Earlier this month, I had the pleasure of co-presenting the first in a series of 4 webinars with Felicia Sadler of Prophecy Health. The session was entitled "Keeping Up & Staying Ahead: The Components of an Effective Compliance Program" and offered a primer on the many innate considerations in crafting a comprehensive compliance program. First things first, a one-hour session can only scratch the surface of a topic such as this. Felicia did an amazing job of introducing a number of key drivers and requirements and providing resources to circle back to dig deeper on any given point.
Felicia's comments began with a few reality checks: implications of Stark Laws and consequences of false claims and coding. In addition, she highlighted the financial impact of NOT having a proper compliance program due to total culpability scores increasing fines. The numbers on this were staggering.
Next Felicia covered 7 key elements of an effective Compliance Program:
- Policies and Procedures
- Compliance Officer Assignment
- Training and Education
- Hotline Administration
- Responsiveness to Allegations and Detected Offenses
- Auditing and Monitoring
- Investigation and Remediation
The first half of the session concluded with a few suggestions to make compliance a core value of the organization by reporting concerns and engaging the Board as well as frontline staff. Felicia's powerful parting thought is one that really sticks with you: the absence of a Compliance Program = Russian Roulette. In closing, an overview of what's new and coming from OIG in 2014 was offered including hot topics such as anticipated patient stays of less than 2 nights being treated as outpatient.
My portion of the presentation transitioned to how to use the intranet to support compliance. A few key suggestions were:
- Compliance page with hotline information and an electronic fillable form to anonymously submit concerns.
- Tips and links to resources from various regulatory agencies.
- Policies and Procedures Management: regulatory updates, access and read acknowledgement by staff, review reminders and audit trail.
- Licensure verification and exclusions databases as reference for HR and credentialing.
- Communicate changes, critical information, and requirements to nursing staff with departmental blog.
- Online Class Registration as well as publishing videos and other materials to support training and education requirements.
- Board page: progress and updates on internal audits.
- Policy management software
Our goal in this session was to provide an outline of requirements and considerations to develop a Compliance Program combined with suggestions to tame the internal communications needs to implement the program. We are equally excited about the remaining 3 sessions in the series: Engaging Your GPS to Navigate a Pay-for-Performance System Under the Affordable Care Act; Using Technology to Improve Patient Safety; and Strategy and Optimization of Lean and Performance Improvement Initiatives.
We invite you to view the recorded Compliance session. What aspects of your hospital's Compliance Program have you found to be most critical?