Catherine Boerner (cboerner@boernerconsultingllc.com) President of Boerner Consulting, LLC, New Berlin, WI.
Now more than ever it is so important to make sure compliance is baked into your organization and there are continual improvement feedback loops in place around high-risk areas. With everyone so short-staffed and with employee turnover, things are falling through the cracks. For some areas, it might also be a result of shifting to remote work. If you have a strong compliance program and culture and strong leaders, now is the time to really encourage those strong leaders to build in compliance safeguards to help protect the organization over time. What is measured gets done, so pay attention to what is being measured. What results would become concerning to them? How do we know when we might be getting off track? What else should/could be measured?
For example, claim denial rates are measured. What do they mean? Are they getting to root causes? What is the continual feedback loop to the operational departments that can reduce denials? Do departments even know they are getting denials?
It may also be beneficial to look at the DNV accreditation model and standards approach. The emphasis is to understand processes from paper to reality.
The basic premise of ISO 9001 is to:
-
Document what you do (policies, procedures, protocols, work instructions),
-
Do what you document (How do we carry out these processes?),
-
Prove it (How have we demonstrated we follow what we say we will do?), and
-
Improve it (How do we change, fix, enhance, innovate?).
Whatever can be done to improve controls, support continuous training updates, and increase touch points will prevent losing progress and help your organization stay in compliance. Do not take it for granted. You lose some key people, and it doesn’t take long for processes to suffer. Former checks and balances might get lost. Compliance can play an important role in helping to ensure that compliance risk areas stay under control over the long term.
Keep in mind what the Department of Justice questions about prior weaknesses: “What controls failed? If policies or procedures should have prohibited the misconduct, were they effectively implemented, and have functions that had ownership of these policies and procedures been held accountable?”[1]