By Pamela A. Cleveland
Some people fear change, and some embrace it. Some cling to the false hope that change will never come while others have learned the simple truth that change is the only thing that remains constant.
For those of us living in the world of healthcare, we know that government regulations, unstable political winds and shifting demographics make change inevitable. We also know, as American historian Joan Wallach Scott once wrote, “Those who expect moments of change to be comfortable and free of conflict have not learned their history.”
All change, even good change, can cause stress and open the door to errors, misinterpretations and confusion. That is why it is so important for all healthcare organizations to be judicious and have a plan and process in place when it comes to implementing regulatory changes. But ever-increasing regulations on the state and federal levels have caused business disruptions for many healthcare organizations who aren’t prepared to navigate the regulatory landscape or to recalibrate their operations so as to comply fully with new standards.
Successfully implementing regulatory changes is dependent upon a health plan’s or hospital’s operational areas working in partnership with its compliance department. Here are 10 tips to help make that happen:
- Knowing that change is inevitable and constant, each operational department should assign an accountable “owner” for compliance initiatives. This person will serve as a critically important liaison with the compliance department while interacting with appropriate individuals within their respective department—as well as their counterparts in other departments—to help ensure compliance with all new regulations.
- The compliance department’s role is to help assure that the organization’s business practices and transactions follow all relevant regulatory and internal guidelines. But this can’t happen without great communication and bringing everyone to the table. As such, the compliance department should distribute new guidance widely to ensure that they are received by all of the “right” people, including company vendors.
- Once received, the accountable “owners” in operations should review the new guidelines in a timely manner and, if needed, seek clarification from compliance to ensure a correct, complete and common understanding.
- The guidelines should then be shared with other departmental stakeholders that need to be aware of impending changes. It should be stressed that while compliance and operations may take the lead in this area, everyone has a role to play in maintaining compliance and taking responsibility for following procedures and regulations. It should also be stressed that healthcare organizations are held to exceptionally strict standards, regulations and laws from the federal and state levels; and violations of these laws can result in hefty fines and penalties, lawsuits and/or the loss of licenses.
- Each department owner needs to review their impacted policies and procedures in their area to ensure continued accuracy. Where needed or desirable, the policies should be updated and communicated out to all members of the department and other interested individuals.
- Health plans are required to have a documented process outlining how they oversee their vendors. Compliance needs to take the lead here by ensuring that FDR (first tier, downstream or related entity) vendors are notified of new guidelines and making sure they have a system in place to monitor vendors to assure the guidelines are being implemented fully and properly.
- The compliance department should also take the lead in calling and chairing a compliance meeting and/or subcommittee meetings in which all compliance liaisons are invited. This is the most effective way to ensure accountability and to track action items. It is critical that the liaisons attend the guidance sub-committee meeting to discuss the organizational impact of the regulatory change as a group and to determine all impacted departments and processes.
- Compliance should implement an organizational compliance-oversight monitoring plan to ensure non-compliance with these changes are reported to compliance for documentation and potential CMS notifications.
- At the same time, each operational area needs to implement its own monitoring plan at the operational department level to ensure that deficiencies are identified and corrected prior to becoming a compliance concern.
- Throughout the process and every day, organizational leaders should set the tone through transparent ethical behavior. This helps breed a culture of accountability that spreads through the organization and helps every staff member see why compliance is both necessary and important.
As frustrating as they may be at times, regulatory frameworks are essential for ensuring consistent compliance with basic standards … and these standards are necessary to ensure that every individual who accesses the system is afforded safe and secure healthcare. In the final analysis, that is what we all strive to achieve.
Pamela A. Cleveland, L.S.W., J.D., CHC, is chief compliance officer and vice president of compliance product strategy for Beacon Healthcare Systems, home to the healthcare industry’s leading compliance and risk management technologies that support all lines of business including Medicare, Medicaid, commercial, health insurance exchanges and risk-bearing entities. beaconhcs.com
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