The dawn of a new year represents a logical time to look at current business operations and commit to making improvements. One key area that physician practices should focus on is compliance.
There are a myriad of rules and regulations of which practices must be aware. For example, with the ICD-10 code set in place, there are new and expanded coding guidelines. Similarly, organizations have to have strong procedures for safeguarding proper medical waste disposal, worker safety, and patient information.
Compliance in these areas can fall short, especially in smaller practices that have limited resources, and consequences can be severe, ranging from financial penalties to blemishes on a physician practice’s reputation. Organizations cannot afford this negativity given the competitive and costly nature of healthcare today.
Although keeping up with the multitude of regulations may seem daunting, it does not have to be. Even though different government requirements touch on diverse topics, organizations can take a similar approach to meeting all the rules. Not only is this cost effective, it also ensures that nothing slips through the cracks.
The following are some key resolutions that practices can make to commit to and execute upon a strategic compliance plan:
Appreciate the scope. First and foremost, physician practices must familiarize themselves with the applicable regulatory requirements. Getting a firm grasp on what an agency mandates is vital to understanding the extent of necessary compliance efforts. For example, two critical Occupational Safety and Health Administration (OSHA) regulations are the bloodborne pathogens standard and the hazards communications standard. These rules dictate that organizations must have detailed written policies that outline the risks present in the organization and describe how the practice plans to address those risks, including needlesticks, exposure to dangerous chemicals, and so on. On top of these two main standards, OSHA has other requirements that relate to personal protective equipment, hazardous chemicals, workplace violence, ergonomics, and so on. Like many other compliance areas, OSHA offers information about what’s required on its website, however, this can be overwhelming and a little unwieldy to navigate. Practices should look for resources, including consulting firms and online tools, to bring the regulations down to size.
Perform a gap analysis. After getting a handle on what’s required, the practice should compare its current performance against the applicable regulations to identify any holes. This may involve performing an in-depth review of existing policies and/or observing operations. In the case of HIPAA, an organization may also want to have conversations with staff about how they maintain patient health information security. Although a physician practice can do some of this on its own, an outside resource, such as a software program or other side-by-side comparison tool, can ensure the assessment process can be more thorough.
Provide training. Once a physician practice identifies compliance gaps, it should work to implement strategies to address them. Training is often necessary at this stage because it builds awareness with staff and can alter behavior so that the organization becomes more consistently compliant. For example, targeted staff training can help with coding compliance in that it demonstrates which codes a practice should use when and why. Training can take many forms, but should include real-world examples and opportunities to practice. To make sure staff retain information long term, facilities can employ knowledge retention strategies, such as periodically quizzing staff on certain compliance situations or having them engage in sample exercises.
Updating policies. Another applicable resolution for closing compliance gaps is to verify that the practice has all the appropriate policies in place and these documents contain the right level of detail. OSHA, in particular, is keen on whether an organization has comprehensive policies and whether the facility regularly reviews them. Even if a physician practice experiences a compliance breach, the regulatory agency may be more sympathetic if the practice can demonstrate that it has the correct policies and is aiming to consistently follow them.
Gain staff feedback. Staff can be a valuable resource in compliance efforts, and organizations should empower individuals to speak up about any perceived hazards or ways to improve compliance efforts. For example, if a staff member feels that waste disposal procedures are sub-par, he should feel comfortable bringing his concerns to practice leadership, and there should be an established method for securely and safely expressing opinions. Periodically surveying staff to get their thoughts and impressions is also a good idea. One thing to keep in mind is that employee concerns should be — at the very least —acknowledged, if not directly addressed. If a staff person shares feedback, but feels that nothing ever comes of it, he or she may be less likely to report concerns in the future.
Now, more than ever, is a good time to commit to renewed compliance efforts. By taking a strategic approach, organizations can meet the bevy of requirements while keeping costs in check—something that will ensure a better and safer environment as well as long-term practice viability.
Richard Best is the technical director/corporate director of OSHA compliance at Stericycle.