Whitepaper

Why Surveys Should Guide Your Healthcare Compliance Solutions

Richard P. Kusserow | October 2015

Healthcare compliance surveys provide revealing data on how an organization’s compliance program is operating. Through an analysis of the result data you may found that healthcare compliance solutions are needed to close gaps or remediate risks.  Many organizations engage with healthcare compliance specialist who can provide customized and tailored healthcare compliance strategies. Other organizations utilize products already on the market that offer an off the shelf solution.

The results of the survey will guide the organization on whether to engage a healthcare compliance specialist, utilize a solution or a combination of both options.

The Impact of Surveys on Healthcare Compliance Solutions

Results of the Compliance Knowledge Survey can be helpful to identify what compliance healthcare solutions are needed. The compliance survey questions focus on the seven elements of an effective compliance program and are designed to identify employees’ level of awareness and understanding of the organization’s compliance program. Specifically, the Compliance Knowledge Survey groups the compliance survey questions into these specific areas:

  • Written policies and procedures
  • Designation of a compliance officer and a compliance committee
  • Conducting effective training and education
  • Developing effective lines of communication
  • Enforcing standards through well-publicized disciplinary guidelines
  • Auditing and monitoring
  • Responding to detected offenses and developing corrective action initiatives

Identifying What Healthcare Compliance Solutions are Needed

How can you identify which healthcare compliance solutions are needed? For guidance, I have addressed several of the compliance program elements and discussed appropriate healthcare compliance solutions.

Healthcare Compliance Policy and Procedures

First, written compliance policies and procedures are the guiding principles and actions for the workforce. Anytime the healthcare compliance survey indicates a weakness or a deficiency in this area the compliance policies and procedures need to be audited. In many cases, the audit will find that the documents warrant revisions.

There are two healthcare solutions that can be utilized. The first option is to engage with a healthcare compliance specialist that has the expertise to update and revise policies and procedures. The advantage of engaging with a specialist is exactly that, they are a specialist. They are knowledgeable on healthcare laws, regulations and program rules that the organization must comply with. Furthermore, they know how to interrupt those laws, regulations and rules into understandable policies and procedures for your workforce.

The second option is to purchase compliance policy and document templates from a healthcare compliance specialist or firm. Engaging with a healthcare compliance specialist may be cost prohibited for some organization. But that doesn’t mean you still cannot have robust and effective policies and procedures.

On the market today are companies, that specialist in healthcare compliance, that offer a suite of compliance policies and document templates. Look for a company that has the expertise in healthcare, maintains templates that are current with laws, regulations and rules and uses a template that requires minimal changes and edits by you. The last requirement is important. The purpose of using a document template is save you time. The template, therefore, should be easy to use with minor reworking on your part; realistically you should only need to edit the procedures section.

Effective Compliance Training and Education

Second, providing employees with effective training and education is essential to having an effective compliance program. When the healthcare compliance survey indicates deficiencies in this area the compliance training program must be reviewed. Specifically, look to the survey results to understand what about the training is ineffective or insufficient.

The survey results may show that employees are not aware of their requirement to complete annual compliance training or that the training did not adequately explain the purpose and operation of the compliance program or that employees were not sufficiently trained on compliance-related policies and procedures. These results specifically tell a compliance officer what areas in the training need to be revised, and perhaps enhanced with more content.

There are many healthcare compliance solutions for training. In today’s tech-savvy work environment, delivering training online is the most logical and cost effective solution. Look for a training vendor that can provide a customized compliance training program; an added bonus would be a vendor that develops the training for you.

First, the training must be customized to your unique organization. Compliance concerns for a skilled nursing facility are different from a teaching hospital. There will be similar compliance areas, e.g., HIPAA, False Claims Act, but the training must reflect only relevant compliance concerns. Secondly, engage a vendor that is a healthcare compliance specialist so that they develop the training for you.  Similarly with the policies and procedures, a healthcare compliance specialist are experts in healthcare compliance and will ensure that all major compliance concerns are sufficiently addressed and can be understood by all levels of the workforce.

Open Lines of Communication

Third, implement effective lines of communication for employees to report actual or potential wrongdoing. Making a hotline available to employees is not an option, it is a must do. Employees need a channel to report if and when they are not comfortable reporting directly to their manager or in-person to the compliance officer.

A weak hotline program will be revealed in the survey results. For example, the survey results may show that employees do not know how to use the compliance hotline or that they are afraid to report suspected wrongdoing or that they are not aware the organization has a non-retaliation and non-retribution policy for those who report suspected wrongdoing in good faith. The healthcare compliance solution in this case is to implement a robust hotline reporting program.

The best option is to utilize a third-party vendor. Why? First, employees’ confidence in the hotline program will increase, particularly in small organizations. Employees will truly feel they remain anonymous because the vendor does not know them, will not recognize their voice nor will their phone number be known, particularly when they call from work. Second, hotline vendors provide 24/7 call coverage will a call center associate.

Internal hotlines can at best have a voice mailbox activated for after hour calls. Employees are reluctant to leave recorded messages. Look for a hotline vendor that has experience with healthcare compliance reports and has current clients in the healthcare industry.

Conclusion

Compliance surveys can guide selecting the right healthcare compliance solutions for your compliance program. The healthcare compliance strategies outlined above can greatly improve your compliance program.

About the Author

Richard P. Kusserow established Strategic Management Services, LLC, after retiring from being the DHHS Inspector General, and has assisted over 3,000 health care organizations and entities in developing, implementing and assessing compliance programs.