Monday, November 25, 2013

Ten Rules for Health System Boards of Directors to Follow to Reduce the Risk of Fraudulent Outcomes Reporting and Scientific Misconduct

Enjoying a good spin
Are you on the Board of Directors for a large health service provider, population health vendor, integrated delivery system, managed care organization or other care corporation? 

If so, your company is likely collecting, analyzing and publicly reporting quality and cost data. Not only do superior results in journals, meetings, splashy web sites and glossy marketing materials present a competitive advantage, achieving superior outcomes is part and parcel of your organization's mission.

The Disease Management Care Blog reminds Board members that intentionally or unintentionally misrepresenting outcomes is an existential threat to health care organizations.  Having to retract a publication, correct a white paper, meet with grumpy regulators, confront claw backs, deal with a whistle-blower, respond to allegations of interpretation spin, uncover suppression of bad results or defend the integrity of your brand is something no Board wants to deal with.

To the DMCB's knowledge, this hasn't happened to any ACOs, risk contracting systems, managed care organizations or population health or wellness vendors.


It's just a matter of time.

While the risk of allegations of scientific misconduct can never be reduced to zero, the DMCB offers up ten best practices for Boards to follow:

Reduce opportunities by:

1. Exhibiting healthy skepticism regarding all outcomes reported by your management team, especially if the results seem to be too good to be true.

2. Insist that your management team has two persons with access to any data base, and that they have separate reporting relationships.

3. Insist that your management team has two persons independently involved in any data analysis, and that they have separate reporting relationships.

4. Be familiar with and insist that the rules on research on human subjects be followed.

5. Maintain a low threshold for conducting internal or external audits of any databases and any interpretations of those data.

Combat any rationalizations that fudging outcomes is OK by:

6. Recruiting Board members with research expertise.

7. Explicitly engage the Audit Committee and any other Board member or committee with oversight of risk to view "outcomes" with the same level of scrutiny as your company's financials.

8. Maintain an ethical "tone at the top" when it comes to research.

9. Have a disaster plan ready to go.  For starters, train your Board on how to deal with hostile media inquiries.

Reduce incentives by:

10.  Asking your CEO if any compensation plans including bonuses or unwittingly promoting unethical or fraudulent behavior.

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