CommonSpirit's Michelle Cooper on compliance

Remaining in compliance is one of the most essential and difficult tasks for any health system.

Michelle Cooper, executive vice president and the chief compliance officer at CommonSpirit Health in Chicago, stopped by the "Becker's Healthcare Podcast" to discuss the changing role of compliance within healthcare.

Editor's note: This is an edited excerpt. Listen to the full episode here.

Question: Take a moment and talk about the job of chief compliance officer at such a large system. How do you go about setting priorities?

Michelle Cooper: It has been an interesting journey. I think back to when I started in compliance, and compliance used to be getting education out, really reacting to government investigations, and the direction of compliance now is so much more proactive. When CommonSpirit came together, I came from the legacy Catholic Health Initiatives side, and we had centralized compliance across our ministries on the CHI side. And when we came together with Dignity, we made the decision to really move everything into an operating model and centralized compliance. So we got our team together and really looked at how we were doing compliance and said, "How do we shift from being so focused on reacting to the government, reacting to increased patient privacy rules, the security threats, all the various things that are happening across our ministry?" and really began to look at data and look at analytics and get ahead of some of the concerns that come before us as a ministry. 

So we put together a compliance team that centralized at the national level. We have individuals in the market, but we also have a very robust national team that is focused on data analytics, focused on the ever-changing rules and regulations. They work very closely with our advocacy team, our transaction team, and really try to look at the data that we have within our systems. They look at our billing, coding, medical necessity data, and say, "Do we have any outliers? Are there problems? Are there things that we should be focused on?" So our shift has really been to move away from just being a hotline, being an education model, to being more of an analytical team that is involved on all the executive leadership teams at the time transactions are occurring to say, "What does this mean for our data?"

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