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 current 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 25% within your firat 12 months.
In your fifth week in this capacity, you receive the following written complaint:
“My name is Teri Wilkins. I am a long-term employee currently on disciplinary action and need your help. I believe I am being retaliated against for my reporting of the following ethical, legal, and compliance concerns to our leadership:
– Patients with Alzheimer’s disease sit unsupervised inside a small room of HOSPITAL’s adult psychological care facility watching the movie “Forrest Gump” every day. Each time the patients sit in front of the TV watching it, the facility submits private insurance claims for providing “group therapy.” Some of the “therapists” have never been trained to provide those services and are under the supervision of a part-time doctor, Suzanne Speedy, M.D., who comes in two days a week to review treatment files and sign claim forms. The facility is being renovated with unattended hazardous equipment laying around, and patient treatment files and forms are currently housed on an open magazine shelf in the lobby.
– HOSPITAL recently implemented an integrated Electronic Medical System (EMR ). All physicians, employees, temporary workers, and others with hospital privileges can access all patient medical records anytime through the interface. A cardiology patient recently filed a complaint with the Office of Civil Rights claiming that here privacy rights were violated because the cardiologist was aware that the HIV positive patient had also recently been treated for Syphillis. HOSPITAL also just rolled out a new “zero tolerance”social media policy stating that any employee using social media (facebook, linked in, twitter, etc.) may not identify “HOSPITAL”as their employer in any way shape or form or be subject to immediate termination and loss of benefits.
– HOSPITAL has opened several new facilities in affluent areas in the past year while at the same time closing an even larger number in lower income areas – leaving some communities without reasonable access to medical care. All existing locations appear to be understaffed with long wait times in the ER — and we even had a patient bleed to death while waiting to be seen. Female nurses have complained they are forced to work uncompensated overtime and almost always at a lower pay rate than their male counterparts. Older employee’s jobs are always the first ones cut; and when a job vacancy is posted for any position, everyone knows that only the “young and healthy” need apply.
– Colleen, a pregnant 15-year-old uninsured patient with suspicious bruising on her face, neck and upper torso appeared at the HOSPITAL emergency room with her boyfriend and appeared to have labor-type symptoms. Admitting clerk, Derek, told Colleen to seek care instead at the free health clinic outside of town. While en-route to that clinic, Colleen’s car is struck by a drunk driver, Joe. Colleen dies from the injuries shortly after giving birth to a baby boy who is now on artificial life support at our HOSPITAL due to a permanent brain damage. Colleen’s boyfriend claims that the baby was fathered by Colleen’s stepfather who is now insisting on taking the baby off the life support.
– HOSPITAL is giving financial incentives to staff employed at Los Angeles homeless shelters to deliver homeless patients by ambulance to HOSPITAL. HOSPITAL provides the homeless patients a hot meal in the cafeteria and has each patient sign a consent form for medical treatment as well as an advanced directive. HOSPITAL does not all the homeless patients to leave the cafeteria until they complete and sign the forms. HOSPITAL then bills Medicaid for a variety of medical services allegedly rendered to the homeless patients, many of which are not medically necessary. When the homeless patient dies at a shelter, HOSPITAL will send an ambulance to collect the body so that HOSPITAL may harvest and repurpose the organs to other patients for transplant.
– Michelle Mengala is an allergy doctor and researcher on HOSPITAL staff providing an experimental treatment not yet approved by government healthcare plans or other insurance companies. Patients are handed a bag of syringes filled with antigens and told to inject themselves in their homes. HOSPITAL bills Medicare for each patient self-injection as an office visit. Because the treatment is not covered by insurance, Dr. Mengala instructs her staff to code it as some other treatment that is covered.
– Arthur Andersen, M.D., is a surgeon on HOSPITAL staff who performs medical procedures for which he is neither competent nor properly credentialed. At least one patient died, and others were seriously injured, and no formal action was ever taken, because the HOSPITAL and the state licensing boards are in cahoots and protect their own. I know that a previous facility had restricted Arthur’s physician’s privileges as a result of a high-complication rate on his surgical procedures.

Please help! I feel I am going to lose my job because of exposing these issues.”
ASSIGNMENT: Analyze and evaluate the organizational risks of Teri’s allegations, citing actual cases and laws in your analysis and argument. Discuss your specific course of action, step-by step, and explain how it integrates into your overall comprehensive strategy for your new function. Explain the ethical dilemmas, if any, in addition to legal and compliance concerns.

NOTE: Resignation from your role is not an option.

***********************************************************************************
YOUR RESPONSE:

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 current 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 25% within your firat 12 months.
In your fifth week in this capacity, you receive the following written complaint:
“My name is Teri Wilkins. I am a long-term employee currently on disciplinary action and need your help. I believe I am being retaliated against for my reporting of the following ethical, legal, and compliance concerns to our leadership:
– Patients with Alzheimer’s disease sit unsupervised inside a small room of HOSPITAL’s adult psychological care facility watching the movie “Forrest Gump” every day. Each time the patients sit in front of the TV watching it, the facility submits private insurance claims for providing “group therapy.” Some of the “therapists” have never been trained to provide those services and are under the supervision of a part-time doctor, Suzanne Speedy, M.D., who comes in two days a week to review treatment files and sign claim forms. The facility is being renovated with unattended hazardous equipment laying around, and patient treatment files and forms are currently housed on an open magazine shelf in the lobby.
– HOSPITAL recently implemented an integrated Electronic Medical System (EMR ). All physicians, employees, temporary workers, and others with hospital privileges can access all patient medical records anytime through the interface. A cardiology patient recently filed a complaint with the Office of Civil Rights claiming that here privacy rights were violated because the cardiologist was aware that the HIV positive patient had also recently been treated for Syphillis. HOSPITAL also just rolled out a new “zero tolerance”social media policy stating that any employee using social media (facebook, linked in, twitter, etc.) may not identify “HOSPITAL”as their employer in any way shape or form or be subject to immediate termination and loss of benefits.
– HOSPITAL has opened several new facilities in affluent areas in the past year while at the same time closing an even larger number in lower income areas – leaving some communities without reasonable access to medical care. All existing locations appear to be understaffed with long wait times in the ER — and we even had a patient bleed to death while waiting to be seen. Female nurses have complained they are forced to work uncompensated overtime and almost always at a lower pay rate than their male counterparts. Older employee’s jobs are always the first ones cut; and when a job vacancy is posted for any position, everyone knows that only the “young and healthy” need apply.
– Colleen, a pregnant 15-year-old uninsured patient with suspicious bruising on her face, neck and upper torso appeared at the HOSPITAL emergency room with her boyfriend and appeared to have labor-type symptoms. Admitting clerk, Derek, told Colleen to seek care instead at the free health clinic outside of town. While en-route to that clinic, Colleen’s car is struck by a drunk driver, Joe. Colleen dies from the injuries shortly after giving birth to a baby boy who is now on artificial life support at our HOSPITAL due to a permanent brain damage. Colleen’s boyfriend claims that the baby was fathered by Colleen’s stepfather who is now insisting on taking the baby off the life support.
– HOSPITAL is giving financial incentives to staff employed at Los Angeles homeless shelters to deliver homeless patients by ambulance to HOSPITAL. HOSPITAL provides the homeless patients a hot meal in the cafeteria and has each patient sign a consent form for medical treatment as well as an advanced directive. HOSPITAL does not all the homeless patients to leave the cafeteria until they complete and sign the forms. HOSPITAL then bills Medicaid for a variety of medical services allegedly rendered to the homeless patients, many of which are not medically necessary. When the homeless patient dies at a shelter, HOSPITAL will send an ambulance to collect the body so that HOSPITAL may harvest and repurpose the organs to other patients for transplant.
– Michelle Mengala is an allergy doctor and researcher on HOSPITAL staff providing an experimental treatment not yet approved by government healthcare plans or other insurance companies. Patients are handed a bag of syringes filled with antigens and told to inject themselves in their homes. HOSPITAL bills Medicare for each patient self-injection as an office visit. Because the treatment is not covered by insurance, Dr. Mengala instructs her staff to code it as some other treatment that is covered.
– Arthur Andersen, M.D., is a surgeon on HOSPITAL staff who performs medical procedures for which he is neither competent nor properly credentialed. At least one patient died, and others were seriously injured, and no formal action was ever taken, because the HOSPITAL and the state licensing boards are in cahoots and protect their own. I know that a previous facility had restricted Arthur’s physician’s privileges as a result of a high-complication rate on his surgical procedures.

Please help! I feel I am going to lose my job because of exposing these issues.”
ASSIGNMENT: Analyze and evaluate the organizational risks of Teri’s allegations, citing actual cases and laws in your analysis and argument. Discuss your specific course of action, step-by step, and explain how it integrates into your overall comprehensive strategy for your new function. Explain the ethical dilemmas, if any, in addition to legal and compliance concerns.

NOTE: Resignation from your role is not an option.

***********************************************************************************
YOUR RESPONSE: