1. Developing Tracking Systems Rick King Director, Corporate Compliance Fresenius Medical Care North America The Sixth Annual National Congress on Health Care Compliance Session 4.04, Developing Training and Employee Tracking Procedures February 7, 2003 1

2. 2 Track What? b Compliance training b Code certifications b Exclusion checks b Disciplinary action b Professional certifications

3. 3February 7, 2003 Why Do We Care? b Training and other trackable items are fundamental building blocks of a compliance program b If you don’t track it, it won’t get done b Provides quantifiable results to demonstrate program performance b Government requirements

4. 4February 7, 2003 Tracking Options b Certifications in files, backed up by audits b Simple lists in Excel or Access b More developed databases Commercially availableCommercially available Internally developedInternally developed è Build to suit your organization’s needs

5. 5February 7, 2003 Design Concepts for Tracking in a Large, Multiple Location Organization “This report is wrong. I went on November 20 from 1:00 to 2:30. I remember it vividly. I know Stephanie went, too, because she kept propping my head up.”

6. 6February 7, 2003 Database Goals b Be accurate b Be simple to use b Provide visible results b Encourage compliance b Promote accountability

7. 7February 7, 2003 Avoid Undermining Credibility in Data b Frustrates those who have done what they were supposed to do b Prevents holding accountable those who haven’t performed

8. 8February 7, 2003 Solution b Locations responsible for tracking their own information Local users enter data into databaseLocal users enter data into database Local users can see their data and create reportsLocal users can see their data and create reports If the data isn’t correct, enable the user to fix the dataIf the data isn’t correct, enable the user to fix the data Find the right level for “local users” in larger locationsFind the right level for “local users” in larger locations

9. 9February 7, 2003 Automatically Communicate with Employees and Managers b When data is entered to confirm accuracy and provide a record b When deadlines approach or have been missed

10. 10February 7, 2003 Reports b Allow management to see information for the parts of the organization for which they are responsible b Centrally produce standard reports for senior management b Centrally conduct random audits on a regular basis to validate database entries

11. 11February 7, 2003 Centralized Database Management b Design b Items being tracked CoursesCourses RequirementsRequirements Timing of alertsTiming of alerts b Oversee authorized user list and security levels

12. 12February 7, 2003 Challenges b Systems that don’t talk to each other HR databaseHR database E-mailE-mail b Categorizing employees by training requirements

13. 13February 7, 2003 Building Institutional Support b Don’t limit databases to compliance only b Involve others in design

14. 14February 7, 2003 Side Benefits b Improvement of data quality b Incentive to coordinate system standards

15. 15February 7, 2003 Budgets b Commercially available databases Per seat chargesPer seat charges Customization charges and performanceCustomization charges and performance b Internally developed databases

16. 16February 7, 2003 Timing b Phase 1: 3 months Web based data entryWeb based data entry b Phase 2: 6 additional months On line viewing, editing, and report writingOn line viewing, editing, and report writing b Phase 3: 3 plus months Automated alerts, system improvementsAutomated alerts, system improvements

17. 17February 7, 2003 Examples b Employee Training Database b Physicians Database