Hospitals are the backdrops for some of life's most meaningful events—birth and death, healing and hope—and trustees are the leaders who make good institutions even better, improving health care for all. Most trustees come to their jobs out of altruism and a simple desire to give back. We at the Office of Inspector General applaud this sense of service, and we want to offer some tools that will make it easier for all board members to do their important work of overseeing corporate operations, helping hospitals balance their books and, in particular, helping hospitals fulfill their health care missions.
Let me begin with a straightforward proposition: The best boards are active, questioning and even skeptical concerning the hospitals they oversee. They don't make assumptions, they don't view their jobs in narrow terms, and they don't shy away from asking some very tough questions.
Now, trustees who embrace such active roles may well raise the apprehensions of medical professionals, the doctors, nurses and specialists who work in hospitals every day. And many board members may themselves shy away from adopting such a leadership stance, particularly the many trustees who come to their board memberships without a medical background. They might be tempted, for example, to leave the hard questions about mortality rates, hospital infections or medical errors to physicians.
Yet that would be a big mistake. Remember the old saw about how war is too important to leave to generals? Nonmedical professionals on boards bring an outsider's point of view that may make them more likely, not less, to see important patterns in how hospitals are doing—provided they can get the right information.
In addition, the days are gone (if, indeed, they ever truly existed), when a hospital's bottom line could somehow be decoupled from its health care track record. More and more, the two are intertwined. Negative headlines in the local newspaper about poor health care outcomes can do untold damage to a hospital's reputation—and business. The federal government is increasingly linking hospital payments of Medicare and Medicaid bills to the quality of patient care, both in terms of monetary rewards and penalties. All these factors have an impact on hospital finances; thus, the board's fiduciary responsibility simply cannot be fulfilled unless trustees examine the nitty-gritty details of how hospitals are doing.
Trustees are just the right people to do this important work. Moreover, it need not be as daunting as it sounds. The OIG wants trustees to succeed, and our website offers guidance that we drafted to help board members fulfill their responsibilities. But there are additional steps boards can take, some of them quite simple, to help them meet their oversight obligations. Here are some suggestions:
1. Every hospital should have an effective compliance plan as well as a compliance officer on staff. Trustee leadership is critical for both. A successful hospital compliance plan establishes a culture of ethical and legal standards of behavior. Compliance plans promote the prevention, detection and resolution of actions that do not conform to federal and state law, as well as the hospital's ethical and business practices. An effective compliance program not only articulates an institution's commitment to high standards of conduct, but sets out specific and practical steps to achieve and maintain those standards.
Hospital trustees' commitment to and promotion of these ongoing efforts greatly enhance their opportunity for success. The OIG has in-depth publications to help hospitals establish effective compliance programs.
The compliance officer is the hospital ombudsman who monitors the institution's legal and ethical response to issues as they arise. This critically important position is a signal to the staff and community at large that the hospital takes its mission seriously. Most hospitals have compliance officers on staff. But in the coming years it is likely that government regulations will require hospitals to hire them, particularly with the implementation of the Patient Protection and Affordable Care Act.
2. Hospitals often find that a compliance officer can be more effective if he or she doesn't also serve as the hospital's legal counsel. The views of both, so necessary to the trustees, can be better appreciated if the roles are kept separate. I also believe that the compliance officer should report directly to a board of trustees, with no buffer in between. Trustees need unfiltered guidance to truly understand how well institutions are doing. They need a person who is paid to deliver the news on how well a hospital is following proper procedures and meeting the high standards of a hospital's mission—especially when the news isn't positive.
3. Every board needs a system in which it can get candid information on how its hospital is doing in a timely, comprehensive manner because communication is critical. The reports should be presented in a way that is clear and easily understood, sometimes in the form of dashboards, scorecards or other graphic presentations. They should include information such as adverse events, patient complaints, medical and medication errors, patient quality and safety indicators, and outcome measures such as 30-day readmission rates. This sounds complicated, and it can be, but the board's understanding will be enhanced if the information is expressed in a consistent, clear way.
Trustees have demanding jobs. But done well, trustees play pivotal roles in helping good hospitals become great hospitals. I salute you for your community service and my office is committed to helping you in your important work.
Daniel R. Levinson is the Inspector General of the U.S. Department of Health & Human Services.