Sometimes, even providers with compliance programs find themselves entering Corporate Integrity Agreements (and hefty settlements) with the Office of Inspector General (OIG). Non-compliance can find healthcare providers, even when they have compliance officers, policies, training, and auditing. How does this happen?
Complacency: The danger
With OIG compliance guidance, work plans, and settlements to track on a daily basis, compliance is a lot of work, often involving a very long to-do list. It can be easy to get bogged down in the goal of crossing things off the list, speeding throught tasks just to get them done, giving audits a cursory glance rather than the attention they deserve--all at the expense of the program's effectiveness.
The point of compliance is not just to have all of the elements and pieces of a program crossed off a list. The point of compliance is to FIND compliance problems and FIX them. If you find yourself going through the motions on compliance, skipping over audits or giving things a hasty review, take a break, and remember: complacency is the enemy of compliance, and it's a dangerous enemy.
The devil is in the details
The extent to which an organization finds (and fixes) compliance problems often comes down to the amount of attention paid to details. How often are audits done? How much time do you spend on an audit? Do you really evaluate each audit question and carefully review the documentation involved--or scan through quickly hoping to find a positive answer? How likely are your billing audits to detect false claims? Is your QAPI effort improving your quality measures, or does your data say the same?
The opposite of complacent is concerned, and self-questioning. Do you question your audit results? When you find a curious result, are you concerned? Do you follow up, or does the audit go into a pile for another day?
There will always be compliance problems to solve, a never-ending compliance to-do list, and essential compliance program elements to keep up (like a compliance committee, policies, training, board reports and audits). By carefully tending to your compliance audits with attention to detail and investigation, you can find and fix inevitable compliance problems..