Regulations, Regulations – Part of the Job
I’m not sure who said it, but one memorable quote that circulated a few years back was that academic medical centers like UMMC might be the most complex organizations on Earth.
One obvious driver of that complexity is our three interrelated and inseparable missions of education, research and patient care. Most organizations are designed to do one thing and do it well – make bicycles, offer banking services or sell clothing, for example. Depending on their size and scope, they may develop subsidiary businesses that support their main purpose – a car manufacturer might have an auto finance business, for instance.
At academic medical centers, the three main missions, though they intersect in important ways, are very different from each other.
One thing these missions have in common is they are all highly regulated. Just as AMCs are among the most complex organizations, they are also subject to a maze of regulations and controls.
I recently asked my staff to compile a list of all the external oversight and regulatory agencies to which UMMC is in some way accountable. Although I expect we missed a few, the list is nearly six pages long, single-spaced. That amounts to more than 200 entities that have some form of regulatory authority over UMMC.
Of these regulatory groups, 78 are at the federal level. As you might expect, the Department of Health and Human Services is a large and important oversight body. We are subject to 15 different agencies, centers and institutes under the HHS umbrella. Many of these entities have multiple divisions of their own. The National Institutes of Health, for example, has 17 subdivisions to which academic medical centers are accountable.
Some of the federal agencies we are subject to are massive in their own right and have high public profiles, like the Centers for Medicare and Medicaid Services. Others, like the Agency for Toxic Substances and Disease Registry, are more obscure.
The list includes 55 state agencies and boards. Some of the more recognizable of these include the state Department of Health, the Department of Finance and Administration, and, of course, the Legislature.
Various units within UMMC are subject to a range of accrediting bodies – 51 by our count. These include accrediting groups for our schools, for every physician residency program, and for the individual educational programs within the School of Health Related Professions. Our UMMC campus-based hospitals are accredited by the Joint Commission under a rigorous set of quality standards.
These regulatory bodies and oversight groups all perform important functions that help ensure quality, accountability and responsiveness to our constituents. But I don’t think most people are aware of the extent to which we are regulated and the time, effort and expense that goes into making sure that we are compliant with all the regulations to which we are subject.
In 2015, the University of Vermont conducted a study to estimate its costs of just its federal regulatory compliance and accreditation. For fiscal year 2015, those costs were nearly $64 million, about 10 percent of the university's $625 million operating budget. The study encompassed the university’s medical school, but not its hospital system, which is a separate corporate entity. A little less than half of the costs were accrued for compliance in the research mission, and about a quarter of the costs were associated with the education mission.
A similar study at Vanderbilt University for FY2014 estimated compliance costs at $146 million, with about $117 million earmarked for research compliance.
All this serves to illustrate that regulatory compliance has become a significant and, I would add, ever-growing part of our daily walk at the Medical Center. For the most part it’s behind the scenes, below the radar and – at times – a bit tedious, but it’s a necessary part of our journey toward A Healthier Mississippi.