Telehealth policies and programs center on patient care

Patients and providers alike flocked to telehealth in 2020. Before the COVID-19 pandemic began, fewer than one percent of Medicare primary care visits (PCV) were conducted via telehealth. By April 2020 that number had risen to 43 percent.  (See the data.)  

This spike was in response to fear of spreading the virus, of course. But it was only possible because healthcare organizations worked so hard to adjust to meet the ongoing patient needs. The federal government helped by announcing a public health emergency that eased key rules.  

Related: Differing state regulations make telehealth compliance more complex.  

Compliance professionals worked across their organizations to make sure that everyone understood and complied with documentation, coding and confidentiality requirements. For example, compliance professionals collaborated with clinical teams to ensure telehealth workflows were HIPAA compliant.  And, given the potential for abuse and scrutiny, providers who bill Medicare/CMS took extra care to document visits properly. 

Telehealth has been hugely popular with patients and has led to better visit compliance, particularly for uninsured and underinsured populations. Telehealth has improved patient care by allowing convenient appointments from the comfort of home via a smartphone, tablet, or computer. Another benefit is that telehealth has the potential to expand health care access to underserved populations by eliminating traditional barriers to care such as transportation needs, distance from specialty providers, and approved time off from work. These visits were essential for patients with limited mobility. And of course, there’s the most immediate and urgent benefit of telehealth:  reducing the spread of COVID-19 by limiting person-to person-contact.  

The work for the Compliance team and colleagues across the organization was significant. They had to determine how to maintain confidentiality, obtain consent, and determine proper billing codes. Despite the enormity of this task, the effort seems to be worth it. Patients are reporting that telehealth helps them take better care of themselves. According to Medical Economics:

  • 93% of patients would use telehealth to manage prescriptions, and  
  • 91% shared telehealth would help them stick to appointments, manage prescriptions and refills, and follow wellness recommendations. 

Providers seem to feel that they have worked through a lot of the challenges of telehealth compliance, especially when internet connections are stable. Nicole Craig is a Family Nurse Practitioner at Children’s Rehabilitative Services in Phoenix. She says compliance guidance helps providers “know what has to be documented in the chart to protect ourselves from things such as improper billing and coding.” And, “in 2021 the billing is now different. Getting help from Compliance allows providers to bill time-based care. We have to understand the billing rules and compliance factors in order to follow them, especially during telehealth visits.” 

For most PCVs, telehealth proved to be an efficient way to provide care. This method limited in-person visits to those instances where the patient needed a hands-on physical assessment or diagnostic testing.  

Isabella Porter, JD, director of Compliance at District Medical Group, Inc., is confident that 2020 created a rebirth of telehealth. She also sees a new appreciation of this method of care delivery which healthcare will not abandon once the pandemic is deemed “over.” And she knows that her team will be a big part of her organization’s success. “I do believe that in the context of telemedicine during COVID-19, our Compliance department’s assistance with telehealth workflows lead to overall better patient outcomes during the pandemic,” she said. 

It’s a good thing. While concern about the coronavirus will recede, providers and patients alike will want to continue some telehealth visits. Healthcare leaders will work collaboratively to ensure their organizations can continue to offer this important option.  

Keep on top of regulations affecting telehealth and make sure those regulations are translated into policies and procedures that affect patient care. YouCompli customers have access to notifications about changes to regulations, resources to inform policy and procedure updates, and tools to track compliance. Contact us today to learn more.  

Denise Atwood, RN, JD, CPHRM has over 30 years of healthcare experience in compliance, risk management, quality, and clinical areas. She is also a published author and educator on risk, compliance, medical-legal and ethics issues. She is currently the Chief Risk Officer and Associate General Counsel at a nonprofit, multispecialty provider group in Phoenix, Arizona and Vice President of the company’s self-insurance captive.  

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Denise Atwood, RN, JD, CPHRM 
District Medical Group (DMG), Inc., Chief Risk Officer and Denise Atwood, PLLC 
Disclaimer: The opinions expressed in this article or blog are the author’s and do not represent the opinions of DMG.  

Six key steps to reduce the impact of telehealth audits

Telehealth is almost as old as the telephone itself. In 1879 – just three years after Bell patented the telephone – an article in Lancet described the concept and advocated its adoption. 

A law that’s even older can trigger many telehealth audits today. The 1863 False Claims Act (FCA) was enacted to keep profiteering contractors from defrauding the Union army. It can trigger serious problems for hospitals that don’t take proactive steps to make sure their telehealth practices are audit-proof.  

That’s because the 2010 Affordable Care Act updated the FCA to make healthcare providers liable for “retention of any overpayments” from Medicare and Medicaid. This even includes overpayments resulting from accident or error. Indexing penalties for inflation each year, a requirement added in 2015, increased hospital liabilities. This puts liabilities at three times the amount of the overpayment(s) plus $11,803 to $23,607 for each instance. (Some 29 states and the District of Columbia have additional False Claim laws.) 

These laws’ implications and requirements touch every part of the hospital. Keeping the whole organization in compliance means that all departments have to work together. 

New laws, new regs, new worries for telehealth 

Even before COVID, the government audited claims from what was then a smaller, rural telehealth system. Regulators found a trend of incorrect payments to doctors outside rural areas, who were therefore ineligible to receive them. 

Telehealth is on the latest Office of the Inspector General (OIG) work plan, too. The OIG will be addressing remote patient monitoring by telehealth as an area of concern. 

The public health emergency, with its series of 90-day waivers, made it possible for telehealth to grow so fast. Now, as the COVID emergency ebbs, Congress is considering making its current, expanded status permanent. (Two bills were introduced in May. One would enable audio-only telehealth services for Medicare enrollee. The other would expand telehealth for Medicaid and Children’s Health Insurance Programs.) 

That’s good. But with laws come regulations covering acceptable types, locations and forms of delivery of telehealth services. And with regulations come scrutiny and audits. That can create challenges, especially with the specter of FCA liability in the background. 

The best way to cope with audits is to prevent the need for them in the first place. Here are six steps to follow: 

  1. Know what you’re up against. Keep up to date with all the developing federal and state regulations, waivers, and other requirements. That in itself can take up most, if not all, of your personal and your compliance team’s time.  
     
    Related: Find out how a team of expert compliance professionals and a nationally respected law firm track and analyze the latest regulatory changes, keep you updated, and give you actionable ways to adapt your process.  
     
  1. Inventory your waivers. Which waivers do you rely on, in which departments and facilities? Do the providers and staff that they apply to know about them? And who makes sure the requirements are met and documents it? 
  1. Check your records. One of the biggest causes of noncompliance isn’t malice. It’s error. Did an accidental typo in Coding result in an incorrect claim? Does everyone in Billing know which states require what reimbursement levels for telehealth services? Are certain telehealth records missing? Who’s responsible for keeping the signed doctors’ orders and documents that establish medical necessity? Do patients and services meet billing guidelines? Do you have a telehealth compliance policy? Does it need changing? Start conducting spot-checks to find out. 

    Related: Find out about state requirements for telehealth billing.  
     
  2. Audit your process. Another big cause of noncompliance is miscommunication – particularly the assumption that someone else is taking care of something. So put together an internal audit team, with each department represented. That way, each can learn from the other. Hold an entrance conference to highlight what you learned from your spot checks, define the internal audit’s scope, set expectations, and assign specific tasks and timelines. 
  1. Fix whatever’s broken. Reconvene the internal audit team and communicate the findings. Together, use that input to find opportunities to correct or cure what’s wrong in your process. Then, create a Corrective Action Plan (CAP) that will include needed education, training, policy, and process changes. Monitor your CAP over time, to see how it’s working and to spot anything else that needs fixing. 
  1. Rebill and repay. If your internal audit and CAP were successful, you’ll have discovered missing or insufficient documentation. Report it. You may have also have found instances of incorrect payments. Rebill and repay. Yes, it will cost your hospital money. But not nearly as much as a full-blown government audit. A Department of Justice investigation could end up costing you time, legal fees, and FCA triple damages. 

Patient demand for telehealth isn’t going away. Neither are the costs of noncompliance with telehealth regulations. As the public health emergency expires, fines from regulators and denial of claims from payers are sure to add up. The best way for your healthcare organization to solve these potentially massive financial problems is to work together to prevent them. Proactively partnering with colleagues in all relevant departments, your compliance team can lead the efforts to identify and fix issues before they become major problems. That way, you’ll be able to provide the telehealth services patients want in compliance with what the regulations demand. 

It’s a big effort to keep your compliance champions connected and communicating. See how YouCompli can help you manage the rollout of new regulations and verify best efforts to regulators and your board. YouCompli is the only healthcare compliance software combining actionable regulatory analysis with a simple SaaS workflow. 

Differing state regulations make telehealth compliance more complex

The beauty of telehealth is that it connects patients and providers through technology that transcends boundaries. But when that connection crosses state lines, your healthcare organization could find itself responsible for complying with regulations from jurisdictions hundreds, maybe thousands, of miles away.  

Or from states just down the road. 

Many of those are stricter than the federal regulations, and many cover issues that the federal government doesn’t. Here are some of the key issues to look out for. 

Related: Growth in telemedicine could mean trouble if you are not careful   

Differing reimbursement structures and rates 

Reimbursement structure and rates vary by state and form of telehealth. For instance, all states pay Medicaid reimbursement for some form of live telehealth, but in different ways, and all states reimburse for interactive, real-time telehealth. However, only 14 reimburse for sessions where the patient records a call for later physician review (store-and-forward), and only 22 reimburse for remote patient monitoring of recently discharged hospital patients. There are eight states that reimburse for all three telehealth methods. 

There are two opposite views about reimbursement rates. One view is that a service is a service, so being virtual or in person shouldn’t affect reimbursement. 

The other penalizes telehealth for its efficiencies. In face-to-face visits, “there are built-in inefficiencies that isn’t time spending with the person,” says Dr. Katherine Dallow, vice president of Clinical Programs at Blue Shield Blue Cross of Massachusetts. “I probably spend somewhere between two to five minutes per patient moving from one room to another or pausing to document or checking something on their file or handing something off.” With less provider time and less pro rata overhead, some states reason, there should be less reimbursement. 

Forty states have their own private payer telehealth reimbursement policies, and six have private payer parity laws requiring the same reimbursement for in-person and telehealth care. 

Stricter privacy protections 

The Health Insurance Portability and Accountability Act (HIPAA) is the federal umbrella protecting privacy and confidentiality of patient records, but states are allowed to go beyond it. Many do. 

For example, if there’s a breach of privacy, HIPAA requires that the patient be notified within 60 days. Some states shorten that to 30 days, and California shortens it to ten. Some states also require hospitals to notify the state attorney general and the three major credit reporting companies: Equifax, Experian, and TransUnion. If there’s a breach of an out-of-state telehealth patient’s confidentiality, do you know what the originating state requires? 

Multi-state provider licensure 

Almost all states require physician licensure where the patient is (also known as the originating location). Same for nurses, nurse practitioners, physicians’ assistants, clinical psychologists, registered dieticians, and physical therapists. Different states have different licensing procedures, and there’s no federal umbrella. That’s something you’ll need to look out for, not only with faraway states, but also in New York, New York; Chicago/Hammond, Ind.; Texahoma, Texas/Okla.; or any of 84 other communities that straddle state lines. 

(Speaking of licensure, is your hospital licensed to provide telehealth services? In how many states?) 

Can doctors prescribe online? 

State regulations for phone-in prescriptions from the late 1990s adapt pretty well to online prescriptions today. The problem is, they differ from one state to the next. Different states have different regulations on just what a valid prescription is. About whether the doctor can prescribe without seeing the patient first, and whether seeing a patient on a computer screen is really “seeing.” About whether there has to be a previous doctor/patient relationship, and whether that relationship can be remote or has to be face-to-face. 

Related: Interstate regulations aren’t the only telehealth complexity. Check out this blog post for more: Telehealth compliance considerations: looking ahead. 

Two ways to keep up; one is practical. 

Complying with more than 50 sets of regulations takes a lot of attention to detail and a lot of reading. One way to keep up is with sheer effort: health organizations designate one or more people to read and track all the regulations that affect them.  

A better, more practical way is to rely on expert compliance professionals and nationally respected law firms to keep you up to date on interstate issues in telehealth regulation. YouCompli users select the agencies that matter to their organizations and receive updates and resources to help them know about new regulations, decide their applicability, manage policy changes, and verify compliance.  

Are you looking for ways to track telehealth regulations in all the states your patients receive treatment? Take a look at YouCompli, the only healthcare compliance software combining actionable, regulatory analysis with a simple SaaS workflow.  

Jerry Shafran is the founder of YouCompli. 

Take as directed: Medication compliance and the Compliance office

Working toward higher rates of patient medication compliance is a critical component of patient care. That includes communicating what the medications are, what they do, and how to take them. Providers are keen to ensure they provide clear directions and to be sure patients can pay.  

It’s no wonder they take such care: Each year, about 125,000 Americans die due to poor medication adherence, according to the American Heart Associationi. Improper compliance practices come with a hefty price tag of $528 billion in annual expenses, according to a 2019 OptimizeRx surveyii.  

What’s more, medication mismanagement is a strong predictor of hospital readmission rates. Individuals who failed to take prescribed medication as directed had a 20 percentiii chance of hospital readmission within 30 days, compared to 9 percentiv for patients who take meds as directed.  For the compliance officer, keeping hospital readmission rates low is crucial to avoid wasteful spending, per the Centers for Medicare and Medicaid guidelines.    

So many factors contribute to whether a patient properly follows through with medication instructions. Providers and administrators alike do their best to put systems and communications in place that make compliance easier. While not within a compliance officer’s direct control, there are policies and procedures that can help hospitals comply with CMS requirements to lower readmission rates. This helps facilitate better health outcomes and increased quality of life for patients.    

So how can you ultimately help patients improve medication management skills? Here are a few tips you can include in your medication compliance plan to help reduce readmission rates. 

Discuss side effects 

Patients who experience side effects may stop taking their medication altogether; without discussing this decision with their healthcare provider.   

That’s why it’s so important for doctors to discuss common and possible side effects with patients.  

Work with healthcare providers at your facility about how they can discuss any treatment plan changes to lessen the chances of side effects. Make it known that the treatment plan may include adjusting the dosage or changing the medication altogether.  Cut Out Distractions 

According to BMC Health Services Researchv, three out of five patients often forget to take their medication.   

Are distractions the main culprit? Encourage providers to discuss the importance of taking meds at the same time each day.  

Maybe patients can use a cell phone alarm to set up reminders. Taking multiple medications at different times? The workaround may be to set other alarm times for numerous times during the day.  

To make things even easier on patients, providers may consider prescribing once-daily medications.  

Providers may consider collaborating with the patient on the best time to take the medications when distractions are at their lowest.  

Money worries 

Sometimes the issue of medication compliance comes down to cost. About 70 percentvi of physicians link high prescription costs to a lack of medication adherence.  

To save money, they may ration meds or not take them at all.  

In a study published in Circulation, viione in eight patients with heart disease didn’t take prescribed medication because of the expense.  

Luckily, there are resources such as GoodRx, an app that allows anyone to shop at local pharmacies for the lowest prescription medication prices.   

Doctors can also prescribe generic versions of meds whenever possible to cut back on costs.   

Communicate more 

Poor communication is a deterrent to medication compliance, which is in turn linked to poor health outcomes.  

Fortunately, Motivational Interviewing can help. With Motivational Interviewing, health care providers are encouraged to ask open-ended questions beginning with What, Why, How, and When during discussions about medication usage. This technique is shown to improve behavioral change and adherence, as reported in Perspect Public Healthviii.   

This PDF by The Motivational Interviewing Network of Trainers provides more information on motivational interviewing.  

Medication compliance helps patients experience better health outcomes, reducing readmission rates and helping the hospital avoid tripping CMS’s indicators for fraud, waste and abuse. While much of the responsibility lies with the patient, hospital policies and procedures can help ensure the patient has the best possible chance to understand and comply with medical guidance.  

YouCompli helps healthcare facilities know about regulations, decide if they apply to them, manage policy and procedure rollout, and verify compliance efforts. Learn more 

i American Heart Association 
ii OptimzieRX survey 
iii 20 percent 
iv 9 percent 
v BMC Health Services Research 
vi 70 percent 
vii Circulation 
viii study 

Yes, worker fatigue is a Compliance concern

How does worker fatigue affect a healthcare organization’ s level of regulatory compliance?  

It turns out, employees who are not getting enough rest have a higher chance of making mistakes or performing their work at a sub-standard level. And in healthcare, this can mean increased non-compliance with facility policies and adverse effects on patient care.  

Worker fatigue during a pandemic 

Healthcare workers have always been at risk of fatigue, particularly with the traditionally long shifts for residents and the high stakes of patient care. The pandemic adds the unknowns of treatment, grief over lost patients, fear of catching the virus and missing family and routine. Unfortunately, this dual fatigue- at work and at home – increases the risk for errors around patient care and other highly regulated elements of healthcare.  

Worker fatigue and increased mistakes 

Workers who are fatigued may not have the same ability to focus on their tasks.  For example, when sending a fax from the hospital to a primary care office on behalf of a patient, a nurse might type in the wrong fax number, thus sending protected health information (PHI) to the wrong person. Or worse, an employee may click on a link embedded in an email that is associated with malware and cause a breach. These are just two examples of how worker fatigue could cause compliance concerns.  

Worker fatigue and decreased quality of work  

Similarly, when people are fatigued or burned out, the quality of their work and judgment can decrease.  For example:

  • A usually conscientious employee may cut corners and not ensure a signature is obtained on a patient consent for surgery. 
  • A contract manager may upload a new contract but forget to obtain a required business associate agreement (BAA) form.  
  • A compliance audit may show that a Human Resources employee delayed scheduling flu vaccines and tuberculosis test for a group of new employees. 
  • A nurse may leave confidential patient information showing on a computer screen at the nurses’ station when called away to answer a nurse call light.  

How Compliance can help 

Helping staff stay well rested doesn’t fall just to the Compliance team, of course. But Compliance is a stakeholder and can partner with Human Resources to make sure the organization prioritizes reducing worker fatigue and supporting employees’ wellbeing. 

  • Compliance professionals can identify regulatory risks and help prioritize issues and develop materials for staff meetings to reinforce the need for adequate rest. Check out these CDC guides for material:
  • Human Resources can create and offer support such as include peer support programs, supporting mental health paid time off, and referrals to the organization’s employee assistance (EAP) program. (An EAP is a work-based intervention program – like counseling – designed to assist employees in resolving personal problems that may adversely affect their performance.) 
  • Hospital administration can work with department heads to make sure shifts are scheduled in a way that allows for adequate rest. 

The issue of worker fatigue is rooted in every aspect of a healthcare organization’s operation. People are passionate about their work and want to care for their team and their patients. Managers are doing their best to schedule people appropriately, but COVID has made existing staff shortages worse. A reminder from the Compliance team may help everyone in the organization take better care of themselves to ultimately deliver better care. 

Keep on top of regulations affecting your organization and make sure those regulations are translated into policies and procedures that affect patient care. YouCompli customers have access to notifications about changes to regulations, resources to inform policy and procedure updates, and tools to track compliance. Contact us today to learn more. 

Denise Atwood, RN, JD, CPHRM 
District Medical Group (DMG), Inc., Chief Risk Officer and Denise Atwood, PLLC 
Disclaimer: The opinions expressed in this article or blog are the author’s and do not represent the opinions of DMG.  

Denise Atwood, RN, JD, CPHRM has over 30 years of healthcare experience in compliance, risk management, quality, and clinical areas. She is also a published author and educator on risk, compliance, medical-legal and ethics issues. She is currently the Chief Risk Officer and Associate General Counsel at a nonprofit, multispecialty provider group in Phoenix, Arizona and Vice President of the company’s self-insurance captive.  

Telehealth compliance considerations: looking ahead

Telehealth seems to be here to stay, even as the Coronavirus pandemic begins to recede in the United States. It’s a good time for healthcare institutions to make sure their telehealth practices hold up outside of emergency circumstances. 

From a compliance perspective, that means  patient privacy and technology, valid consent for treatment, visits with minors, and interstate care.    

 

Patient privacy in telehealth

Patient privacy is just as important in telehealth as it is for in-person visits. This includes ensuring the provider conducts visits in a private space and documenting the visit in a secure medical record.   

During the Coronavirus national public health emergency, the federal government has some enforcement discretion with telehealth. Regulators can choose not to impose penalties for Health Insurance Portability and Accountability Act (HIPAA) violations if they see that a provider took precautions to protect patient privacy provider. Good faith might mean using a platform like Microsoft Teams, Zoom, or WebEx and patient-specific passcodes – and still having a privacy breach. In a case like this, the regulator has the discretion not to impose fines under HIPAA. 

 

Consents and visits with minors 

Developing a process to obtain consent to treat before the first visit can help you comply with consent requirements. This may include mailing or securely emailing the consent to the patient (or parent or legal guardian) the week before the telehealth visit and having the patient send it back.  This gives the provider time to answer the patient’s questions about consent for treatment.   

For urgent telehealth visit, make sure there are policies in place to address telephone/verbal consent or to obtain two provider consents.  If your system allows, you may be able to electronically send the consent. The patient can sign it online so you can add it to the electronic health record.  

Whatever method to obtain consent your organization chooses, ensure there is a policy addressing the proper procedure and educate the team on the policy.   

For telehealth visits with minors, try to follow the same process as for in-person visits. That means you should obtain the consent to treat and have it signed by a parent or legal guardian.  Then have the parent or legal guardian attends the telehealth visit with the minor patient.  This way diagnosis, care, and treatment plan can be discussed with the patient and the parent or legal guardian at the same time.  

 

Crossing state lines for telehealth

Things to consider if the patient and provider are not conducting the telehealth visit in the same state: 

  • Licensing: Some state licensing boards have reciprocity. Some may not require an additional license in compact states while others may require a temporary or actual license to provide care in that state. This often applies to care provided via telehealth. 
  • Prescriptions: Can you prescribe across state lines? Avoid compliance issues by sending the prescription to a pharmacy in the provider’s “home” state. Then have the patient request a pharmacy-to-pharmacy transfer of the prescription. 
  • Your insurance: Does your medical professional liability (MPL) insurance provide coverage if you are out of state? How about if the patient is located outside your “home” state? Contact your MPL insurer to be certain you have coverage in the event of an out of state lawsuit. 
  • The patient’s insurance: What will the patient’s insurance cover for visits conducted out of the patient’s “home” state?  Be sure to verify this before the patient’s telehealth visit to ensure proper billing and reimbursement for the visit and to decrease billing denials.   

Considerations for adding telehealth as a service line 

There are resources available for organizations considering adding telehealth as a permanent service line. YouCompli can help you understand which regulations apply to you, stay on top of changes, and manage implementation.  

You can also find many free resources online:  

For many types of visits, patients love the option of telehealth. As providers work to be sure that they continue to deliver quality care, Compliance teams have an equally big job to be sure the systems and processes are in place to support that experience. 

Keep on top of regulations affecting telehealth and making sure those regulations are translated into policies and procedures that affect patient care. YouCompli customers have access to notifications about changes to regulations, resources to inform policy and procedure updates, and tools to track compliance. Contact us today to learn more. 

Denise Atwood, RN, JD, CPHRM is the Chief Risk Officer at District Medical Group (DMG), Inc., vice president of DMG Insurance Company (DMGIC), and owner Denise Atwood, PLLC.   

Disclaimer: The opinions expressed in this blog are the author’s and do not represent the opinions of DMG. 

Denise Atwood, RN, JD, CPHRM has over 30 years of healthcare experience in compliance, risk management, quality, and clinical areas. She is also a published author and educator on risk, compliance, medical-legal and ethics issues. She is currently the Chief Risk Officer and Associate General Counsel at a nonprofit, multispecialty provider group in Phoenix, Arizona and Vice President of the company’s self-insurance captive.  

Communicating Compliance Terms in Plain English…

communicate compliance terms in plain english

If you have ever been new to a particular field of the workforce, such as healthcare compliance, you know all too well that the language used by coworkers can sound foreign, like gibberish, or “alphabet soup.”  As we continue to work in the field though, we too, start speaking the language.  However, while that may be ok for conversing in the compliance department, it still be confusing if we are trying to communicate with, or to educate, other functional areas of the healthcare organization.  Without knowing the terminology, the message we are trying to convey is unlikely to be understood when received.

Alphabet Soup

Take a look at an example of terminology just starting with the letter “A” from the Office of the Inspector General Work Plan (reference below):

  • ADAP AIDS Drug Assistance Program (note this one includes an abbreviation in the definition);
  • AI/AN American Indians and Alaska Natives (I, for one, was unfamiliar with this abbreviation);
  • AIDS acquired immunodeficiency syndrome;
  • ALF assisted living facility;
  • ALJ administrative law judge;
  • AMD age‐related macular degeneration (while I have heard of macular degeneration, I did not know this was a standard abbreviation);
  • AMP average manufacturer price;
  • ASC ambulatory surgical center;
  • ASP average sales price; and
  • AWP average wholesale price.

Say I am talking to another seasoned compliance professional in front of a new employee.  Using the above “A” acronyms only, the conversation may sound something like this,

“Based on the billing audit, I see we are not receiving contracted AWP reimbursement under our AI/AN contract for ALF patients with AMD.”

As you can imagine, a new employee might be confused by the acronyms and terms communicated instead of using common business English.  Sometimes just saying the entire word instead of the abbreviation is a good place to start, so instead of saying AWP say average wholesale price.

Repetitive Communication

In order to improve communication between seasoned compliance professionals and other members of the organization, it is important to use repetitive teaching strategies.  In addition to saying the entire compliance term and the abbreviation, be repetitive and write out the compliance term in addition to the abbreviation in written communications.  That way staff become more familiar with compliance terminology and it becomes a part of their daily vocabulary.

Knowledge in Practice

When it comes to any industry, including healthcare, it is easy to throw around acronyms and jargon that is familiar and efficient.  However, it is important to be aware of who you are talking to, and therefore make sure they clearly understand whatever it is you are communicating.  Translate and reword industry terminology in emails, policies and teaching materials where necessary in order to improve communication and understanding.  Better compliance will ultimately be the result.

PRACTICE TIP:

  1. Regularly evaluate training and orientation materials to ensure industry specific terminology is defined and understandable.
  2. Utilize the youCompli system as a centralized hub for new and existing compliance processes and utilize the included model procedures throughout the various areas of your organization.

RESOURCES:

Health Care Compliance Association (HCCA) Compliance Dictionary found at https://www.hcca-info.org/publications/compliance-dictionary

Health and Human Services (HHS), Office of the Inspector General  (OIG), Work Plan Appendix B: Acronyms and Abbreviations found at   https://oig.hhs.gov/publications/workplan/2011/wp09-appx_b_acronyms.pdf

Denise Atwood, RN, JD, CPHRM

District Medical Group (DMG), Inc., Chief Risk Officer and Denise Atwood, PLLC

Disclaimer: The opinions expressed in this article or blog are the author’s and do not represent the opinions of DMG.

Denise Atwood, RN, JD, CPHRM has over 30 years of healthcare experience in compliance, risk management, quality, and clinical areas. She is also a published author and educator on risk, compliance, medical-legal and ethics issues. She is currently the Chief Risk Officer and Associate General Counsel at a nonprofit, multispecialty provider group in Phoenix, Arizona and Vice President of the company’s self-insurance captive.  

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