Agreeing with the above, however the root of the problem could be the failure of the compliance program and its leaders. Could it be that the Compliance Officer has failed to lead change of the culture and embrace true leadership, ethics, and integrity? Maybe it is not in his nature to live by true compliance and example, but to act on self interest, as he twist the
facts from black and white to meet the demands of the day. To support this theory here are examples. 1) Agreeing to establish San Fran as a center for more revenue and then bragging about it, when CMS has given guidance this is not ethical for existing companies to shift operations from one part of the country to another just for revenue gains. 2) Defending the company's action to Highmark BCBS when he knows the action was to change codes to achieve reimbursement, after claims denied. How can this be ethicall? Another fact; based on his words - is that he will push business decisions "right up to the line", to get the job done. What if he is wrong about where the line is? Lets reiterate the possible problem: Is it a lack of ethics understanding and what true leadership should be in today's healthcare environment? Not having all the facts, this could be true - however, it is very disappointing that this company has gone from being one of the first IDTFs to embrace Joint Commission and Jim Collins Good to Great Leadership in 2006 to today's reality.