UW Medicine Board Review Committee Report: Achieving Excellence in Compliance

The well-publicized four and one-half year Federal investigation of UW Medicine produced criminal felony convictions of two nationally prominent physicians and a $35 million settlement. The purpose of the Review Committee's Report - Achieving Excellence in Compliance - is to help convert this traumatic series of events into the development of an excellent Compliance Program, which is supported by a culture of professionalism, ethics, and integrity.

Full Report

Chairman Memorandum of Transmittal

Acknowledgements

Table of Contents

Executive Summary

1. Brief Executive Summary
2. Full Executive Summary
1. The Relevant History
2. Analysis and Assessment of the History
3. What Has Been Done: UW Medicine Compliance Programs Today
4. Organizational Culture
5. Review Committee Recommendations
6. Conclusion

Report of the Review Committee

1. Introduction
1. The Investigation and Settlement
2. Costs of the Investigation and Settlement

Review Committee Work

1. Purpose of This Report
2. Committee Membership
3. Committee's Independence
4. Scope of Committee's Review
5. The Committee's Expectations
6. Elements of Methodology
7. Sources of Information
1. UW Medicine Billing Investigation Documents
2. Meetings and Briefings with UW Attorneys
3. Key Personnel and Stakeholders
4. Government and Whistleblower
5. Review of Federal Regulations, Guidelines, and Academic Literature
6. Best Practices Study
7. Member and Staff Training
8. Committee Meetings

Cooperation of UW Medicine Administrators, Faculty and Staff

UW Medicine's Compliance Program Initiatives

Overview of UW Medicine

1. UW Medicine and its Affiliated Entities
2. National Recognition

Evolution of Medical Billing - Summary

What Happened - Events and Causes

1. Summary of Developments in Compliance Programs at UW Medicine in the mid- 1990s
1. Early Notice of Allegations of Improper Billing in the 1990s
2. Pre-Investigation Audits

Summary of Investigation and Outcomes

1. The Criminal Case
2. The Civil Case
3. The Settlement

Causes of the Problems that led to the Federal Billing Investigation

Developments in UW Medicine Compliance Programs: 1999-2004

1. Professional Billing Compliance - UWP and CUMG Ð 1999-2004
2. UWP and CUMG's Compliance Program in 2005
3. HMC and UWMC Compliance Programs from 1999-present
4. Committee's Commentary

Summary Assessment of Current Compliance Programs

Organizational Culture and Physician Accountability

1. Organizational Culture
1. Findings
2. Responsibility of Individual Providers
3. Responsibility of Physician Leaders and Department Chairs
4. Responsibility of Administrative Leaders
5. Other Recommendations

Expectations, Feedback and Incentives for Physicians

Communications

Governance

1. Role of UW Medicine Board
1. UW Medicine Board's Role and Authority
2. Board Level Compliance Committee
3. Board Functions and Perceptions of its Role
4. Considerations on Strengthening the Board's Governance Role

UWP Structure and Governance

Detailed Findings and Recommendations - UW Medicine Compliance Programs

1. Management
1. Management Accountability
2. Risk Assessment and Compliance Planning

Compliance Functions

1. Structure and Oversight of Compliance Function
2. Monitoring and Auditing
3. Education, Training and Information for Physicians and Staff

Business Infrastructure

1. Information Technology
2. Coding and Billing Functions

Looking Forward

1. Implementation of Review Committee Recommendations
2. A Vision for Compliance
3. Expectations and Outcomes

Conclusion

Appendices