The ROPE (Rule Overload Prevention and Elimination) system reduces “rule overload” while improving profitability and operational efficiency. Complying with the system requires climbing a ROPE ladder with five rungs. The first rung consists of three strands woven together: (1) Articulate how you want your systems to run and note, dispassionately, how they in fact do run; (2) identify whether the way you want to do things needs to be modified to satisfy legal rules; (3) and, finally, write down the operating policy.
A Draft Policy
But does this first rung really work? To find out, try running a preliminary test by creating a draft equipment purchasing policy.
Start with questions. How do you purchase equipment? Do you have a standing order for minimum inventory? Do you deal with multiple vendors? Do you communicate your orders on the same day(s) each month? How long do deliveries take? Do you verify delivery? How? How do you handle special purchases or expedited purchases? When do you use your line of credit? Who is authorized?
Write down the answers to these and all related questions like this: Equipment Purchasing Policy: We currently purchase our equipment in the following manner … etc. Then list all the pertinent and accurate facts about your purchasing system in a logical sequence.
Look over that sequence, and have your department heads from purchasing, warehousing, financing, vendor relations and others do the same. They should comment on the draft policy's accuracy, catch any omissions and suggest areas for improvement.
Referring to the Rules
Now, look over your draft policy with reference to the rules. For example, HIPAA requires that you have business associate agreements with any vendors with whom you share patient billing information. Does this apply to you? Do you share patient information with some vendors and not others? How do you keep track? HIPAA may require you to modify your draft purchasing policy to address those business associate agreements, when they're needed and what to include.
Use your staff to identify how you actually operate different components within your company that affect equipment purchasing and what improvements you wish to make. If any rules apply to new policies, you need to determine whether the way you prefer to do things already complies with the rules. If the rules do require modification, make them, and note in writing why you have done so; you will need to explain this change when training your staff.
At this point you have created a customized, best-practices equipment purchasing policy that combines your present-day reality, the improvements you have chosen and refinements the rules require. The ROPE system has given you a blueprint for running your company's equipment purchasing system the way you want it to run, for all of the reasons you value.
You can apply the same analysis to other areas in your company, such as maintenance contracts, referrals from hospitals or physicians, work schedules or marketing to Medicare beneficiaries.
Neil Caesar is president of the Health Law Center (Neil B. Caesar Law Associates, PA), a national health law practice in Greenville, S.C. He also is a principal with Caesar Cohen Ltd., which offers compliance training, outsourcing and consulting, and the author of the Home Care Compliance Answer Book. He can be reached via e-mail at ncaesar@healthlawcenter.com or by telephone at 864/676-9075.
The ROPE Ladder
Rung 1: Articulate the way you want things to run, and note how they run now. Then, tweak your systems as necessary to comply with “The Rules.”
Rung 2: Teach your operating systems to your employees.
Rung 3: Implement a clear and simple method for dealing with problems — identify them, report them, investigate them and fix them.
Rung 4: Give your compliance staff resources to help them keep up-to-date with internal and external changes that may sometimes require you to refine your operating systems.
Rung 5: Monitor your operating systems to make sure they continue to run as you intended.
