INSTRUCTIONS: Please type your response to the following case and organize it in
ID: 377383 • Letter: I
Question
INSTRUCTIONS: Please type your response to the following case and organize it in a way to include and address your scope of responsibilities and the areas of concern, as assigned below.
CASE: You are hired as the new regional compliance director for a Fortune 500 multi-facility integrated healthcare system (aka “HOSPITAL”) to lead their corporate compliance program. You currently have a staff of six and have been informed that as part of the company’s efficiency and optimization mandates, you are expected to reduce your departmental staff by 30% within your first 12 months. In addition, you immediately receive a request from your executive leadership to review and approve from a legal, compliance and ethical perspective the following: “Due to our increasing intrinsic health care costs, decreasing profit margins, significant reductions in Medicare reimbursement rates, and the high cost of life continuity and chronic care measures, effective January 1, 2017, Hospital will implement the following program. Hospital will establish a fund to help defray patient expenses incurred due to a stay in the hospital. Hospital, as part of its’goodwill and community outreach measures will require each current female employee of Hospital to contribute 5% of their salary to that fund which Hospital will match at 100%. Male employees will be required to contribute 7% of their salaries to address the fact that men are generally paid more than women. Any employee requests to be exempted from the forced contribution based on financial hardship will be considered on a case by case basis only. The funds will be applied selectively by Hospital to patients deemed by the Hospital Board to be most deserving. In addition, each non-emergency patient shall sign a release prior to admission allowing the hospital to use their photographic images and treatment information for fund-raising purposes to help defray cost to the hospital to the extent that their individual costs of care are not met by their insurance and/or the patient’s out of pocket payments. This may include broadcasting the images on video monitors throughout hospital where you can make donations similar to a telethon, selling of photos of newborns to advertising agencies, community messages showing individuals suffering the effects of smoking, drug use, and for religious purposes such as the promotion of abstinence and warnings against teenage pregnancy. If the patient refuses to sign the release, they will not be admitted. The hospital shall be fully transparent in terms of patient care costs; and provide each patient with an estimated cost of care (including a menu of basic treatment plan services and a la carte options prior to admission so that the patient may select their appropriate level of care. The patient will receive a daily invoice accounting of the hospital services provided each day thereafter (not unlike the hotel invoice placed under your door on the day of checkout.) Patients admitted under emergency conditions will be required to sign the release as soon as their condition is deemed by hospital physician to be medically stable.”
YOUR RESPONSE?
Explanation / Answer
As Part of the Compliance team and Regional director following would be my response.
The Downsizing of my team would be done for efficient working of the company and I would have to reduce 30% of the staff strength, which I will evaluate and take action accordingly, only after looking at the companies police in detail. If Downsizing is to be done I would identify 2 staffs who are low performers both qualitative and quantitatively would terminate them by giving notice well in advance.
About the contribution, being a director i would not have any issues paying 7% of my salary, but here I would explain it to HOSPITAL that forcefully deduction of the money from an employee is not the ethical way, such deductions should be voluntary. There is a possibility that a lower grade employee might find it difficult and as said company may consider that, but still I feel this contribution must be voluntary rather than forcefully deducting it from employees.
Lastly, about signing the release to use the photographs for the hospitals benefit, I would explain hospital that this is completely wrong. Hospitals duty is to serve patient and they should not deny anyone from getting the treatment if they are not allowing us to use their photograph. That is their personal choice and we cannot force patients to do so, nor could we refuse admission to the patient if he is fulfilling all other requirements, this might land us up in a possible legal battle, which is not good for goodwill and image of the hospital. I would ask the hospital to immediately revoke the policy about signing the release.
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