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Rehab-focused compliance risk assessments: Identifying and mitigating your risks

Holly Hester (holly.hester@nethealth.com) is Senior Director, Strategic Client Partnerships, at Net Health in Grand Rapids, MI, and Yolunda Dockett (ydockett@aadermatology.com) is Chief Compliance Officer at Anne Arundel Dermatology in Linthicum Heights, MD.

The compliance risk assessment has been described as the “eighth element” of an effective corporate compliance program, emphasizing its importance above and beyond the established requirements for auditing, monitoring, and overall program assessment. An annual compliance risk assessment is essential to determine the scope of an organization’s compliance plan, to identify areas of increased risk, and to direct the overall compliance efforts of the organization.

In 2015, Deloitte defined compliance risk as “the threat posed to an organization’s financial, organizational, or reputational standing resulting from violations of laws, regulations, codes of conduct, or organizational standards of practice.”[1] Compliance risk management is the process that mitigates or reduces this risk to a level that is acceptable to company leadership or management. Risk can never be erased. It must be decreased to a level that is tolerable, and this tolerance level differs between organizations and even between specific elements of risk. For example, one organization may take a zero-tolerance approach to billing policy violations, while another company may encourage the reeducation of violators.

The compliance risk assessment helps the organization understand the full range of its risk exposure, including the likelihood that a risk event may occur, the reasons it may occur, and the potential severity of its impact. An effectively designed compliance risk assessment also helps organizations prioritize risks, map these risks to the applicable risk owners, and effectively allocate resources to risk mitigation.

Healthcare organizations should ensure each department is included in the risk assessment process. This includes rehabilitation services when it is a part of the organization’s business line. Incorporating the rehabilitation division into the risk assessment further demonstrates the presence of a comprehensive risk assessment process. Furthermore, much of an organization’s risk exposure exists within the rehabilitation services division. There is no one way to conduct a risk assessment unless a regulatory body mandates the approach, and for therapy practices and post-acute care, there is no standard or regulation.

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