On Demand Webinar | Basic | Compliance
In 2018, the Centers for Medicare and Medicaid Services released the CY 2019 Revisions to Payment Policies under the Physician Fee Schedule and other Revisions to Medicare Part B, which included policies related to Medicare Quality Payment ...
Save
Live Webinar | Compliance
This webinar, which will focus on requirements of physician involvement in the Medicare Quality Program (QPP), is based on the Centers for Medicare and Medicaid Services CY 2020 Revisions to Payment Policies under the Physician Fee Schedule...
Save
Course | Intermediate | Compliance
Explore patient rights under HIPAA, learn how privacy and security differ, what can be disclosed and to whom, what makes an authorization valid, and more. Find out what's covered under the False Claims Act and dig into Medicare coding issue...
Save
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

Advertisements

Related Articles | Compliance

Fact Sheet | Compliance

OIG Civil Money Penalty Amendment Proposed Rule Summary

HFMA summarized in detail the OIG's proposed rule amending its civil money penalty regulations.

Blog | Coronavirus

CMS's second COVID-19 interim final rule further relaxes Medicare regulations

HFMA's Chad Mulvany provides details on key provisions of CMS's second COVID-19 interim final rule.

Blog | Compliance

And the small print taketh away: Providers need to stay updated on HHS changes to the CARES Act Provider Relief Fund terms and conditions

HFMA's Chad Mulvany reviews some of the U.S. Department of Health & Human Service's changes to the terms and conditions related to the CARES Act Provider Relief Fund.

Research & Reports | Physician Compensation

Physician Compensation Systems Survey

Survey analysis reveals important learnings from a February 2020 HFMA-conducted study, sponsored by Ludi, about physician compensation.