It’s great to be back. I am so glad that Cahaba Media Group has purchased HomeCare, and I am confident the magazine will continue to serve as an invaluable HME resource for years to come.
My Compliance University column has been around since 2002. I will be returning the column to its roots, with a focus on regulatory compliance and compliance programs. Effective compliance programs will be mandatory for health care providers beginning in 2014, and there are many benefits a good compliance program offers. I had virtually stopped writing about compliance programs around 2005 because not enough providers seemed to care. Now, there are a growing number of reasons to care.
You Can Lead a Horse to Water …
Providers won’t read about compliance, learn about compliance or use tools to assist compliant behavior until they are ready. Compliance programs can provide immediate benefits as soon as they are implemented. This was true even five years ago. Perhaps many providers were not ready for such a step back then.
Times change.
Change Is the Only Constant
A compliance program is not a recitation of laws and regulations or outside rules. It is a process, an attitude and a commitment to operating your company appropriately. The dynamics that determine “appropriate behavior” in years past have been modified in light of new laws and changes in government attitudes or policies. Compliance has become increasingly important in areas such as managed care, joint ventures and financing. As new ideas and new attitudes evolve, compliance programs will reflect not only changes in law, but changes in perspective and internal dynamics. These operational shifts often affect the success of a compliance program far more than does learning some new, technical reimbursement or contracting requirement.
Experience Counts
A compliance program can reflect the successes and failures of compliance programs—or the lack thereof—from the past. Your program can reflect insights and experiences. Because a compliance program is ever-evolving, it is important to create a sensible set of policies and procedures that make sense. Your company’s own experiences are key to this success. But the ability to learn from others’ successes and failures is vitally important, as well. After all, why bother to repeat mistakes of others when there are so many new ones you can make yourself?
Roll Up Your Sleeves
Too many compliance programs are centered on “form books,” one-shot manuals purporting to offer model plans for punch-out use by providers. The materials are generalized and are not routinely updated, And they don’t reflect particular needs of a provider. While forms are sometimes included, materials tend to be guidelines for what policies to write or topics to cover. Much work is still required.
A compliance program is not a recitation of the law. It is an internal communication system, focusing on operational, clinical, administrative and financial policies that must be formalized and communicated clearly. The compliance program can then ensure personnel understand policies and know how to report concerns with compliance. Finally, the compliance program creates a mechanism for ongoing training and education, and for investigating and correcting problems.
Within this framework, a compliance program can offer a homecare company security and comfort and can demonstrate that a provider has his or her act together. It can withstand scrutiny and help maximize legitimate reimbursement opportunities. It can ensure that a provider is positioned to identify and take advantage of opportunities for further growth and increased profitability.
It’s good to be back.
HomeCare, January 2012
