4 Takeaways from the HCCA 2017 Compliance Institute
Last week, the 21st Health Care Compliance Association (HCCA) Compliance Institute was held in National Harbor, Maryland. Adjacent to our nation’s capital, Washington, D.C., National Harbor was the perfect location to hear from regulators such as the Office of Inspector General (OIG) and its various departments. Besides learning about the latest regulatory developments, the HCCA Compliance Institute is also a great opportunity to learn about compliance best practices and gather inspiration to strengthen your organization’s compliance program.
As the healthcare landscape adapts under a new administration, the following represent my top takeaways from HCCA’s 2017 Compliance Institute.
The OIG’s Lesson on Making Compliance Human and Using Technology
This year, Inspector General Daniel R. Levinson from the OIG discussed how healthcare compliance officers should focus on telling the compliance story horizontally across their organization. “A lot of it has to do with building the human factor,” he addressed attendees during his opening keynote. Corporate culture is an important factor for any organization’s success, with most executives ranking it as one of the top contributors to a firm’s productivity, profitability, innovation, and creativity. Having the right culture can make a big impact when it comes to your organization’s compliance program.
Although the OIG spoke about the importance of making compliance more human, Inspector Levinson also addressed the significance of technology. Technology is powerful because it can help us observe, measure, and assess our progress which can in turn affect behavior and results. “A fitness tracker is an example of technology that can use data to change behavior and motivate,” he explained. Consider how your organization can use technology to maximize the same factors that are impacted by a strong company culture. Together, culture and technology can pave the way for a successful compliance program at your organization.
Becoming a Highly Effective Compliance Officer
Kristy Grant-Hart, Owner at Spark Compliance Consulting, offered attendees an important lesson on how to become more effective compliance leaders. “You can affect much more people when you care about what you are doing,” she explained. “When you are excited about what you do, you become magnetic.” As leaders, we sometimes have to play the role of the cheerleader in motivating our teams to accomplish our goals.
When it comes to motivating people, Grant-Hart shared four primary motivators that compliance officers can use to motivate different people. Consider the following motivators:
- Fear for Self: People don’t want bad things to happen to them. Most people are moved emotionally by stories about people like themselves.
- Fear for the Business: People are afraid of the business having a bad reputation. This is similar to the fear for self and can be highly effective for addressing risk mitigation.
- Noble Cause: People are motivated by a bigger purpose. Some companies can attract more noble cause people. This motivator means they are emotionally buying in.
- Competitive Edge: People want to win and succeed. If you can show them how compliance can help the business, you can convince them you can help them to win.
By using the four motivators appropriately, healthcare compliance officers can drive organizational compliance more effectively.
5 Risk Mitigation Lessons from the Space Shuttle Program
Although it may seem as though astronauts and compliance officers have little in common, Dr. Garrett Reisman, Director of Space Operations at SpaceX, demonstrated there are a few things we can learn from the Space Shuttle Program concerning risk mitigation. Patient safety is a key priority for healthcare organizations, but safety is also critical for space programs, with the odds of dying in a space shuttle being 1 in 68 for astronauts. Here are five things healthcare compliance officers can learn from the Space Shuttle Program for mitigating risk, taken from Reisman’s keynote presentation:
- Keep Schedule Pressure at Healthy Levels: All projects need healthy pressure from management to control cost and schedule, but when schedule pressure becomes too high, things can go awry. Excessive schedule pressure can create an environment where people cut corners, which could result in reduced adherence to compliance guidelines.
- Avoid Normalization of Deviance: This is defined as when someone does something wrong, but there is an absence of negative consequences. Reisman reminds us that getting away with something over and over again, doesn’t mean it is not a danger. In compliance, it can be something as simple as people not locking their computers, for example.
- Use Caution with “Group Think”: “Group think” can be dangerous because it can lead to decision-making based on gut feeling and emotion. “You can convince yourself that something is fine,” Reisman explains. Instead, he recommends making decisions based on facts and data, not opinions or beliefs.
- Maintain Free and Open Communication: Open communication can save lives and play a key role in mitigating risk. In the case of the Space Shuttle Program, information from engineers regarding the safety of the materials for the space shuttle was filtered by contractors and managers. Astronauts who lost their lives on the 2003 Columbia mission were told they had nothing to worry about.
- Encourage Dissent: While no one likes a “Negative Nancy,” encouraging dissent is critical for mitigating risk. “Doctors don’t like being told they are wrong sometimes,” Reisman explained, “but you have to do it as compliance officers.”
Healthcare Exclusion Best Practices
Although healthcare exclusions are nothing new for compliance officers, it’s always a good component to review on a regular basis as part of your overall compliance program. “One thing to keep in mind is that a simple background check will not necessarily determine whether a person could be excluded,” Lauren Marziani, Senior Counsel at the OIG, stated during a conference session on this topic.
If you are reviewing your organization’s exclusion screening processes, here are a few things to keep in mind based on Marziani’s session:
- Review the OIG’s Guidance on Exclusions: The OIG published a Special Advisory Bulletin in 2013 on the effects of exclusions, which should serve as a guide for your organization’s exclusion screening processes.
- Reinstatement is Not Automatic: Although an exclusion term may have expired, keep in mind that reinstatement into federal healthcare programs is not automatic. Excluded individuals will continue to appear on the OIG’s List of Excluded Individuals and Entities (LEIE) unless they follow the proper steps to apply for reinstatement.
- Follow Best Practices for Exclusion Screening: Make sure you screen at the time of hire and ask for the employee or contractor to certify they are not excluded. Additionally, the best practice is to screen on a monthly basis for ongoing screening.
I hope you found some compliance nuggets to apply at your organization from these takeaways. If your healthcare organization is evaluating your exclusion screening program, contact PreCheck today to learn how we can help streamline your processes.