Sitting Pretty with Healthcare Compliance Data

Sitting Pretty with Healthcare Compliance Data

Data in Healthcare

Data has been a buzzword around for the last couple of years now in just about every industry. Healthcare is no exception. We all know we need it, we know that it’s important and we should be tracking it. However, when it comes to healthcare the word “data” still feels a little ambiguous sometimes. Do you think it is the case because there is so much information to be aware and track when it comes to effective healthcare compliance?

Compared to other industries, there is a heightened importance placed on the right data in healthcare because it has to do with patient health– and there should be! Not every industry has these high stakes associated with their numbers. Yes, large amounts of dollars can be lost or gained when looking at the data, but ultimately in healthcare it comes down to saving lives. This means lots of disparate information is pulled from a wide variety of sources and departments within a healthcare organization.

“Not every industry has these high stakes associated with their numbers.”

In healthcare,  there are multiple forms of data for each patient and multiple clinicians that may provide data. Clinical data could include “EMR, Electronic health records, administrative data, claims data, disease registries, health survey and clinical trials data.”  

But clinical data is not the only measure of compliance. Billing data, prescription patterns, staffing needs and incident data all add up to provide a better compliance picture.  These datasets reside in different hands, in different formats and are typically not shared or transparent to all who come in contact with or who are responsible for compliant care.

There’s a lot of data to pull information from, which is good! But not sharing and forecasting from it is bad.  Effective compliance means getting the right data in a timely fashion. It’s just not always easy to contain it! Moreover, there needs to be key metrics that trigger immediate action or reaction in order to use data effectively.

Sitting Pretty

Thankfully when it comes to compliance with monitoring your employees and vendors,  compliance data is relatively easy to find.  However, the data is in many formats, in many state and federal lists, and does not contain minimum identifiers to match with your employees or vendors.  We will discuss a  few trusty sources to turn to and how to organize the information you need in order to take care of the people and uphold a high standard for our compliance organizations! It doesn’t have to be messy and unorganized. We can have a reliable plan.

Where To Go

Exclusions:  Federal and State

  1.  Two Federal Lists

OIG   (Office of Inspector General)

SAM  (Systems for Award Management)- which includes GSA-EPLS

Almost 40 state Exclusion Lists:

  1.     State Lists Records
Alabama Alaska Arizona Arkansas
Califoria Connecticut District of Columbia Florida
Hawaii Idaho Illinois Iowa
Kansas Kentucky Louisiana Maine
Massachusetts Michigan Minnesota Mississippi
Missouri Montana Nebraska Nevada
Nevada New Jersey New York  North Carolina
North Dakota  Ohio  Pennsylvania South Carolina
 Tennessee Texas  Washington West Virginia

Does not include:
Colorado, Delaware, Indiana, New Hampshire, New Mexico, Oklahoma, Oregon, Rhode Island, South Dakota, Utah, Vermont, Virginia and Wisconsin

Now here is the catch. One source isn’t enough. Remember how we mentioned earlier there are multiple forms of information for a single patient? Similarly, just going to one of these resources above only gives you part of the picture. You need both the state records and the OIG’s records.

There is a serious gap in reporting from state sources to the OIG. This means an excluded person in Texas could potentially beat the system by moving to Tennessee and continue to practice without getting caught. Texas may not have reported on time to the OIG, or at all! If Texas’ exclusion list isn’t checked by the new provider, because they are only searching the OIG, a healthcare organization is employing someone who could cost them thousands of dollars in fines and even worse put patients at risk.

Keeping up with the data has a lot higher stakes in healthcare, but if you check all of the available exclusion lists including: OIG, SAM and ALL of state lists. Then you must follow it and track it on a monthly basis. That way an excluded individual should have no way of slipping through the cracks! This is good news for healthcare leaders who are having to worry about a lot of different forms of healthcare data- compliance doesn’t have to keep them up at night!

Furthermore, we suggest the best way to keep your compliance data organized is to use a compliance dashboard.

License status and Disciplinary Actions:  State License Board data

In health care, certain positions which primarily involve direct patient care, require licensure or a certificate from a state board or approved trade association. For example, a registered nurse requires licensure in any state to practice in healthcare. Different states, have different requirements to qualify for a RN. In addition, 25 states participate in the nurse licensure compact which allow nurses to practice in other compact states without having to get additional licenses.

A critical component of compliance healthcare data is whether or not such licensed professionals have a current and valid license. Further, an employer would want to know if such license has been disciplined restricted or limited.

There are over 80 different licensed types of providers. Each one might be governed by a separate state licensing board within the state. This means there are well over 4,000 possible licensing boards. That would maintain the license and disciplinary data. Depending on which type of licensed providers your organization hires or contracts with will determine how many different boards within the state or states where you have facilities that need to be monitored.

All of these relevant data sources need to be monitored at least monthly for disciplinary actions and upon renewal to determine if the license was renewed.

It may take a while to find the best system for organizing all of the available healthcare data, but thankfully when it comes to compliance, we can add some structure to it and feel comfortable knowing our organizations aren’t letting the numbers slip through and cost us in the end. If you continue to check all of the available exclusion lists and keep up with your employees with a compliance dashboard – you’ll be sitting pretty!  

Written by Michael Rosen, ESQ
ProviderTrust Co-Founder,

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
Connect with Michael on Linkedin

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