by Kortney Nordrum, CHC
Alison Green, Director, Compliance Program & Reporting, UnitedHealthcare Medicare & Retirement
Steve Bunde, Vice President, Internal Audit and Integrity and Compliance, HealthPartners
John Tanner, Medicare Compliance Officer, AVP, Molina Healthcare, Inc.
Do your leaders say, “That’s great information, but how is the compliance department doing compared to the rest of the industry?”
There are several ways to help communicate to your leadership how you’re doing as a compliance department. One way to do that is to show them the trends. Answer the questions, “Are we getting better? Are we getting results?”
To help you do this, answer the following questions:
- Are we getting complaints to the Compliance department? Questions? Reports?
- Are you resolving the issues as they are reported?
- What is your culture?
- Do you have a management issue? A training issue?
Another way to benchmark for leadership is through audit readiness. The speakers suggest putting together a dashboard that shows where you stand. Use bright colors to get their attention. For example, use bright red for potential ICARs (Immediate Corrective Action Required). After all, the purpose is to get your senior leaders’ attention and get the resources you need to remediate any issues before they become even more problematic.
You can also perform a mock audit. If you do, graph those results out for your leaders. When you present your mock audit findings, make it clear where your program currently stands, compared to what CMS expects.
When preparing your leadership for audits (and to some extent for mock audits), it’s important to set realistic expectations, for your organization and your senior leaders. CMS had told the industry where the problems are, and what to do to remediate those problems. It’s your job to do that in your program. However, you need to let your leaders know that every CMS audit since 2010 has resulted findings. It’s your job to set the expectation with your leaders that there will be findings and corrective actions will be necessary. Finally, you can report on enforcement actions throughout your industry. This will help to let leadership know what the industry expectations are and give context to the audit results.
The speakers also suggested regularly reporting your compliance program metrics to your business leaders. This would include:
- How many of each type of reports do you have?
- How many incidents lead to investigation?
- Are the calls you’re receiving reference or research questions, where employees are asking questions of the compliance department?
- How many of the reports are referred out to different departments, HR for example?
- How many of your incidents are still open more than 30 days out? If incidents are more than 30 days old, can you identify why?
- How complex are your incidents?
- Do you have adequate staffing to handle what’s coming into the compliance department?
- Is Compliance properly delegating work to others?
With these metrics, and the audit/mock audit results, you should be able to provide an accurate, helpful snapshot of your compliance program to your executive leaders.