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Primary Source Healthcare License Verification and Monitoring
Primary Source Healthcare License Verification and Monitoring

A healthcare license is a privilege and not a right. By that we mean one must earn a professional healthcare license. The individual must graduate from an accredited school/program and then pass a competency exam. Such exams are administered by and regulated by a State Licensing Board or a certifying board, recognized by the state. Upon successful completion, a license is granted to such individual. Thereafter, there are obligations and requirements in order to stay in good standing with the issuing Licensing Board.   The State Licensing Board is considered a primary source ("Primary Source") and will be the single place to verify and monitor for renewal, standing and in some cases, disciplinary actions taken against the individual and/or his/her license. In order to conduct effective compliance monitoring of licenses, a monthly monitoring of the license is critical.  Why Monthly?

Joint Commission HR Standards – are you audit-ready?
Joint Commission HR Standards – are you audit-ready?

Ever wonder if today is the day the Joint Commission shows up to begin its audit of your Human Resource compliance practices? How will you confidently demonstrate compliance with Joint Commission HR standards 01.02.01 with regard to staff qualifications and 01.02.05 with regard to verification of qualifications? For most people, this causes waves of panic and uncertainty. Will they find that you are compliant with your own internal requirement policies?  Do your HR files contain all of the primary source documentation that your policy requires?  Do you have a record of monthly OIG exclusion checks? Are you missing any key licenses, certificates, proof of MMR...? The list goes on and on. Failure of compliance in any one of these areas can result in the forced compliance of a CIA. But no need to panic. Educating your organization on how to implement best practices will result in an “audit-ready” compliance plan as well as avoiding any potential CIAs.

Guidelines for Human Resource Compliance
Guidelines for Human Resource Compliance

Healthcare has changed in so many ways in the last 25 years.  I often think about how, if my grandfather(s) were alive today and practicing medicine, rather than in their lifetimes, how foreign the delivery of medicine would be to them. With the advances in technology, vaccines and even the cures that have been discovered for once deadly diseases, I am not sure if they could process all of the advancements. However, the one thing I know they would be astonished by would be how much healthcare delivery has been changed by increased regulation, fines and penalties, fraud and abuse, and even how medicine has evolved into a business. On the business side of medicine, I think they would particularly be struck by how in today's healthcare industry HR and Compliance are not so divided anymore. HR and Compliance work in conjunction with one another; the separation is not so black or white, tomato/tomahto, potato/potahto. Instead, they go hand in hand with one another. Specifically, compliance is a way of defining "proper" work behavior as well as outlining specific laws and policies. There are many thoughts and steps that have to go into it. In order for compliance to be successful, it has to start from the top and trickle its way down to all levels, educating and enlightening coworkers and employees on how to be compliant.  

You Can’t Afford Not to Monitor Healthcare Licenses and Sanctions
You Can’t Afford Not to Monitor Healthcare Licenses and Sanctions

“An ounce of prevention is worth a pound of cure.” At least that is what Benjamin Franklin said a century ago. He is right, and that was insightful - even before his face would appear on U.S. currency. Little did he know how many “Benjamins” it would cost a healthcare company in fines for non-compliance with licenses.

OIG Continues Focus on Skilled Nursing Facilities
OIG Continues Focus on Skilled Nursing Facilities

Like most compliance officers, I receive compliance updates in my inbox every day from various vendors, compliance organizations, and of course the Office of Inspector General and Department of Justice. I always make sure to read all of the recent government settlements but maybe because of my background and love for the post-acute sector, I continue to notice how frequently the OIG and DOJ focus on the post-acute sector, and often more specifically on skilled nursing facilities.

The Path of an OIG Exclusion
The Path of an OIG Exclusion

Maybe the Wizard of Oz had good advice: follow the yellow brick road. It may have curves and present different paths, and you may meet some interesting people along the way, but in the end, it can take you to the big castle. In this case, the castle is the Office of Inspector General (OIG) for the Department of Health and Human Services (HHS) - the ultimate enforcer for healthcare fraud. The OIG has enforcement powers with the wave of its wand. Those powers include the statutory authority to impose civil fines and penalties (CMP) and exclusions against individuals and/or entities that stray from the yellow brick road.

Are Physician Licenses Going Interstate?
Are Physician Licenses Going Interstate?

Nursing Boards have been proactive in making it easier for nurses to have a license in one state that is accepted in another state. The Nurse Licensure Compact allows for Nurses to have one multistate license, with the ability to practice both in their home state and other compact states. To date, there are 25 states that have enacted legislation accepting the Compact effect in their state.  

Part 3: SNF Requirements of Participation – Licensing
Part 3: SNF Requirements of Participation – Licensing

Did you read the new Skilled Nursing Facility Requirements of Participation (ROP) section 483.12 carefully? In a document of nearly 200 pages and three columns of small print, sometimes it is easy to miss an important change. I read the new ROP multiple times and until just a few weeks ago I missed an important new requirement in the Freedom from abuse, neglect and exploitation section. Hopefully, you aren’t like me and you saw this already but just in case I thought I would highlight the change for you and give you some great news about meeting this new requirement.

Onboarding an Employee – Steps to Ensure a Compliant Culture
Onboarding an Employee – Steps to Ensure a Compliant Culture

"The moment you meet a stranger, both of your brains are making thousands of computations at lightening speed to make major decision about one another," according to an article in Forbes. This only take seven seconds. It only takes seven seconds to make a first impression. 

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