CASE STUDY
Parkland Health & Hospital System: Cultural Transformation and Restoration of Trust
Background
Parkland Health & Hospital System (Parkland) is a safety net institution that plays a critical role in Dallas County. As a public hospital district, Parkland’s legal mandate is to furnish medical care to indigent and needy individuals residing in the County. Affiliated with the University of Texas Southwestern, Parkland is a leading academic medical center for the region.
In August 2011, following surveys by the Centers for Medicare & Medicaid Service (CMS) and the Texas Department of State Health Services, CMS notified Parkland that its Medicare Provider Agreement would be terminated, effective September 2, 2011. CMS and Parkland thereafter entered into a Systems Improvement Agreement pursuant to which Parkland made an array of commitments in exchange for being permitted to continue participating in the Medicare program.
The Engagement
In May 2012, Parkland’s Board of Managers (Board) retained Saranac as its independent governance and healthcare compliance advisor. In November 2012 and March 2013, Saranac issued two reports that the Board released to the public. The first addressed the Board’s fiduciary duties and oversight obligations with respect to quality of care, patient safety and regulatory compliance. The second focused on corporate governance, cultural transformation and restoration of trust with key stakeholders. The reports included observations and comprehensive recommendations regarding the Board’s responsibilities; the size and composition of the Board; the appointment process; and Board operations, including its annual self-assessment. The Board implemented all of the key recommendations, several of which required legislative amendments.
In May 2013, Parkland resolved an unrelated qui tam (“whistleblower”) lawsuit brought under the federal False Claims Act. Among other things, Parkland agreed to enter into a five-year Corporate Integrity Agreement (CIA) with the Office of Inspector General of the U.S. Department of Health and Human Services. The CIA required the Board to retain an Outside Expert to assist the Board in fulfilling its duties to review and assess annually the performance of Parkland’s Compliance, and Quality of Care and Patient Safety, Programs. Saranac served as the Outside Expert for the first two years of the CIA; the role was then transitioned to a Dallas-based expert. Parkland timely fulfilled all of its CIA obligations.