Faster Compliance Using “Command Signals”

You don’t want to waste time on regs that don’t matter to you!

Whether it’s a new reg from the Office of Civil Rights (OCR), the Centers for Medicare & Medicaid Services (CMS), or your state’s Health Department, one of the 1st steps required for compliance is gauging the new regs’ relevance to your organization.

We’ve analyzed and translated over 15,000 regulations into business requirements, Every business requirement we create includes relevance testing; we know how to do this…pretty well.

Here’s a powerful tip that will help you make the relevance decision quickly (and comply faster).

  • Create a list of command signals. These are words and phrases within a regulation that identify or “signal” compliance actions to be taken by regulated entities.  Command signals act as flags which help in the determination of relevance.
  • Break your list down between mandatory command signals, those requiring action, and permissive signals, those permitting action
  • When reviewing a regulation do a search for the command signals,. When you find them, it is likely you will find parameters which relate to whether or not the reg applies to you.

Here are some examples of command signals we use:

Mandatory Signals

  • Shall
  • Must
  • Should
  • Required to…
  • Obligated to…
  • Need to…
  • Have to…
  • Have until [Date] to

Permissive Signals

  • May
  • Can
  • Permitted to…
  • …is/are permitted
  • Allowed to…
  • …is/are allowed
  • …is/are optional

So if you are interested in faster compliance, think about building your own set of command signals. If you’re interested in learning more about our complete list (happy to share) contact me at jshafran@ .