materials, disaster preparedness, violence in the workplace, corporate compliance, radiation safety (mandatory for those who work in areas where a radiation badge is needed), cytotoxic drugs (for those areas where chemotherapy is prepared or administered), age-specific competencies and latex allergy (should be done during orientation or as needed). CPR reviews, TB, patient rights, customer service, ergonomics, and restraints and restraint reduction are left to the discretion of the manager.


Customer Service Survey for Managers 

  • Joan Herbert, administrator for the Institute of Psychiatry, announced that the Customer Service Tactical Planning Group will distribute a survey to managers and directors. Managers and directors should print the survey, complete it and make two copies—one for their files, and one to be given to their director or administrator by April 21.