Trend | Compliance

Signs and symptoms to watch for in evolving compliance areas

Trend | Compliance

Signs and symptoms to watch for in evolving compliance areas

Five evolving areas for compliance require attention from a hospital’s or health system’s compliance program: quality of care, patient abuse, quality reporting, emergency preparedness and case management.

A hospital’s compliance program should be alert to the following compliance concerns in each evolving area of compliance focus.

Quality of care

  • Consistently low event reporting
  • Joint Commission citations
  • High turnover in clinical areas and staff working outside their scope of practice
  • Clinical and quality outcomes areas working in silos
  • Physicians who perform far greater numbers of specific procedures than are performed by other physicians or institutions
  • Physicians who have not completed the conflict-of-interest attestation

Compliance leaders should routinely discuss these concerns with clinical and quality leaders to assess the level of risk and determine root causes and the status of any corrective actions. They also should collaborate with clinical and quality leaders to ensure areas identified as deficient by external surveyors are addressed, and clinical processes such as event reporting are routinely audited.

Patient abuse

  • Inadequate follow-up to patient grievances
  • Staff found outside their assigned unit
  • Staff coming in on their off days to check on patients
  • Inadequate surveillance of safety events
  • Lack of a robust background-check process

Compliance personnel should collaborate with clinical (and possibly human resource) personnel   to understand the nature of the issues and any remediation activity. An audit of key processes such as patient grievances can provide greater insight into whether these cases are handled appropriately. Patient-grievance processes should adhere to CMS requirements for the timeliness and nature of follow-up activities.

Quality reporting

  • Pressure to meet financial goals
  • Lack of oversight and validation around quality reporting
  • Unclear definitions of quality metrics
  • Lack of understanding of current quality reporting requirements
  • Frequent data integrity issues or data coming from multiple disparate systems

The compliance leader should ensure the quality reporting process is audited to validate whether the process supports accurate reporting and the ability to respond to changing requirements.

Emergency preparedness

  • Lack of emergency drills
  • Poor risk-assessment process
  • Lack of a holistic approach that involves all key stakeholders
  • Failure to consider billing procedures (for example, billing when the system is down or suppressing inappropriate billing)
  • Unassigned ownership of critical components

Compliance personnel should be active participants in emergency preparedness committees to anticipate risk, evaluate preparedness activities and assess 
remediation efforts.

Case management

  • Inactive utilization review committee
  • Excessive avoidable days or lack of avoidable day tracking
  • High readmission rate
  • Perception of low stature within the organization
  • Excessive clinical denials

The compliance area should collaborate with the case management area on routine auditing and monitoring to assess compliance with CMS conditions of participation.

See related article: Evolving compliance risks that should be on your radar


Related Articles | Compliance

Trend | Chargemaster

Holliday & Associates: Comprehensive Charge Management Software

A charge management company discusses how it helps clients successfully manage charge processes, comply with changing coding and regulatory requirements, eliminate charge-related compliance risks and ensure accurate and appropriate reimbursement.

Business Profile | Revenue Cycle Technology

Ontario Systems: Helping Healthcare Organizations Realize the Benefits of an Accountable Collections Team

Steve Scibetta, vice president and general manager at Ontario Systems, offers strategies for optimizing the revenue cycle, including employing supportive accounts receivable technology and building an accountable collections team.

Business Profile | Medical Necessity

Enjoin: Enabling Holistic Clinical Documentation Improvement

James Fee, MD, CEO of Enjoin, discusses the importance of holistic clinical documentation to realize success with existing fee-for-service payment models, as well as value-based care and population health initiatives.

Blog | Telemedicine

University of Rochester: Using telemedicine to reach more patients with Parkinson’s disease

An academic medical center’s efforts to bring telemedicine to patients with Parkinson’s disease has reduced costs and improved outcomes.