THE COMPLIANCE MINDSET: IT’S ALL ABOUT “DOING THE RIGHT THING”
Many times in the healthcare industry today, the mere mention of “compliance” brings negative thoughts among professionals, signifying the level of worry about adhering to regulations to avoid adverse consequences for their organizations. For this reason, Karen Bommelje, RN, BSN, HCS-D CHC, Senior Manager, Simione Healthcare Consultants, suggests that home care and hospice providers work to motivate their teams by re-positioning compliance as simply a matter of “doing the right things for the right reasons, which affect all aspects of your organization.”
In order to create a “culture of compliance”, the nurse executive and 20+-year home health/hospice veteran said organizations should start by assessing the level of knowledge and understanding about compliance, risk and ethics. The next step involves identifying the high-risk compliance issues that may be threatening quality, reimbursement or other vital components for survival in today’s high-scrutiny environment.
“Compliance is more than the presence of a regulatory expert in your organization,” explains Bommelje, “It is a process guided and supported by many people that helps everyone say and do the right thing, thus reaping the rewards of compliant behavior.”
The characteristics of a compliant culture begin with an organization that is true to its mission and core values, where executives express their commitment to compliance policies, encourage communication and feedback, and support the compliance officer identified to lead the way. “In high-performing organizations, interdepartmental communication and cooperation is commonplace, and department lines are blended with shared accountability for goals,” Bommelje says.
Instead of “a list of dos and don’ts”, compliance initiatives should be seen as quality improvement efforts that will benefit the organization. “We must work to be compliant through initiatives that are outcome-based and customer-driven,” Bommelje says, “with frequent, open communication, and recognition and rewards for efforts that lead to better compliance within the organization.”
Support for the compliance officer within an organization is essential in developing a culture that propels effective compliance plan monitoring and improvements. Everyone within a hospice or home care organization has a role in supporting the organizational compliance plan, which should include:
- Written policies and procedures
- A code of conduct
- Oversight by a compliance officer, compliance committee and governing body
- Regular education and training
- Specific provisions for monitoring/auditing, reporting/investigation, enforcement/discipline, and response/prevention
Additionally, Bommelje outlines these components for creating a culture of compliance in home health and hospice:
- Support from everyone for organizational mission and core values
- A compliance plan developed by leaders based on current regulations and identified risks
- Expectations that all managers understand specifically how compliance affects their responsibilities
- Allocation of appropriate resources to achieve and sustain compliance
- Clear lines of communication and accountability
Bommelje notes that regular upkeep of a compliance plan should include all of the following at least annually: a full internal review of the plan, oversight and documentation of key compliance strategies by the governing body, and a plan review and/or validation audit by an external expert. She recommends that these reviews be completed by professionals with a thorough knowledge of mandates by the Centers for Medicare and Medicaid Services (CMS), the Office of Inspector General (OIG), and other key measures related to clinical policies and procedures, billing and claims submission, quality and performance improvement activities, Electronic Medical Records (EMR), and human resources practices.
“Compliance plans need to evolve and change to address new circumstances,” Bommelje says, “and every agency has its own priorities and unique risks that make ongoing review a critical habit for survival.”
Beyond the government oversight that drives our growing focus on compliance, these principles and practices lay the foundation for organizations to do “the right thing” every time, thereby protecting their quality, reimbursement and reputation. “When you have compliance done right, you protect everything that is important. It makes accreditation, certification and reimbursement – our every reason for being in home health and hospice – count. An effective culture of compliance with a clear plan of attack pays ten-fold in terms of keeping home care and hospice thriving and always moving forward,” Bommelje adds.