Teamsters Local 166

Business Representative

Sandy Wohler

November News Report

Shakespeare might ask “The Compliance Hotline-to call or not to call-that is the question”.  Sherlock Holmes in turn would quickly reply “elementary, my dear fellow”.  While it might seem clear to Holmes, many of us are like Shakespeare with the answer being as clear as mud.    Otherwise why would 45% of hotline calls received need to be referred back to regional/facility HR.  So to ask again, when does one use the Compliance hotline?  What are the differences between HR issues and Compliance issues?  The simple answer is: HR issues deals with the work environment; while Compliance issues are actions that go against the ethical and legal responsibilities you would find in the Principles and Responsibility (POR). 

Compliance means doing things right-which is to follow all applicable laws, regulations, standards, policies and procedures.  Each employee is expected to promote honesty and integrity in their work actions; which in turn fosters an environment our members, fellow employees, physicians and our communities can trust. So what types of issue would be considered to be under the Compliance umbrella? These are examples of issues that should be directed to the Compliance community:

1. HIPAA violations
2. Disclosing of Personal Health Information (PHI)
3. Disclosing KP confidential information
4. Violating health, safety and environmental regulations
5. Falsification of documents
6. Inaccurate or incomplete documentation, coding or and billing
7. Conflict of Interests concerns/issues
8. Theft, fraud, waste and/or abuse of KP assets
9. Accepting or giving inappropriate gifts and/or gratuities
10. Non-compliance with regulatory requirements

The top three compliance issues reported included:

1. Member fraud
2. Prescription fraud
3. Privacy issues related to member and patient information and PHI

The Compliance community is here to support employees in understanding today’s complex, regulator world of medicine.  If not sure-Ask.  Most questions can be answered by Managers, Directors or local Compliance Officers. Do not hesitate to bring issues up. If our workflows are not meeting the governmental expectations, we need to tweak or fix those workflows. It is our concerns that protect our members and our careers.  If there are fiscal concerns than the local Controller is the perfect resource.  All Regions have Regional Compliance and Privacy and Security Officers.  They are knowledgeable and up-to-the-minute in any changes in laws and regulations that affect the medical delivery system.  National Compliance has an informative website that allows concerns to be addressed on the intranet at: http://kpnet.kp.org/national/compliance/index.html.

The National Hotline is available at 1-888-774-9100.  Compliance Hotline is intended to:

• Provide an internal channel for employees and physicians to anonymously report compliance issues and suspicious activity without fear of retaliation.
• Isolate those committing, condoning, or covering up improper acts by creating an environment in which others can report the improper act.
• Allow the organization to discover and address potential improper behavior in order to correct any deficiencies and to self-disclose, as necessary, any information that may be required.

It is anonymous as a third party vender receives the call and takes the information then passes the concern to National Compliance by a number system.  Because it is a third party system, the process can take considerably more time especially if more information needs to be collected.  The questions need to go back to the third party vender and wait for the caller to return the call to collect the new information.

What ever path you choose to report a concern be prepared and organized. 

The issue/concern I am reporting falls into the following category(ies):

___ Theft, fraud, waste, or abuse

___ Violation of health, safety and environmental regulations

___ Illegal use or disclosure of confidential information

___ Conflict of interest

___ Acceptance of inappropriate gifts and gratuities

___ Improper use of KP property and systems

___ Falsification of documents

___ Inaccurate or incomplete documentation, coding and/or billing

___ Other

Summary of issue/concern

Location (e.g., region, area, facility, department)

Date

Description of the issue/concern

Do you have supporting documentation (e-mails, pictures, paper copies, etc.)?

Information about those involved

____ First and last names – correct spelling is important

____ Relationship to case, i.e., employee, member

____ Relationship to reporter

____ Are there any witnesses? If there are, who?

Who you’ve notified/spoken to

____ Supervisor:  Name ________________________

____ Manager:  Name ________________________

____ Chief:  Name ________________________

____ HR Representative:  Name ________________________

____ Regional Compliance Officer:  Name ________________________

____ National Department Compliance Leader:  Name ________________________

____ Privacy and Security Officer:  Name ________________________

____ Controller:  Name ________________________

Actually Holmes is right—Elementary, my dear Watson, elementary!

Kaiser Permanente: 

The Teamsters Union Stewards at Kaiser are as follows:

 Bill Waterman, Chief Steward Fontana/Contract Specialist

Jesse Aceves, Chief Steward Riverside/Contract Specialist

Mark "Red" Brancato - Riverside

Kim Gutierrez - Riverside

Jim Page - Riverside

Amber Cabrera - Fontana

Martha Carrillo - Fontana

Kathy Phipps - Fontana

Phil Montuori - Fontana

Gary Rigby - Fontana

Brian Williams - Fontana

Mike Reynolds - Ontario