Medical Journal Houston | Page 15

. . . . . . . . . . . . . . . . . . . . . . . . . . . . Medical . . . Journal . . . -.Houston . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . May 2016 FINANCIAL PERSPECTIVES continued from page 3 . . . . . . . . . . . . . . . employee or asked to interview the employee about possible unethical or illegal conduct relating to the facility? • While employed with the company, did the employee or any family member own, operate, invest in, assist, or otherwise have an interest in any company or enterprise which competes with or does business in the healthcare industry? Page 15 is crucial because that knowledge may be imputed to the employer in litigation. Thus, it is imperative to learn what employees in reimbursement-related positions know before they leave the facility’s employ. Ascertaining the Possibility for Litigation An employer should not overlook the use of the exit interview as a tool to explore general • Reason(s) for leaving. If the individual was terminated, it is crucial to examine his or her understanding of the events leading to the termination. A similar inquiry should be made if the departing employee was subject to disciplinary action. • Beliefs concerning whether appropriate opportunities for advancement were The above list is by no means exhaustive. The list should be expanded to address areas of concern for an employer; it should also be tailored to address the employment circumstances of each departing individual. Employees in coding or billing departments provide but one example of the importance of the exit interview. Because those employees are directly involved with issues of reimbursement, they have a hand in creating the documents that are submitted to the government for payment. If these documents contain false information or statements, they may provide the basis for litigation under the False Claims Act. A civil action for a false claim will include, among other things, inquiry into an institution’s awareness of government billing policies and requirements, as well as an examination of an institution’s own billing practices and policies. The knowledge possessed by an employee involved with reimbursement facets of the employment relationship. Discussion with a departing employee will enable an entity to identify and assess the possibility for civil litigation stemming from that individual’s employment. This litigation can take many forms, but employers should be especially sensitive to the possibility that a departing employee may be harboring a claim of employment discrimination or harassment. To that end, the exit interview should focus on an individual’s: available. • Comments concerning the level of pay and provision of other benefits. • Overall assessment of working conditions, including the workplace “dynamic” and interactions with supervisors and peers. Healthcare institutions should also use the exit interview to learn more about an individual’s assessment of workplace quality. Thus, topics that should be raised and discussed during an exit interview include an employee’s opinion of the supervision he or she received, evaluation of the effectiveness of training, likes and dislikes about the institution and/or its policies, recommendations for change in the workplace, and overall assessment of working conditions. Applying Information Learned If the exit interview reveals that an employee encountered no illegal or unethical practices, the form used and notes made during the interview should be placed in the departing employee’s personnel file. If, on the other hand, the interview reveals that an employee may have witnessed illegal or unethical practices, or if information is uncovered which suggests that a departing employee has a complaint of harassment or discrimination, counsel should be notified immediately. An investigation must follow in order to diffuse the situation, assess whether the employee has viable claims, plan for the possibility of litigation, and preserve testimony and documents, should litigation ensue. Information uncovered during an exit interview simply cannot be ignored, and statements made by departing employees must be taken seriously. Using the exit interview to monitor the potential for wrongdoing, unethical behavior, unsafe or unsound business practices, and litigation will help the healthcare employer run a more efficient facility. t TREASURE the tranquility Within minutes of Downtown and the Texas Medical Center Gracious homes welcome family and friends. Neighborly amenities and events evoke a hometown ambiance. Acclaimed Alvin ISD schools reassure parents who want the best for their children. Sedona Lakes is where families thrive and happy memories multiply. Shouldn’t Sedona Lakes be home to what you treasure most? NEW MODELS NOW OPEN! New Homes from the $280s to the $600s A Treasure Found · SedonaLakes.com