Wheaton Franciscan Healthcare
Wheaton Franciscan Healthcare realizes an automated Conflict of Interest disclosure application is the only way to move forward and stay in compliance with new COI rules.
Wheaton Franciscan Healthcare system is a large not-for-profit healthcare organization serving communities in Illinois, Iowa and Wisconsin. With facilities that include 17 hospitals and four long-term care facilities, it’s the largest healthcare provider in southeast Wisconsin.
In a system this size, it has never been easy to gather data for the IRS Form 990 reports required of all not-for-profits—or to manage mandated financial conflict of interest (COI) disclosures.
That task grew even more difficult when the federal Department of Health and Human Services (HHS) published a new final rule on COI disclosures that represented a significant overhaul of the original 1995 rule. Beginning in August 2012, the new rule required healthcare organizations to:
- Show greater transparency and accountability in identifying and reporting financial COI on the part of any employees involved in Public Health Service (PHS) funded research.
- Report COI disclosures within five (5) days of a public request.
- Redefine Significant Financial Interest (SFI) as any remuneration or equity interest in a publicly traded company that exceeds $5,000 in the twelve months prior to the date of disclosure—regardless of whether it is related to specific PHS funding.
- Disclose SFI information not just on providers and researchers, but on their spouses and dependent children as well.
Historically, Wheaton Franciscan used a paper-based system for managing COI disclosures. However, because of its size and organizational complexity, distributing and tracking paper questionnaires had become a cumbersome and resource-consuming process. Wheaton Franciscan was ready for change even before the new COI rule, and the tipping point came once the rule was announced. “Wheaton Franciscan executives knew it would be virtually impossible to report COI disclosures using a paper-based system within their five-day window,” says Sarah Kleaveland-Kupczak, Vice President of Compliance Services.
Just the volume of data entry alone was amazing, let alone processing the information. The timing was right to implement an automated COI management system.
Wheaton Franciscan has 935 physicians and researchers to monitor, including a multitude of boards. That number includes more than 500 board members (and 990-reportables) and 400 employed physicians. In addition to tracking current board members, Wheaton Franciscan also has to manage information from former board members, as well as the special forms required for highly compensated employees and other “special” personnel categories.
The organization was using letters and faxes to gather this information, which was then manually entered into the system and resided on various spreadsheets or in file folders. There was no single repository for all COI data.
“The whole process required one administrative assistant to work just on distributing questionnaires to board members; I worked with our tax manager to compile and review the data,” says Kleaveland-Kupczak.
Wheaton Franciscan executives knew it would be virtually impossible to report COI disclosures using a paper-based system within the five-day window imposed by the new HHS rule. As the organization began looking for a technology partner, its software search committee had several key criteria in mind. It wanted a solution that would committee had several key criteria in mind. It wanted a solution that would:
- Provide comprehensive back-end management tools;
- Promote a thoroughly documented review process;
- Match FCOI workflow; and
- Offer demonstrated ease-of-use.
In addition, the committee looked for an application partner that thoroughly understood the COI process. After canvassing the market, Wheaton Franciscan decided to implement COI-SMART® from HCCS, now a HealthStream Company. “We weren’t interested in just an online survey or a full suite of compliance products,” Kleaveland-Kupczak explains. “We needed a robust back-end tracking mechanism. We wanted to buy a tool that’s really good at what we want it to do—manage COI.”
The HCCS/HealthStream team was very responsive creating a system that mirrored Wheaton Franciscan’s existing workflow.
Initially, Wheaton Franciscan went live with COI-SMART with a pilot group that consisted of executives at the level of vice president or above. Later, the system was extended to employed physicians and, finally, to board members and other Form 990-reportables.
Kleaveland-Kupczak admits it was an interesting pilot group, but there was a reason behind it. By delivering a positive experience to those at the VP level or higher, she ensured there was someone sitting on all of the boards who would champion the implementation at roll-out. Enthusiastic buy-in from top management set the tone for the rest of the implementation.
“The HCCS/HealthStream team was very responsive,” stated Kleaveland-Kupczak, “creating a system that mirrored Wheaton Franciscan’s existing workflow.” In fact, to demonstrate the system’s ease-of-use to senior leaders, Kleaveland-Kupczak even completed a questionnaire on her smart phone.
“The whole implementation was so smooth, it was almost an enjoyable process,” says Kleaveland-Kupczak. “How often can you really say a software install was ‘smooth’?” she asks.
The organization’s new COI-SMART system now customizes COI questionnaires for each respondent by role, making it faster and easier to respond. A board member who is a physician will see one set of relevant questions, for example, whereas a board member who is not a physician will see only those questions relevant to him or her.
The automated system has a number of features designed boost productivity on the back-end as well. A disclosure flagging feature, for instances, highlights only those questionnaires that have some type of disclosure, so users don’t have to search through hundreds of questionnaires with nothing to report.
“There are literally hundreds of disclosures I don’t have to touch just because of that feature,” says Kleaveland-Kupczak. It also automatically checks the status of all questionnaires, ensuring that responses haven’t been misplaced or forgotten. Reporting functionality lets Kleaveland-Kupczak pinpoint within seconds exactly which board members, physicians or others still need to complete their questionnaire.
Because all COI information now is sent and stored within the COI-SMART application, it’s much easier to find, track and manage the both surveys and responses. “Even through multiple layers of reviews, it’s all centralized to my office,” Kleaveland-Kupczak explains
The entire process is now not only more robust, but it also requires far fewer staff hours. The administrative assistant, tax and compliance managers formerly tasked with this function now have much more time for other mission critical duties.
When the HHS final rule took full effect in 2012, most healthcare organizations decided that implementing an automated COI solution was necessary to ensure the highest level of compliance with the greatest efficiency. With the HHS rule requiring healthcare organizations to have a timely, transparent system for gathering and reporting COI data, they found that a paper-based process was no longer feasible.
Many organizations found that a technology partner like HCCS/HealthStream, which understands the nuances of COI disclosure, review, and reporting could help navigate the complex, ongoing process. Some learned that the cost of implementing an electronic solution was an allowable expense eligible for reimbursement as a “facilities and administrative” cost on PHS-supported funding.
“Compared with other healthcare software the COISMART application isn’t that expensive, but we really didn’t look at it from the standpoint of pure return on investment (ROI),” says Kleaveland-Kupczak. “The fact is, there was simply no way to go forward without an automated solution. HCCS/HealthStream was quick to understand not only what we were asking for, but why we were asking for it. Working with them has been outstanding.”