Compliance Officers play a huge roll in healthcare organizations when it comes to safety and risk, work culture, quality of care, and much more. Let’s be honest, compliance has moved from a committee no one wants to talk about (or be on) to, in many companies, the committee with a seat at the executive table. Some would argue it took too long for this evolution to arrive, but no one would challenge the need for compliance in today’s complex healthcare environment. Regulators have focused on compliance since the beginning. The main purpose of the OIG-HHS is to set standards, guidelines, and enforce healthcare compliance.
This article, The Health Care Director’s Compliance Duties: A Continued Focus of Attention and Enforcement, from the OIG, provides great guidance on the evolution of compliance in healthcare.
Ever since the advent of enterprise risk management and the tying together of risk, operations, and compliance, this integrated and proactive approach to compliance has spread and is now adopted as the norm. The OIG has actually required a compliance plan to exist in acute care for decades. Section 6102 of ACA created a mandate that nursing facilities have effective compliance and ethics programs in operation by March 23, 2013. Another section of the ACA, Section 6401, requires other providers to have these programs as a condition of participation in Medicare/Medicaid programs, but nursing facilities are the first provider group to be singled out. More importantly, the OIG has provided for a reduction in civil fines and monetary penalties based on the Federal Sentencing Guidelines.
Compliance employees are cut from different fabrics of cloth. Some have risen in the ranks or simply just been there the longest and know where the skeletons are hidden, while others are certified by HCCA in privacy, compliance, and other specialty areas. Some compliance officers may have started as attorneys by trade. No matter how a compliance officer arrived, here are three ways their role makes a healthcare organization healthier.
The Role of the Healthcare Compliance Officer
Observation and Effective Listening
A great officer and his/her team will have eyes and ears open at all times and be on the lookout for areas to improve, policies to create, and know when an issue needs to be raised to management/board due to potential legal liability. This does not mean the role is to be a police officer with glasses that are only focused on finding non-compliance. Instead, an effective healthcare compliance officer will look for areas to increase efficiency and reduce risk. Thus, a healthcare company that truly adopts enterprise risk management will include compliance at the table and embed them with operations.
Educators and Champions for Doing What is Right
An effective officer will constantly review and revise programs to better educate everyone in the healthcare organization on current risk and compliance topics. The goal and challenge of creating a great culture of compliance, is ensuring that how and what you are communicating make sense, are correct, and can be easily related to your staff.
Model Behavior Within the Organization
A healthy organization starts at the top. If management and the board live and breathe by the core principles of compliance and its business values, then it will permeate throughout the entire organization. A great officer will model such behavior in every communication, interaction, and/or activity.
Employees want to follow the lead and do what is right when it comes to delivering high-quality care and favorable outcomes in building healthy relationships. Be the change you want the organization to follow and remember that every move is being watched by your staff.
Compliance officers have a critical seat at the table when it comes to strategic decisions made for the health of any organization. Reducing risk and creating a vibrant culture where everyone feels welcome, safe, valuable, and heard is essential for continued healthcare success. Don’t forget that many employees are looking for you to set the tone and practice what you preach each day, so go get em’.
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Written by Michael Rosen, ESQ
Michael brings over 20 years of experience founding and leading risk mitigation businesses, receiving numerous accolades such as Inc Magazine’s Inc 500 Award and Nashville Chamber of Commerce Small Business of the Year.