Catherine Boerner (cboerner@boernerconsultingllc.com) President of Boerner Consulting LLC in New Berlin, WI.
Because most organizations are struggling to support their staff and keep a positive culture during the pandemic, it has become apparent to the compliance department that risks to the organization have increased as well. It has also become apparent that the approach to mitigate these risks has changed, too.
When you don’t have adequate staffing levels throughout the hospital and there is too much work, or people wear too many hats, it will take longer for some things to get done in today’s environment. I don’t need to tell you that the stress level is high for everyone in different ways, and for those healthcare workers on the front lines with COVID-19 patients, the level is extremely high. This is a difficult time for many, both professionally and personally, and everyone has to do the best they can.
People also need to be more sensitive to the fact that “the best they can” may have changed or diminished due to the added stress the pandemic has caused. The compliance department has to identify and acknowledge to leadership the areas that are resulting in increased risk to the organization in the current environment while also trying to set a realistic timeline to mitigate the higher risks.
This actually may be a good time to conduct a compliance risk assessment so that a risk mitigation plan can be determined. By asking up front what compliance risks are happening due to the current environment, people can be heard in another way, and the compliance department can play a role in understanding the culture or just reality right now.
You often hear, “what is measured, gets done.” So at the compliance committee and other committees—for example, a denials management committee—be clear what is getting measured. What indicators will tell the organization that compliance risk has increased? This may be a time to ask human resources to provide a report on staff turnover or reduction and in what departments. If the organization has outsourced to vendors to manage critical operational areas, take it into consideration. Who is overseeing those vendor relationships? What is being measured by the vendor to help demonstrate compliance controls are in place?
The increased sensitivity and collaborative approach to all of this work by the compliance department is critical to build and/or strengthen relationships and be successful in mitigating compliance risk in a difficult time for so many.