Alanna J. Kroeker
Loyola University Chicago School of Law, JD 2017
Valerie Dixon currently serves as the University of California Irvine Health (UCI) Deputy Compliance Officer. Ms. Dixon brings 17 years of compliance experience with her to UCI, as she started her compliance career in 1999 at UC San Diego. Prior to joining UCI, Ms. Dixon was the Director of Health Sciences Compliance at the University of California Office of the President Office of Ethics, Compliance, and Audit Services (UCOP), which oversees the compliance programs for the entire UC system. During her time at UCOP, Ms. Dixon worked with the Chief Compliance Officers of all 5 UC academic medical centers and worked to identify system wide clinical compliance issues and develop uniform approaches to mitigate risks and implement compliance initiatives. I recently had the pleasure of interviewing Ms. Dixon, the transcript of which follows below.
Q. How is the UC system unique from other healthcare systems?
UC Health has a tripartite mission of patient care, research, and medical education so I think that is different than other types of organizations. UC is the largest health sciences training program in the nation…with 17 professional schools in 7 fields on 7 campuses. Even though a campus may not have an academic medical center, like UC Berkeley, they have a school of optometry. The health enterprise touches 7 out of our 10 campuses. We educate over 50% of the medical students in California…and are the 4th largest healthcare delivery system in California. [We have] 5 medical centers, 11 hospitals, and probably more to come fairly soon. We have 3600 licensed beds, 165,000 patient admissions, and over 365,000 emergency visits a year. We serve a large number of Medi-Cal patients, 29% of our hospital admissions are Medi-Cal beneficiaries. Then we are nationally recognized and we are at the top of our fields. Two of our medical centers are in the nation’s top 10, UC Los Angeles and UC San Francisco. We have top rate pharmacy and veterinary medicine [programs]. We are #2 in nursing and #3 for research and primary care. If you work for UC you are here with the best of the best and that is what separates us from other types of hospitals and healthcare delivery systems.
Q. What are some of the benefits and challenges for compliance programs in a system structured like the UCs?
I think the challenge is the size and the complexity, but we are first and foremost an academic medical center. Research and teaching is paramount along with our patient care. We are doing research into new treatments, discovering new processes and new procedures. Compliance has to recognize that you’re looking at research compliance issues whereas at other places you may not have to deal with research at all. You also have to deal with faculty. Here at UC we have shared governance, the faculty helps govern, so it isn’t just necessarily business operations decisions. There are other considerations when you are at an academic medical center and I think that adds another level of complexity for compliance.
Q. What is the dynamic like between the UCOP and the individual campus compliance offices?
UC is a system of systems, so we have our UC system and we have each of our academic medical centers or health systems and they’re all autonomous. Even though UC sets the compliance program structure, they really want to guarantee… a certain level of independence and authority. None of our compliance offices report to legal, they are very independent. They all report to the CEO of the hospital or Vice Chancellor of health affairs. I think that UCOP makes sure that the compliance operations are elevated to that level to where they do have that authority as well as that autonomy to really identify, detect, and deter fraud, waste, and abuse in our health care delivery system. We work together in that there are certain processes and procedures and other types of things in running a hospital that we can do more efficiently if we work together, especially in the area of procurement. We all need hospital gowns, we all need things like that. There is an initiative underway to leverage our contracting capabilities through strategic sourcing to drive down costs in that way.
[Because] our patient population is so large, we deal with a lot of big data, which helps our research enterprise because we have access to millions of patient records that [are] very useful for research purposes. We work a lot as far as protecting privacy in the research realm and also on the clinical side. Because we are California, we do have to report up to the state for rather small breaches. That is a whole enterprise in and of itself. I think that each health system structured their own compliance office to meet their particular needs. A campus like UC San Francisco, which is totally health sciences, their compliance office is going to be different than us here at Irvine. We do have the autonomy to structure our programs to suit our individual needs. All Chief Compliance Officers do report up to our Senior Vice President of Compliance and Audit…at UCOP. We also meet as a system, all of our compliance program officers meet twice a year in person. We also have monthly calls so we collaborate and try to solve problems collectively; [we] try to mitigate those risks that we can identify amongst all of us. I think it is a very collaborative relationship.
Q. In your compliance experience, how have you seen compliance programs evolve and adapt?
Compliance is demonstrating their business value to the health systems. We are moving away from being a cost center to more of a revenue protection center. Compliance is moving away from being authoritative; we are not the police. We always have to stress that to the faculty and staff. We are building compliance programs based on what fits our faculty and staff. We all have our 7 elements that of course we have to incorporate into our programs but we’re not being so prescriptive. [We are] moving towards being more engaged with our partners and really developing a partnership with our physicians, ancillary staff, [and] all those that are involved in the health delivery system on our campuses.
Q. What new rule or regulation do you think is going to have the greatest impact on compliance programs in 2017?
MACRA! I think it’s a big shift going from a volume based payment methodology to a value based payment methodology. We’re going to have to work much more closely with quality and we have to be educated on those kinds of quality reporting programs, where we may not have been doing that in the past. We have to understand the internal processes as far as gathering all of the data because [reimbursement is] really going to be evidence based and data driven. I think we’re going to have to know much more about the clinical enterprise and how health care is delivered so that we can understand those quality measures, patient engagement, and other kinds of areas that…compliance may not have had a lot of interaction with before.
We’re [also] still dealing with things on the privacy and security front. We have hackers that are much more sophisticated and want access to our medical records, that’s a treasure trove full of very personal and sensitive information. In addition to our compliance hat, we are also having to learn more on the technology side. [We are] educating ourselves much more on privacy and information security and working much more closely with our IT specialists to mitigate those kinds of risks.
Q. How do you handle staff members who may be reluctant to embrace the changes that compliance offices are trying to initiate?
You have to consider yourself as part of the entire business enterprise. If you have physicians or staff that have developed processes and procedures that aren’t in compliance, you have to ask yourself ‘why are they doing that?’ Obviously it’s some kind of workaround because they want to solve some kind of business process. Compliance [has] to look at the problem from their perspective. You can’t always come up with a prescriptive solution, you have to figure out what is going to work best for those that are actually performing the work because you want to make it easier for them to ask for permission rather than seek forgiveness. You make it easy for everyone to comply, I think that’s the main thing you have to keep in mind. If you notice overpayments, why isn’t their coding matching the medical documentation? Is it just easier for them to keep pulling the codes that they always have done? Is there some education that we can do? What are the things that we can put in place to make it easier for people to comply?
Q. What is the most effective way for you to stay up to date on new rules and regulations?
I read HCCA, Health Care Compliance Association. They have weekly blogs [and] their magazine is also very good. I subscribe to several online newsfeeds [for] health law, pharmaceutical issues, and regulatory issues. There are several I subscribe to, at least 3. You need different perspectives; some might highlight federal regulatory requirements and then some might focus on new legal opinions that have come down that affect health care.
Q. What is your best piece of advice for emerging compliance professionals?
I think you have to possess a strong knowledge base and technical skills, but you also have to work on the soft skills. Compliance is a lot of times getting people to do the right thing [when it is] not necessarily the easiest thing for them to do. I think they have to be willing to see you as a resource, as someone that’s there to help them and not hammer them. You have to be a teacher; you have to explain what’s maybe counter-intuitive or difficult to understand. You have to charm and persuade and have good judgment. It’s all those kinds of soft skills that you need that could really serve you well in the field of compliance, because to get people to do the right thing is hard sometimes because the right thing may not be the easiest.