Your personal compliance plan - personal accountability of healthcare personnel

Healthcare Financial Management, Sept, 1997 by Richard L. Clarke

Healthcare reform, managed care, capitation, continuous quality improvement, benchmarking - all these terms are part of the healthcare lexicon of the 1990s. These terms represent important issues - they have had and will continue to have a significant impact on our industry and our jobs. And add to these terms "corporate compliance."

Perhaps no other term gives healthcare financial managers more cause for concern than this one. This concern is not only for the financial exposure of our organizations, but for our personal accountability and liability for the actions of those under our supervision as well. And it is difficult to know where to begin to address the issue. I believe the first step toward dealing with corporate compliance is to confirm your personal standards of performance - to establish your personal compliance plan.

The foundation of a personal compliance plan can be found in the HFMA Code of Ethics (The Code). The Code was established to promote the highest standards of professional conduct. All members of HFMA, as a condition of their membership, agree to abide by these standards, the HFMA Code of Ethics:

"As a member of the Healthcare Financial Management Association, I will endeavor to promote the highest standards of professional conduct by:

* Practicing honesty and maintaining personal integrity, including avoidance of conflicts of interest with those of my employer or the Healthcare Financial Management Association;

* Striving for the objective and fair presentation of financial information;

* Fostering excellence in healthcare financial management by keeping abreast of pertinent issues;

* Maintaining the confidentiality of privileged information;

* Promoting a greater understanding of financial management issues by others in the healthcare field, and seeking increased public understanding through communication about such issues; and

* Seeking to maintain a reasonable balance between the quality and cost of health care."

Membership in the Healthcare Financial Management Association is voluntary. By joining HFMA, an individual assumes an obligation of self-discipline above and beyond the requirements of laws and regulations.

The Code of Ethics of the Association reminds members of their responsibilities to the public, to clients, and to colleagues. The Code guides members in the performance of their professional responsibilities, and expresses the basic tenets of ethical and professional conduct. The Code calls for an unwavering commitment to honorable behavior, even at the sacrifice of personal advantage.

In relation to the issues raised by the need for corporate compliance, HFMA's Board of Directors has developed an expanded definition of "practicing honesty and maintaining personal integrity":

"The standards of Honesty and Integrity require a member to be, among other things, candid within the constraints of employer or client confidentiality. Service and the public trust should not be subordinated to personal gain and advantage. By definition, intentional illegal acts are contrary to public trust. The standards of Honesty and Integrity can accommodate the inadvertent error and the difference of opinion; they cannot accommodate deceit, subordination of principle, or intentional violation of laws or regulations.

The standards of Honesty and Integrity are measured in terms of what is right and just. They require a member to observe both the form and the spirit of legal, technical, managerial, and ethical standards; circumvention of those standards constitutes subordination of judgment." (HFMA Board Policy, Nov. 1995)

The HFMA Code of Ethics will stand you in good stead as the basis for personal standards of conduct - your personal compliance plan.

Richard L. Clarke, FHFMA President and CEO, HFMA