Reprinted from the 2013 Compliance Today May Issue
Written by Timothy L. Davis
Although I have been in my position as Corporate Compliance Officer, HIPAA Privacy Officer, Risk Manager, and Director of Quality Management for a rural behavioral health provider for a little
over a year, I must admit being somewhat overwhelmed in the beginning, I was unsure if I could effectively do the work associated with each title. This was reinforced by others who, in
astonishment, asked “Can you really do all your jobs with so much to do?” I had faith in my abilities, because ideas associated with each compliance area were not new to me, but still I wondered: Am I setting myself and the agency up for failure? Can I really manage the workload of so many areas?
The reality is that most rural providers of any medical service are usually smaller than their urban counterparts and have fewer resources for development and operation of programs not geared toward clinical practice. Even if some resources are devoted, they are often not sufficient to implement all the aspects of a comprehensive compliance program. So the outcome is frequently, “Let’s hire one person and give them all the titles. That should solve all our problems. Although this sounds good, most likely it will lead to a non-functional compliance program and wasted resources. So, how do we make sure our efforts are successful?
One of the first things any agency should do is complete an analysis of need based on their size, practice, and past experience. These key elements will guide the magnitude of the program and what positions may be needed. For example, if you are a moderately sized provider and have a high volume of paybacks/overpayments resulting from insufficient documentation or billing errors, you want to focus on your Quality Management/Auditing and Corporate Compliance positions, and possibly pair other elements, such as HIPAA and Risk Management, with these positions because they may not be as pressing. This is not a onesize-fits-all approach and is as varied as each unique agency.
Once you have determined the positions needed, consider the workload associated with each position and the current stage of development of your compliance program. A common mistake for rural agencies is to understaff in the early (development) or middle (implementation) development stages. The CEO or the director for the agency may look like a hero to the board of directors for
saving dollars, but this approach in the longrun could lead to undesirable results, such as unfavorable financial outcomes, burnout of the compliance professional, lack of buy-in and participation by agency staff, or even negative public opinions about the agency itself.
Another mistake to avoid is the “super” compliance professional who says they can do it all. Although they are most likely capable and talented, the volume of work, even for a small agency, is daunting. Overburdening one person often leads to early negativity toward program implementation and staff unwillingness to buy-in to the program for the long-haul The key is to be realistic about what is to be accomplished, who will be completing the work, and the timeframe for completion.
Once developed and implemented, the day-to-day tasks of the compliance professional settle into a manageable process and staff can be reassigned to other duties within the department or agency. Oversight, monitoring, and updating use far fewer resources if the initial and middle development stages are completed with a thoughtful approach. The wise words: Plan for success early on, make sure you devote appropriate resources based on your agencies needs, and have enough staff to ensure the program is successful. Then, one person wearing many “hats” becomes as easy as just putting them on!
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