Catherine Boerner (cboerner@boernerconsultingllc.com) is President of Boerner Consulting LLC in New Berlin, WI.
When beginning a compliance risk assessment, I want to know what risk areas leaders believe are well controlled. It says a lot when we can breathe a sigh of relief believing something is going well. After we confirm in the risk assessment that a risk area is, in fact, well controlled, we also get a good example. This example can be highlighted for others to understand and follow when working on controls in their areas.
It might be a good approach for your organization, when discussing compliance controls, to have the mindset of knowing up front what reassures the compliance department that a risk area is well controlled. Is it an up-to-date policy and procedure? Is it the education and awareness that have taken place? Is it the level of monitoring or a recent audit?
Communicating examples of controls up front should help leaders understand why compliance may have concerns about higher compliance risk in a particular area. It is nice to be proactive, and the compliance risk assessment provides that opportunity. Compliance can look at things from a different angle. It is nice to change perspective from the day-to-day concerns and step back.
The connection and collaboration the compliance department can facilitate between clinical areas and financial areas can not only reduce risk but help reduce denials and save the organization money. The organization is not only put on notice of overpayments but also underpayments, and root cause analysis and education are key to correct documentation, coding, and billing.
What compliance risk areas do your leaders believe are well controlled? For example, are any of these areas well controlled?
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Discharge disposition status coding accuracy
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Coder education and accuracy rates
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Physician contracting/Stark Law/Anti-Kickback Statute risks
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HIPAA privacy
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HIPAA security
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Exclusion screening
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Nonmonetary compensation tracking
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Emergency Medical Treatment and Labor Act
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Credit balances
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Professional courtesies/write-offs
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Credentialing
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Medicare Secondary Payer Questionnaire
This process can also provide ideas of where the compliance department can collaborate and partner with leadership on, perhaps, making some specialized compliance training a part of management meetings with staff by learning what is effective in the well-controlled compliance risk areas. What is working in other departments that fits into your culture of compliance? With staff turnover rates high, it is important to strategically form a compliance foundation of ongoing specific education throughout the organization to mitigate compliance risk and find ways to establish ongoing monitoring.