On a daily basis, compliance officers are asked to find solutions to a variety of operational requirements. For example, consider a regulatory change requiring the organization to adjust an operational process in order to bill for a particular service. In this case, the solution must be compliant and operational-friendly, but who’s responsible for making that happen?
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The revenue cycle is the process that starts with a patient’s initial appointment and ends with full payment for services. It encompasses all the administrative and clinical functions that contribute to collecting patient service revenue. For healthcare organizations that provide services to patients, the revenue cycle is the organization’s financial lifeblood.
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“When it comes to the compliance program, effective communication is essential for building strong relationships, resolving conflicts and gaining buy-in. One of the most valuable interpersonal tools to help you achieve these goals is assertive communication. It allows you to express your thoughts, needs and boundaries in a clear and respectful manner.”
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Traditionally, many healthcare compliance programs have left the work of patient safety and quality to other departments. However, according to the Health and Human Services (HHS) Office of Inspector General (OIG), “Entities should incorporate patient safety/quality oversight into their compliance programs.”
OIG’s recent emphasis on patient safety and quality is not necessarily a call for compliance programs to take over these efforts. Rather, it’s a reminder that a compliance program should be designed to address the significant risks health care organizations face, which includes patient safety and quality of care.
How can your compliance program answer the OIG’s call and include patient safety and quality in your oversight efforts? This blog explores four practices to integrate safety/quality concerns into compliance practices.
1. Build a Strong Compliance Committee
2. Provide Safe Reporting for Safety/Quality Concerns
3. Get Your Governing Board Involved with Quality of Care
4. Nurture Relationships with Quality and Safety Leaders
Most mature compliance programs have a compliance committee in some form or fashion. To build stronger safety and quality representation, include individuals responsible for quality assurance and patient safety as members of the committee.
A strong compliance committee should ensure that appropriate auditing and monitoring of patient safety and quality take place on a regular basis. The OIG goes as far as suggesting that “Compliance committees of entities directly furnishing patient care, particularly entities such as hospitals, long-term care facilities, and other entities providing residential care, should also assess staffing for nursing, therapy, and other clinical services to ensure that the entity has the appropriate quantity, quality, and composition of care providers.”
Compliance programs establish lines of communication for reporting concerns, and anyone aware of patient safety or quality concerns must know how to report such incidents or issues. They must also have confidence they won’t face retaliation.
Awareness of incidents involving safety or quality is often the first step in developing a correction plan, so it’s essential that those who report know how their information is protected.
Steps have been taken at the federal level to encourage reporting and analysis of medical errors. The Patient Safety Act and Rule provide federal privilege and confidentiality protections for patient safety information called the Patient Safety Work Product (PSWP). PSWP includes data, reports, records, analyses and written or oral statements related to patient safety events.
More about the types of protections at the federal level can be found here: https://www.hhs.gov/hipaa/for-professionals/patient-safety/index.html
Governing boards of healthcare entities have ultimate accountability for ensuring quality of care, and their involvement can also ultimately benefit compliance outcomes.
There are many resources available to educate your board on their responsibilities related to quality. These include:
Read and share these with board members to help them stay informed more easily.
Compliance departments aren’t expected to take over the detailed, day-to-day management of quality and patient safety programs. However, it’s essential that compliance leaders develop productive working relationships with leaders and in-house experts within the organization’s quality and patient safety programs.
One way to develop productive working relationships is to better understand what quality and safety leaders do. A good resource for learning more about the standards, goals and language often used by quality and safety leaders is the Institute for Healthcare Improvement or IHI (https://www.ihi.org/).
This organization offers both introductory, intermediate and advance learning opportunities for those who want to become better-versed in quality and patient safety topics. The IHI Open School (https://www.ihi.org/education/ihi-open-school) is a great place to start. And for those looking for more formal recognition, the IHI offers certifications, such as the Certified Professional in Patient Safety (CPPS)™.
The call for compliance programs to become more involved in an organization’s patient safety and quality efforts is getting louder from agencies such as the OIG. It’s also smart business practice.
In summary, this blog has covered four ways to begin the process:
With these practices in your toolkit, you’ll be on the path to a stronger, more effective compliance program.
And to help with overall regulatory analysis and operations, learn more about how YouCompli compliance software can support your mission. The tools include capabilities to easily map and track responsibilities across functions.
CJ Wolf, MD, M.Ed. is a healthcare compliance professional with over 22 years of experience in healthcare economics, revenue cycle, coding, billing, and healthcare compliance. He has worked for Intermountain Healthcare, the University of Texas MD Anderson Cancer Center, the University of Texas System, an international medical device company and a healthcare compliance software start up. Currently, Dr. Wolf teaches and provides private healthcare compliance and coding consulting services as well as training.
“It’s really simple – people get hooked on stories, and the tales stick with us. For example, once upon a time, there was a girl named Cinderella. Not only does that line open every fairy tale, but it also won’t leave your mind, no matter how old you get. That’s the same result you want for compliance communication and training, right?”
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“Compliance in healthcare isn’t just about meeting regulatory requirements – it’s about protecting patients, maintaining trust, and ensuring operational efficiency. Too often, compliance is treated like a separate function and oftentimes a bit disconnected from department heads, operations and leadership.”
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There have been many times where we have talked to auditors or inspectors who wanted to know if training occurred. While the answer was yes, there also have been times where we didn’t have any concrete documentation to support it, save for the Outlook meeting invite with everyone’s name on it. Even more surprisingly, there have been times where that has been accepted. Now, call it chance, dumb luck, or we dodged a bullet, but this is not always the case.
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As compliance officers, we spend a lot of time focused on how others perform their jobs. However, being self-aware of how we do our own work is paramount for an effective compliance program.
Incorporating self-awareness into your healthcare compliance program can significantly enhance its effectiveness. For example, it improves your ability to empathize with the challenges operational leaders face when adjusting a process to meet a regulatory requirement.
To help build awareness, explore these 18 actionable tips for compliance officers.
Be aware of how your policies are viewed. Are my policies easy to read and understand? Do impacted staff follow the policies in practice? If not, why? Are they cumbersome to navigate from the end user’s perspective?
Tips for Better Compliance Awareness
1 – Clarity and Usability: Be aware of how clear your policies are. Ensure that the practices are easy to read and understand. Be intentional about avoiding jargon and using plain language. Also, engaging operational leaders who must live with the policies helps ensure the interpretation is clear.
2 – Real-World Application: Regularly assess whether operational staff are following policies in practice.
3 – User Perspective: Solicit feedback from end users to identify any challenges they experience when navigating policies. Be open to making necessary adjustments.
Self-aware compliance professionals must ask themselves questions like these: Am I physically present in my organization such that people know I exist, or am I hiding behind my keyboard? Am I getting to know others in the organization?
Tips for Better Compliance Awareness
4 – Physical Presence: Are you visible within your organization? Do you attend non-compliance related meetings, participate in organizational events, and engage with staff to foster relationships?
5 – Build Connections: Take the time to get to know others in the organization. This helps develop rapport, which builds stronger relationships that lead to establishing trust and improving your compliance culture.
Compliance Committee Engagement
With greater awareness comes greater engagement with colleagues. Use these engagement tips to raise your profile.
Tips for Better Compliance Awareness
6 – Awareness: Ensure that organizational leaders who are not on the committee are aware of the group, its members, and the role it serves.
7 – Role Clarity: Clarify the role of the compliance committee to both leaders and members. You can do this by sharing visual aids or other documentation that outlines responsibilities.
8 – Obligations Training: Regularly review and communicate the obligations of committee members to strengthen understanding and foster accountability.
Have I done enough training with our staff about a particular requirement? Am I clear with my audience about what I expect of them? Am I using examples that relate to their work when illustrating how the requirement applies to their job role? Understand your role in making sure this important compliance step isn’t neglected.
Tips for Better Compliance Awareness
9 – Relevance: Be mindful to tailor training to include examples that directly relate to your audience’s job roles. For example, when talking with physicians about safeguarding patient information under HIPAA, a common scenario is determining who can be involved in a discussion about a patient’s treatment plan.
10 – Expectation Setting: Communicate what you expect from staff and providers during training sessions. Make these expectations clear and achievable by answering these questions, “What actions do I need my audience to take?” and “What do I need them to know after I have trained them?”
Have I communicated with my audience about how to report issues? Do the staff feel comfortable reporting issues? If not, why? Have I educated them about how the hotline process works? The self-aware compliance leader cares about the answers and uses these tips to continually emphasize communication.
Tips for Better Compliance Awareness
11 – Reporting Mechanisms: Clearly communicate the process for reporting issues and concerns. You can accomplish this by explaining the process as if you were reporting an issue and asking yourself “What information would I want to know?” Also, it helps to use multiple channels (e.g., email, intranet) for accessibility.
12 – Comfort and Anonymity: Assess whether staff feel comfortable reporting issues. You can hold a random sample of individual discussions or conduct a survey. If they don’t feel comfortable, find out why, and take specific steps to overcome those concerns.
13 – Hotline Awareness: Educate employees about how the hotline process works and reassure them on confidentiality measures in place and why they are important (i.e. to ensure staff can trust the process).
The self-aware compliance leader constantly asks themselves about their performance, including investigations. Has my investigation been thoroughly conducted? Can I defend my work product to a government agency if we’re investigated or audited? Use this tip for more confident investigations.
Tips for Better Compliance Awareness
14 – Thoroughness: Ensure that investigations are comprehensive and well-documented by continually assuming you will need to defend your work in a courtroom or to a government regulator. Since conclusions of compliance investigations are based on fact, keep detailed records to support your findings.
Ask yourself these questions to get a sense of your awareness around program auditing. Am I communicating with those I’m auditing? Do they understand my expectations? Do I understand how they are performing the work being audited?
Tips for Better Compliance Awareness
15 – Communication: Maintain open communication with those being audited by clearly conveying your expectations and the purpose of the audit.
16 – Understand the work: Engage with operational staff during audits to make sure you understand how they are performing the work and any challenges they face versus making assumptions.
Sometimes compliance awareness is related to risk. Are you aware if the need to monitor an operational activity is connected to a medium-to high level of risk, or does it just seem like a good idea? An example would be how a department documents a service provided to a Medicare patient, so it is compliant with Medicare billing guidelines. Also has your audience been given a reasonable amount of training about requirements before you monitor their work?
Tips for Better Compliance Awareness
17 – Risk Assessment: Connect the need for monitoring to a defined level of risk instead of arbitrary reasons. Use risk assessments to guide your monitoring activities.
18 – Training Prior to Monitoring: Be mindful to provide necessary training to your audience regarding requirements before implementing any monitoring practices. Ensure they understand what will be monitored and why.
By prioritizing self-awareness and incorporating these tips, compliance officers can create a more effective, responsive regulatory program within their healthcare organizations.
Reach out to YouCompli if you’d like some ideas to guide your compliance strategy.
Jay is a compliance professional and consultant in Colorado. He is a healthcare lawyer with significant industry knowledge of the U.S. healthcare market. Over the past 20 years, he has worked for large for-profit and non-profit health systems and small physician-owned entities. In tackling the countless regulatory and operational issues for these diverse organization types, he has developed a deep understanding of the business of healthcare and the regulations governing the industry.
“Audit readiness in quality is no different than anything else – follow a pre-defined process to the letter, tweak it as necessary and continue to evolve it until it works for your organization. It’s not hard. People just panic because the auditor can shut them down. But you wouldn’t panic if you had a process to follow to minimize the damage.”
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