When a retired physician walked into Carilion Clinic in Roanoke, Va., to order an X-ray for his spouse, an employee immediately called the compliance hotline to ask whether it was appropriate to provide the service. After all, the physician was not affiliated with the clinic and the patient was a relative.

The clinic employee had good instincts. Physician orders cannot be honored unless there is “a bona fide relationship” between the physician and the clinic and between the physician and the patient, says Jodie Caplan, director of corporate compliance at the nonprofit health system, which includes eight hospitals, 80 physician practices and 450 employed physicians. In this case, the physician was retired and therefore had no relationship with the clinic. He also had no professional relationship with his wife.

This is one example of the kinds of questions tackled by Carilion’s compliance hotline. Rather than outsourcing to a hotline vendor — a common practice in the health care industry — Carilion’s compliance department takes its own calls and keeps the hotline (called “ComplyLine”) open for all types of employee inquiries.

“Employees call if they have a question of any kind. We help them with regulatory research so we can be sure we’re in compliance with all laws and regulations,” Caplan says. If employees are concerned they’re not doing something correctly or need regulatory clarification for a new service line, compliance will track down the answer. Or perhaps employees picked up information at a conference but need it amplified. “They will call, and we fill in the picture for them,” she says.

Caplan, a CPA and certified internal auditor, has compliance liaisons in certain clinical departments (e.g., lab, health information management), and she brainstorms with them to get answers to the many questions that come into the compliance hotline. “We get a lot of calls about billing practices” — whether to use one CPT code or another, for example, or which modifier is appropriate for a particular procedure, or how a change in the regulations affects documentation and billing requirements. Though potential violations are also reported to the hotline, the majority of calls come from employees seeking information, feedback and problem-solving. “We’re not here to be punitive,” she says.

This approach is meant to reinforce Carilion’s efforts to avert compliance violations, Caplan says. “Our goal is to do it right the first time,” she says. “If employees need additional regulatory information, we are happy to do the legwork.” Apparently, the strategy is working because “over the past few years, we have gotten more proactive calls,” Caplan says. “Employees know they can call and feel safe calling us. We want to get it right from the beginning. And the myriad regulations are confusing.”

Full story