Rabia Mughal

From HIPAA to Occupational Safety and Hazard Administration (OSHA) guidelines, medical practices often face challenges when it comes to compliance, but there are low-cost tips to avoid violations.

That’s according to Marcia L. Brauchler, president of health care consulting firm Physicians’ Ally. Brauchler was a speaker at this year’s Medical Group Management Association (MGMA) Annual Conference in San Francisco.

She shared the results of an informal survey done by her company which indicated that 80 percent of medical practices in the Denver area have a compliance officer. Almost 40 percent said they had no annual budget for compliance. Of the practices that had a budget, it ranged between $200 and $4,000 dollars; or an average of $1,215 per practice.

Brauchler said these statistics show that there is a need for low-cost solutions among medical practices.

The first resource she recommended is the 

Office of Inspector General (OIG) Individual and Small Group Voluntary Compliance Plan

 which has been available since 2000. Brauchler pointed out that about half of the survey participants were aware of this resource which is a good starting point.

“OIG, which is the police force for a lot of different federal laws, expects your compliance plan to have at least what has been outlined in this voluntary compliance plan guidance,” she said.

There are OIG Model Compliance Plans for different healthcare entities and Brauchler suggested that medical practices review the 

“Individual and Small Group Physicians Practices”

“Third Party Medical Billing Companies”

According to the OIG, any compliance program should have seven basic elements, explained Brauchler.

It should have written policies and procedures.

There should be a designated compliance officer or contact(s).

The practice should have a training and education program for staff; for example OSHA requires training upon hire and annually after that and HIPAA requires training upon hire and whenever there is a change in HIPAA law.

There should be effective lines of communication so the person who is responsible for the compliance plan should not get squashed by the CEO or someone who does not want to listen.

The plan should require internal monitoring or doing your own auditing which includes the three Cs; auditing your care, contracts, and coding.

Also, standards need to be enforced; for example if a staff member is in violation of regulations there should be a plan for escalating things from a verbal warning to potential termination.

Prompt responses are important since some laws require action within 60 days, so sitting on a violation could get you into trouble.

An informal eighth step, Brauchler noted, is implementation and making sure you catch things before you get caught by an outside entity

“The government wants you to know that ‘I didn’t know this federal law existed’ is no longer an excuse,” said Brauchler.

In fact, OIG recognizes “deliberate ignorance,” and in some cases a penalty is increased if someone at a medical practice is intentionally disregarding guidelines.

“It’s better to try and fail than to not even try to figure out what are rules are,” said Brauchler.

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Medical practice compliance can be challenging, but implementing a basic compliance program can help you avoid violations. 

Low-cost Strategies for Medical Practice Compliance 

Today’s patients are looking for more than just high quality clinical care and with increased competition from retail walk-in clinics, it is important to provide them with the enhanced service level of retail and other industries.

Karen Shaffer-Platt, vice president of revenue cycle/patient concierge services at the University of Pittsburgh Medical Center (UPMC) and Edward McQuade, a UPMC executive administrator recently explained how to enhance consumers’ experience at the Medical Group Management Association (MGMA) Annual Conference in San Francisco.

Shaffer-Platt explained that in the past, insurance used to pay for everything. But bigger out-of-pocket expenses and high-deductible plans mean patients are now spending more of their own money. A lot of small businesses, for example, are just putting the money back in employee paychecks with instructions to purchase healthcare benefits independently.

Patients play a bigger part in the selection of their healthcare benefits now, she said. “That’s the future.”

There was a time that people would never leave their doctor, but in today’s market they are likely to seek easier options like a retail clinic if they have an immediate need like a flu shot.

The truth is, patients are consumers now and they want what retail gives them: availability, consistency, affordability, and convenience.

“That’s what they shop for in other industries and what they want from us,” she said.

Shaffer-Platt explained how UPMC has enhanced patient experience, including the addition of a direct call center, self-service options for check-ins, a welcoming staff, and patient education.

She said that it is important to understand the diverse needs of different consumers and not take a one-size-fits-all approach. Millennials, for example, are a digital generation and want to manage their affairs on their mobile devices. This generation also appreciates services like online check-ins and payment options.

Busy professionals may not be able to call during regular hours because of their hectic schedules. Maybe they call after they put their kids to bed, said Shaffer-Platt, so medical practices need to be available. Likewise, older or more traditional patients may prefer a face-to-face interaction or one that allows them to have caregivers or proxies present.

Shaffer-Platt described the consumer contact center at UPMC that serves as a single point of contact for patients where they can schedule appointments, find a doctor, and address a number of questions using various forms of communication including calls, emails, and live online chat.

Patients often do not fully understand their insurance policies and are confused about terminology. Employers tell their employees that they didn’t raise premiums but they may instead simply change the packaging to include hidden costs. It is important for practices to counsel and inform patients through services like pre-service estimates, on-demand estimates, simple statements in patient friendly language, and provide easy ways to make payments, she noted, pointing out UPMC’s approach.

As a practice, don’t tell patients you don’t have the technology to process payments a certain way, she said. Simply put: Don’t walk away from payments.

Shaffer-Platt explained how UPMC streamlined patient visit days by introducing self-service technology like kiosks for check-ins and biometric technology that allows quick recognition of patients. A staff person is available for check-out and to help people who don’t want to use the technology, but most like it and are very comfortable with it.

Also, she stressed that staff should make eye contact with the patient, answer their questions, and thank them for choosing your organization.

“When you walk around a Marriott, everyone thanks you,” she said. “Think hotel mentality.”

Finally it is important to personalize patient experience through advanced technology. Patient portals can be used for customer feedback or to send real-time notifications and text messages.

Shaffer-Platt pointed out that when you call Pizza Hut, they remind you that you ordered cheese sticks with your order before or Talbots may send you a message saying your favorite sweater is on sale. Likewise, in healthcare, patient experience can be enhanced by recognizing their preferences and experiences like remembering if someone has trouble with transportation, or prefers appointments at a specific time.

“Every other industry does it,” said Shaffer-Platt. “We have a chance to do it too.”

In today’s consumer-based healthcare market, patients expect personalized, retail-like service along with high quality clinical care.

How to Offer Patients an Enhanced Consumer Experience

With increasing patient volume set as a key goal for most medical practices, one way to do that is to reduce some of the administrative burden on physicians. This can be done by hiring scribes, advanced practice providers (APPs), and medical students, according to Kyle Matthews, CMPE from Phoenix Heart PLLC.

Matthews, who manages a cardiology practice in Mesa, Ariz., spoke at a session at the annual Medical Group Management Association (MGMA) conference, held in San Francisco. He started the session by doing a live audience survey asking attendees if they are currently using, interested in using, have used in the past, or have no interest in using scribes. The majority of the attendees said that they are interested in using scribes.

Matthews explained that scribes can increase both the speed and efficiency of physicians. "If they don't, it's either a bad scribe or bad physician," he said.  But most importantly, he pointed out they can increase patient volume. For a medical practice, patient volume is one of the most important things, he said. "We had a four month backlog for seeing a cardiologist," said Matthews.  "We added a scribe [and] he added four slots [for patients] a day."

Also, scribes can improve patient experience since they allow physicians to have more face-to-face time with the patient. Matthews explained that computers in most exam rooms face away from patients and physicians typically have to type with their back to the patients. With scribes doing the typing, physicians can have a more personal interaction.

Scribes can be hired from a number of qualified companies, directly, or can be developed internally. Matthews gave the example of young personable college graduate he hired to work at the front desk, who later transitioned to becoming a successful scribe. He stressed that you need to make sure the person has the right temperament. A shared scribe within the practice can be a benefit by working with multiple providers and even be moved to other jobs as and when needed.

"They are a niche and not for everyone but for the physicians who wants to see more patients it's an idea," he explained. However, he noted, family practices deal with a lot of people and some do not like to get certain exams done or don't want their children examined with another person present in the room. This is also a problem that comes up with medical students.

APPs are another way to increase patient volume and offer other advantages. They can chart on the physician's desktop, reduce paperwork, take on same day appointments, and bring a sense of team approach to the practice. They can work with multiple providers and also provide additional services that physicians may not want to do since the role of APPs in most states is expanding.

One important realization with APPs is to ensure that patients understands their role, explained Matthews. If a patient comes in expecting to see a doctor, they may not want to see an APP in their place.

As for medical students, a live audience poll showed that the majority believe they slow down physicians. "If they are slowing down the provider they are likely not being used right," said Matthews.

Beyond the first week, medical students actually speed up your provider if they are used in a coordinated way, explained Matthews. They may need a short training period after which they can help increase the physician's speed when it comes to seeing patients.

Moreover, including medical students in the practice can give some physicians a sense of purpose.  For a lot of practitioners who feel overwhelmed by the regulatory burden and feel less motivated, it can be a way of giving back to the profession and they take pride in it. Also, they can increase community connections. For example, Matthews encourages physicians to become guest lecturers at the medical student's school.  

Matthews did warn that it is important for medical students to receive some training, for example in HIPAA and OSHA compliance. "These medical students are acting as agents of the practice," he said.  "If they mess up they will hurt the practice."

Looking for ways to increase patient volume at your practice? Scribes, APPs, and medical students are three potential roles to help you out.

Author | Rabia Mughal

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