April 2013 Health Care Bulletin SPRING CLEANING – DUST OFF YOUR COMPLIANCE PROGRAM MANUAL AND TAKE SOME PRACTICAL STEPS TO REINVIGORATE YOUR PROGRAM. Compliance program fatigue is about how you can do a little Spring developed, the manual you were nothing new. Over at least the last 15 cleaning, dust off your compliance given or the manual the company years, health care organizations program, reinvigorate your efforts purchased is mostly useless to you have jumped in head first, put and do something meaningful for from a practical and operational together detailed manuals and taken your organization that produces perspective. The language used, the the plunge. However, reimbursement results and uses resources efficiently topics covered and the process just cuts, quality initiatives, RACs, ZPICs, and effectively. Below you will find 6 don’t translate to effective whistleblowers, physical plant suggestions that involve blowing off compliance in your organization. If it renovations and simply significant the dust and thinking about is that bad, burn it and start over. industry challenges got in the way of improving your compliance program Although, drastic action like that is sustaining an efficient and effective efforts. normally an anomaly. What you compliance effort. Health care should be prepared to do is to re- Get a fresh read on your organizations have also become write or reconfigure portions of what manual – desensitized to the barrage of you have to make them more user- Take your manual off the shelf and compliance education, enforcement friendly as well as updated with have at least one senior manager, press releases, audits and reviews current thinking and regulatory not part of your compliance function, and other shock-value requirements. As an example, ACA read through the entire manual. Give communications on the importance and certain significant legislation them a Starbucks card or a nice of regulatory compliance. In that before it made some major changes fleece with the corporate logo on it vein, this very article may get lost in to the federal fraud and abuse laws. for their time. Ask them to give you the shuffle, although, we hope it If your program manual was written an unfiltered and honest assessment doesn’t. 7-10 years ago, it is very likely it is of the content and their not current. An efficient and effective compliance understanding of the content. Ask effort with your organization is Educate employees on ethical them to let you know all they can extremely important, if only as an and appropriate behavior, not about what seems to work, what insurance policy against government on the treble damages that does not work, what makes sense, scrutiny. Additionally, the Patient can be assessed under the what they don’t understand and Protection and Affordable Care Act of Federal False Claims Act – anything else they can add. Be 2010, H.R. 3590 (“ACA”) includes prepared for some serious criticism Dusting off your program also requirements that CMS implement and use it to your advantage as you involves taking a good look at your mandatory compliance program analyze whether or not your manual employee education. Pull out that requirements for all providers and accomplishes what you expect from PowerPoint presentation that you suppliers. In a distinct section of it. have HR using with all new ACA, nursing home mandatory employees. When you read through compliance programs were given a Burn your manual and start your educational materials are they specific implementation timeline. over, if you have to – focused on appropriate, ethical and What we hope to accomplish with You don’t want to hear this, however, compliant behavior in a way that this article is to get you thinking you may find that the manual you
makes your employees “buy-in” to internal or external personnel and Respond to identified issues – your corporate culture of have quality assurance reviews or If there is only one pearl you take compliance? Or, are they focused on audits done in the same manner. from this article, take this one – when explaining to a porter in an However, if you dug deep into these you are approached with a concern institutional health care setting what separate processes, you often find or complaint – do something the penalties for non-compliance with that somewhere between 70-100% of meaningful to address it. Compliance the Federal False Claims Act are? If the work being done in these reviews related concerns come to the your answer is the latter, it is time to or audits overlap. However, there is attention of the compliance officer rethink how you are implementing no connection between compliance and senior management on a pretty your compliance educational efforts and QA to get these activities frequent basis. Doing something to make them effective. Retool those completed more efficiently and meaningful to investigate, materials to garner respect, buy-in effectively. The compliance understand, mediate and deal with and a culture of compliant and department can be significantly the issue is likely the most important ethical behavior from employees at amplified simply by ensuring that thing your compliance program can all levels. these connections exist and do for you. If you are not doing that analyzing how to make the best use effectively, your program simply is Most importantly, teach your of the available resources. In most not working. employees how to utilize a “smell- cases, you can make the compliance test” mentality. Every employee Creating good will with employees, officer way more than a one person doesn’t always have to understand ensuring that you have developed a band by simply integrating internal the exact ins and outs of a statute or culture of compliance and simply functions and making the appropriate regulation. However, they need to meeting current and future connections between high and mid- have an inner sense of when mandatory compliance requirements level management. something does not “smell” right and necessitate – doing something they need the incentive to talk to meaningful. Your compliance Incentivize compliance and someone within the organization program will fall flat on its face make your employees more about it in order to get the right quicker than you can imagine when accountable – answer or get comfortable with what you are, by design, inviting Creating a culture of compliance can concerned them. employees to raise issues that bring an entirely new perspective to concern them but then failing to take your employees and add to the The Compliance Officer is not meaningful action to address those stickiness they feel to their employer. a one person band, take a issues. Meaningful action requires a Compliance program incentives such look and you will be surprised well thought out response plan to the as give-aways for participation in at what you find – issue and some feedback to the voluntary compliance education can Many large and small organizations reporter about what the company is work wonders, recall the Starbucks have one individual assigned either doing to address the issue. Make card mentioned earlier. However, full or part-time to the organization’s sure you close that loop. compliance program efforts with compliance efforts. While the amount employees should include carrots If you are solely focused on of resources dedicated to compliance and sticks. Employees need to meaningfully doing something about is an inherently individual exercise of understand the necessity and reported issues and responding to each organization, effectively importance of compliant and ethical questions, you will find your program connecting that one person to other conduct. Are you currently asking is much closer to meeting its goals functional units within your employees on a regular basis to let than you imagined. With that said, organization is an imperative. Most, if you know whether they are aware of this is not an excuse for reactionary not all, organizations have very conflicts of interest or compliance compliance efforts. In fact, it’s a significant internal efforts designed to related concerns? A compliance hot- reminder that to be effective you meet quality assurance, risk line poster only goes so far and it cannot only focus on process but management, reimbursement or does not create a feeling that “my have to act appropriately to address other business objectives. The company cares” with most identified issues in every compliance officer is, more often employees. However, regularly circumstance. Don’t dismiss the than not, operating outside of those asking employees for feedback and comment of a mid-level manager in internal information flows. Creating whether or not they have observed the hallway because it wasn’t an efficient and effective program or been concerned about any reported through the hot-line. Do requires organizations to get all of business conduct will give them the something about it and circle back to those efforts collaborating and understanding that compliance is an that manager, effective and efficient working together efficiently. important function within the compliance programs do that every Organizations often have compliance company and is a necessity. day. review or audits conducted either by
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