Every day, with each interaction, practices are expected to do the right thing. This includes keeping patient information secure, maintaining confidentiality, documenting correctly, billing appropriately, monitoring quality standards, meeting medical necessity, following published guidelines and, most importantly, taking care of patients. It is virtually impossible to do this alone and empowering your staff to help can be a step towards remaining compliant.
The office of Inspector General (OIG) has published The Seven Fundamental Elements of an Effective Compliance Program (oig.hhs.gov). Reviewing these elements and determining how staff can assist will engage your team and ensure each member has a stake in doing the right thing!
Implementing written policies, procedures and standards of conduct:
Assign your current Compliance/HIPAA manual to one or more team members for review. If you do not have a current manual, assign the task to your team for completion. Encourage them to review all current processes and ensure that a written policy exists to support them. Ask them to review various websites, including Compliance 101(http://oig.hhs.gov/compliance/101/), created by the OIG, to ensure they are meeting published compliance guidance. Set up regular meetings to review their work and ensure the work they are doing adds value to your practice.
Designating a compliance officer and compliance committee:
Name a Compliance Officer for your practice along with a committee to assist in reviewing compliance issues. Create a charter for your committee and schedule regular meetings throughout the year to discuss potential issues in your office. Assign the compliance committee the task of determining what education needs to occur in your practice. Ask them to create the process and frequency for documentation and system audits. Consider peer reviews of work processes and have the committee members create training guides as needed.
Conducting effective training and education:
Once the Compliance Officer and committee have created the training requirements schedule various times throughout the year. Keep a log of the education topic, date and who attended. Consider having team members educate each other on new polices with a sign off to validate training and understanding. Use internal audit findings as a training tool during staff meetings.
Developing effective lines of communication:
Create an environment for staff to voice their concerns. Some practices create a concern box where staff can anonymously place issues they are not comfortable discussing in person. Have the compliance committee create a policy that includes anti-retaliation language to support your reporting processes. Ensure all staff members are aware that concerns need to be escalated.
Conducting internal monitoring and auditing:
Create internal and/or external audit processes for potential high risk areas including: documentation, system use and log in attempts. Consider additional audits to verify processes such as patient check in, claims submission and payment posting. Educate team members on the findings and update processes as needed to ensure compliance. Maintain records for all audits and education performed.
Enforcing standards through well-publicized disciplinary guidelines:
Create a policy and procedure that allows you to enforce compliance standards with your staff. Request staff input regarding the disciplinary action that should occur when team members are not following your direction. Disciplinary action should be escalated with continued non-adherence to your policies. Consider a verbal warning for the first offense, written warning for the second offense and continue to escalate up to and including termination. This policy is critical in protecting your practice against non-compliance.
Responding promptly to detected offenses and undertaking corrective action:
Finally, fix issues of non-compliance as you identify them. Continue to enhance processes, policies and education as needed. Your compliance program cannot be created and put on a shelf. It must be an integral part of the day-to-day work of you and your team. A strong compliance program protects you, your practice and your patients!!
Using a team approach helps to ensure your practice is a compliant one. Challenge your team to create an environment that allows all of you to take care of patients while remaining compliant! Work together to do the right thing!!