Tuesday, December 6, 2016

Overwhelmed, Underpaid, Stretched Too Thin: The Case of Multi-Office Compliance Administrators

Managing compliance with multiple offices at different locations can be challenging, but it is possible if done right.

Rita just finished talking with the Tampa office, as they have been struggling with some compliance issues. She begins drafting her report when the phone rings again. This time it is another issue with a misinterpretation of a compliance issue, but this one is at their office in Atlanta. Rita clarifies the issue and makes notes for her next report that will be done after she has completed the one from the Tampa office. "That's two offices in the last few minutes," Rita says aloud. "As long as I don't hear from the other seven offices I should be alright." At that moment, Rita's phone rings again.

Being responsible for the compliance regulations (HIPAA, OSHA, Human Resources, and Medicare) at one office is a demanding and time consuming job. Being responsible for all of the compliance regulations at multiple offices is, in all likelihood, overwhelming and ineffective. There are three specific areas that we are going to be reviewing where having a "multi-office Compliance Administrator" is a challenge.

So Many Duties, So Little Time
In many offices, the person who is assigned to be responsible for the compliance duties within that office, is also responsible for many other duties that have been assigned. These conflicts often lead to one or more of the person's assigned duties being neglected. Far too often, the duties that are often left neglected within an office turn out to be those duties that the person wants to do the least . . . compliance. Neglecting compliance, even if unintentional, will lead to an increase of liability for the organization as a whole. An adequate amount of time needs to be accounted for in order for the assigned person to be able to protect the organization by being effective in their compliance duties.

Compliance Representation

Even in a multi-office structure, it is essential to have compliance representation for each individual office. Examples of compliance representation include:

  • Office specific compliance policies and procedures
  • Compliance forms identified for each individual office
  • Subject matter expert (SME) at each location as the go-to person for compliance questions or patient concerns
Compliance and Employee Awareness
Being aware of what is happening within each individual office is a big challenge for multi-office Compliance Administrators. However, this is the most important factor in determining the success for failure of a compliance program.
  • Needs and Circumstances - Each office has its own uniqueness in terms of compliance needs, focus, and circumstances. For example, restricted access areas within the office might be a huge issue at one office. Where as, verbal protected health information (PHI) exposure could be a concern at a different location. Each office is unique and has its own challenges. One office could have a ramp safety issue and another office could be facing IT security issues. Each office is unique and should be treated as such.
  • Employees - Do you know what your employees are doing and saying when it comes to compliance? This is the biggest liability challenge for any organization. Having the ability to identify and quickly correct any possible compliance issue brought on by your employees lack of understanding or poor attitude, is a big difference maker for any compliance program. This goes a long way to creating the all too important culture of compliance within any healthcare office. Lacking employee awareness will leave your organization open to compliance issues and liability. It is also the quickest way for the multi-office Compliance Administrator to have an involuntary job change.
Can one person be the multi-office Compliance Administrator? The answer is, yes. If one person wants to be responsible for the compliance of the entire organization, they can do that, but they need to ensure that they have the following at each location:
  • Written and customized policies and procedures
  • Customized compliance material (forms, Business Associate Agreements, etc.)
  • Compliance Representative/SME
Having an effective compliance program and developing a culture of compliance within each healthcare office can be achieved. However, having one person trying to do all of the compliance program themselves for multiple healthcare offices is not the sign of a hard worker. It is a risky course to take that is laden with pitfalls and unnecessary liability.

Take a moment to review your current compliance situation. Ask yourself, "is my current compliance program protecting the organization or putting it at risk?" Could your current compliance program be better based on the needs of your organization and its individual offices? We can all do better improving our compliance efforts and meeting the needs of the organization. Rita has begun reviewing her compliance situation, maybe its time to review yours as well.

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