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Compliance Wake Up Call: What Keeps You Up at Night?

Posted by Margaret Scavotto, JD, CHC on 6/23/14 4:35 PM

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Everyone who works in a nursing home has woken up in the middle night worried about work. This is especially true for employees whose jobs involve compliance. 

Skilled nursing is a highly regulated industry, which is seeing an unprecedented era of government enforcement, penalties and settlements.

It is tempting to ignore those late-night nags, set them aside, and get back to work. But your OIG compliance program will be more effective if you seek them out and address them.

For example

MPA frequently asks people what keeps them up at night when it comes to compliance. Here are some common responses:

  • I'm worried our employees don't understand that vendor perks and treats could be illegal kickbacks.
  • If I audit our therapy charts, I'm terrified I might discover false claims due to sloppy documentation.
  • Some of our employees think compliance doesn't apply to them. How do I know our compliance training is helping them?
  • Recently, several patients have tried to "Friend" me on Facebook. I don't know if that's OK under HIPAA--but I don't want to hurt any feelings.

Ask your employees what keeps them up at night

The Compliance Officer should have lots of midnight worries to report, but don't stop there. Talk to the Administrator, the board or other leadership, supervisors, and a sample of your other employees. Your most valuable tip could come from a CNA or dietary aide. MPA recommends asking this question as part of your compliance program's baseline assessment, and at each effectiveness review.

Improve your compliance program

Your OIG compliance effort is only as effective as you make it. Continual updating is essential to keeping your program ahead of the curve. Once you know what is keeping your employees up at night, consider their fears your new compliance risks. Incorporate them into your compliance program, with policies and procedures, training, and audits. Remember, the goal of your compliance program is to prevent, detect, correct and report compliance concerns yourself--before the government does this for you. Plus, you can help your employees sleep better at night.

compliance risk assessment annual review



Topics: Compliance Basics, Culture of Compliance

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