Patient-Focused Elements of an Effective Healthcare Compliance Program

Use the OIG’s seven elements to guide and align healthcare compliance with compassionate, quality patient care.

Using the OIG’s seven elements as a guide to delivering better patient care 

Healthcare Compliance professionals tend to focus, rightfully so, on the regulations and organization requirements around providing quality patient care and keeping patients safe. But what if compliance officers focus on the impact these regulations have on a patient’s experience?  

Consider the seven elements in the OIG’s guidance on effective compliance programs. Of course, they concentrate on compliance and measuring the effectiveness of your program.

Yet they’re also key to providing a better patient experience. Below is a look at the seven elements and how each one shapes the way that patients perceive their experience. This reframing of the work of the Compliance department can help you engage your clinical and operational colleagues more effectively. It aligns your goal – an effective compliance program – with theirs – a great patient experience.

The OIG’s seven elements align quality patient care with compliance 

The connection to patient care for some of the elements is obvious. And there’s overlap among the elements, particularly regarding education and training. Altogether, the elements are a reminder of all the ways compliance officers influence how their organization provides patient care.

1. Implementing written policies, procedures, and standards of conduct 

This is among the most straightforward elements for demonstrating how compliance officers shape patient care. Complying with this element – from a patient perspective – means ensuring that staff are educated and aware of their roles in 

  • Protecting patients’ personal health information 
  • Billing patients’ services correctly 
  • Providing patients’ medical records when they request them. 

Compliance officers have three main roles in this. The first is to develop policies for staff, continually reviewing them to ensure they’re current. Next is to create standards of conduct for staff. Finally, the compliance team writes and implements ongoing staff education programs. All are critical for delivering superior patient care. 

2. Designating a compliance officer and compliance committee 

For patients, this element involves ensuring that they have a point of contact for filing a complaint or grievance. It’s also about enabling patients to report their concerns anonymously.

The focus is on the foundational work of maintaining a compliance program and keeping current on regulatory changes. It involves a range of compliance responsibilities, including gauging program effectiveness by evaluating for conflicts of interest, providing a venue for reporting to the organization’s board of directors or executive leaders, and developing and implementing an annual compliance workplan. 

3. Conducting effective training and education

Compliance officers fulfill this element in multiple ways, including by helping to ensure that patients can 

  • File a complaint or grievance without fear of retaliation or cancellation of future appointments 
  • Feel confident their care team knows what they are doing, and
  • Receive clear instructions on how to use the organization’s patient portal 

It’s about more than developing and implementing education programs for employees. It’s about compliance officers fostering a culture of compliance. This means conducting rounds or in-person education sessions with the employees to evaluate compliance-based knowledge and ensuring that training materials are easy to understand. Another key is recruiting and training compliance champions – individuals who can act as liaisons between patients, staff, and Compliance.

4. Developing effective lines of communication 

The fourth element involves making sure patients are comfortable asking about the organization’s policies and practices. It means ensuring that patients feel like they’re listened to at appointments and are treated like their health-related concerns are valid.  

Compliance officers can implement this element in several ways, including by

  • Conducting rounds or in-person education sessions with the employees to allow them to ask compliance-related questions 
  • Ensuring that employees know how to contact Compliance and how to find the compliance hotline number 
  • Checking in with compliance champions to see what’s happening in departments and clinics throughout the organization. 

5. Conducting internal monitoring and auditing 

In addition to monitoring and auditing, this element extends to patient privacy. For example, it means that when patients sit in the lobby or walk to an exam room, they can’t see or hear other individuals’ personal health information.
Among the compliance activities involved are making sure staff are educated on how to 

  • Protect patient confidentiality
  • Return overpayments to patients
  • Follow a compliance workplan for monitoring and auditing
  • Document and benchmark audit data

6. Enforcing standards through well-publicized disciplinary guidelines 

This element correlates to patient care primarily around privacy issues. It involves activities such as making sure patients are given sufficient time to read their admission paperwork and their rights under HIPAA. It also means enabling patients to ask questions about how to designate someone to receive their health information and share patients’ rights.

Again, this element requires compliance officers to provide staff education and training. It also involves reporting any compliance infractions to the board and the compliance committee, and in turn, ensuring disciplinary actions taken are consistent. 

7. Responding promptly to detected offenses and undertaking corrective action 

This is another area where compliance officers shape the front line of patient care. This element involves activities such as making sure patients

  • Receive a timely response to written complaints from a clinic manager 
  • Have billing problems handled promptly 
  • Are asked for the correct copayment during their visit 
  • Receive notification if their personal health information may have been compromised. 

In addition to conducting staff education and training in these areas, compliance officers are responsible for requesting corrective actions plans, as needed, and reporting disciplinary actions to the required regulatory body, if needed. 

Delivering a high-quality patient experience starts with building empathetic relationships with patients. Implementing the OIG’s seven elements can help compliance officers facilitate an organizational culture that prioritizes delivering quality patient care and showing patients empathy.  When a patient receives care at a clinic or calls with a complaint, showing that you care goes a long way toward providing a better patient experience.  

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.  

Never miss an article from YouCompli. Denise writes a regular column about the intersection of healthcare compliance and quality patient care.

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