7 Key Takeaways and Best Practices from the 2014 HCCA Compliance Institute
While PreCheck is a longtime supporter and exhibitor of the Health Care Compliance Association (HCCA) Compliance Institute, this was my first time attending the conference as an attendee. As a healthcare exclusive background screening firm, it is imperative that we as an organization stay abreast of the latest healthcare regulations that affect our clients in this complex industry. I think we can all agree that healthcare is ever-changing. Nothing stays the same with new regulations, directives, advisories, and guidelines being rolled out year after year. Whether you are new to the healthcare compliance field or are a seasoned veteran, I hope you find the following list of takeaways and best practices from this year’s conference helpful as you tackle the challenges affecting your organization.
Familiarize Yourself With the OIG Work Plan
One of the most exciting aspects about this conference is the opportunity to hear directly from the OIG, including Inspector General Daniel Levinson himself. During the general session, Inspector Levinson addressed the issues the Department of Health Human Services will be focusing on in 2014. If you haven’t already, take advantage of the OIG Work Plan (link to OIG Work Plan article) issued at the beginning of the year, specifically the hospital compliance reviews. Quality and patient safety has become a very important priority in 2014 and beyond. Last year, the OIG examined adverse event issues as they have occurred in hospitals and nursing facilities, but will also focus on investigating adverse events occurring at inpatient rehab facilities moving forward. These are just a few of the items Inspector Levinson addressed during the session, but you can find more details about the OIG’s key initiatives in the 2014 Work Plan.
Review Your Exclusion Screening Program Against the Latest Best Practices
As you may be aware, last year the OIG issued a Special Advisory Bulletin on exclusion screening, the first of its kind in over ten years. In this guidance, the OIG establish a monthly screening frequency as the recommended best practice in order to minimize the level of risk for engaging excluded individuals and entities. Section 6501 of the Patient Protection and Affordable Care Act states that an individual that is excluded in one state is excluded in others. This is important because there are now 34 states that have a State Medicaid Exclusion List, separate from the OIG LEIE. So if your current exclusion screening program is not checking any of the publicly available State Medicaid Exclusion Lists, you are placing your healthcare organization at risk. Simply checking the OIG LEIE is no longer enough to mitigate risk for your organization—in some cases, it may take as much as two years before an excluded individual on a State Medicaid Exclusion List makes its way into the OIG LEIE. With Civil Monetary Penalties calculated at $10,000 per item billed in addition to treble damages, this is a considerable amount of risk. Thus, if you haven’t reviewed your exclusion screening program, it may be time to increase both the frequency of your current procedures as well as the scope of the lists and databases searched.
Prepare for ICD-10 Implementation (Now) in 2015
Interestingly enough, ICD-10 implementation was delayed until October 1, 2015 during the conference. Whether your organization has already started preparing for the former implementation deadline of October 1, 2014 or you are still in the early stages of preparation, here are a few best practices and recommendations Michelle Leavitt, Director of Learning Solutions at HealthcareSource, shared in her session titled “Be Ready for ICD-10: Best Practices for Educating Coders”:
- Assess your staff’s level of knowledge. Not everyone will need the same level of training, so perform some initial assessments on your staff to ensure that you can tailor a training program that meets their needs.
- Develop a customized learning plan for each of your coders. Make sure you provider your coders with a foundation on anatomy and physiology and use your initial assessment results to tailor the program to each staff member.
- Provide in-depth education and coding instruction. HIMA recommends that you provide ICD-10 training education within 6-9 months before ICD-10 implementation, so you may need to consider refresher training a year from now.
- Allow your staff opportunities to practice. Dual coding is one of the best ways to provide training for ICD-10 and is a great practical application, says Michelle Leavitt, Director of Learning Solutions at HealthcareSource.
- Early planning is key. Although the ICD-10 implementation deadline was extended until October 1, 2015, it is nonetheless highly recommended that you still start today. It is more cost-effective if you start early.
Instate a Social Media Policy to Protect Your Organization
As a marketer, social media is great tool to engage with our clients and our industry. In the complex world of healthcare, however, there certain threats that social media poses, even by way of careless actions on behalf of an employee. It was interesting to see that a handful of conference attendees shared they had either terminated or disciplined an employee because of a social media issue. As a healthcare organization, it’s important to remember that employees can post things on their personal Facebook page from home that could affect the work environment in a detrimental manner. If your employees are not mindful of what they post on their social media profiles, they could be disclosing personal health information (PHI). Even physicians have been guilty of sharing too much information. The Federation of State Medical Boards recently issued guidance on the appropriate use of social media in the medical practice, which is a great resource as you consider writing a policy for your organization.
Beware of ‘Cookie Cutter’ Compliance Plans
Another theme that I observed throughout the conference sessions is the importance of investing the time and resources to customize and tailor your compliance program to fit your healthcare organization’s unique needs. With the ease of information available at our fingertips in the era of Google, you can most likely find sample compliance policies through a web search. Inspector Levinson, however, reminded us that every compliance program should be different and stressed the need for things to be customized. While it may be easy to copy a compliance policy you come across online, adopting it as your own without careful consideration could place your organization under considerable risk.
Work on Your Relationship and Involvement with the Leadership Team
As a healthcare compliance professional, it’s becoming increasingly important to have a close relationship with your leadership team to ensure that your compliance initiatives are supported. As the subject matter expert in regulations and directives at your healthcare organization, you have the knowledge and background information to ensure that the business goals and objectives are compliant. Make sure that you establish yourself as a resource for your leadership team. Ideally, it would be great if the compliance officer examines each new project or initiative considered by the executive team. Take the time to truly develop relationships, not just when there is a crisis. Proactively offer your help and guidance before issues arise. It can be challenging to get to the point where you are invited to leadership and board meetings, but you’ll find the benefits of aligning compliance with strategy rewarding.
Incorporate Ethics into Your Organizational Culture and Compliance Program
Establishing an ethical culture is one of the elements of an effective compliance program, and it’s also another recurring theme throughout the conference. It’s important to establish clearly-defined behavior standards to ensure that your organization can implement consistent disciplinary measures. According to Deann Baker, Sutter Care at Home Compliance Officer, a just and fair culture looks at opportunities and supports the patients, families, staff by providing a process to evaluate why an error occurred. If you don’t have a just culture, your organization will suffer the consequences, people will stop reporting issues and you could potentially see an uptake in whistle blowers. As one of the attendees expressed, “If there is a fear factor involved between the employees at any level and HR, it really creates a monkey wrench into all communication.” Michael Josephson, President and Founder of the Josephson Institute, stresses that “the only good reason to have an ethics and compliance program is to ensure it will affect behavior. You need to affect attitude in order to affect behavior. You need to create the belief and incentive for doing the right thing.”
These are just a few of the takeaways from this year’s conference. What are your top compliance initiatives in 2014?