Corporate Compliance. If you work in healthcare, you have most likely heard the words. Set in a statute as a part of the Patient Protection and Affordable Care Act (ACA) as a condition of Medicare and Medicaid provider enrollment, Sections 6102 and 6401 of the ACA mandate that skilled nursing facilities (SNF), as well as other healthcare providers, adopt Corporate Compliance standards by March 23, 2013.
As more advances in technology force those in the Long Term Post-Acute Care (LTPAC) community to adopt, and adapt quickly to use of technological resources, it is important to ensure that your system(s) are not just set up to meet the needs of the provider, but that the system(s) are maintained appropriately and timely.
In a recent blog, I outlined the components of what makes up Policy & Procedure (P&P) – the WHY, WHEN, WHO, WHERE & HOW that is the backbone of good process. P&P need not be overly complicated or detailed – in fact, if you don’t “Keep it Simple” you are creating a monster. They say that the devil is in the details, and in this case that is true. Overthinking it, and adding unnecessary layers to your process will make it all too hard to comply with. If that is the case, and you make it impossible to meet your internal process points, you may truly be “hoisted by your own petard” (arcane reference acknowledged, but in plain English – “you have no one to blame but yourself)”. Do not err on the side of making your process too hard to follow.
We attended the American College of Health Care Administrators (ACHCA) Convocation 2016 in Philadelphia this week. My colleague, Jennifer Leatherbarrow and I presented a session to the membership on Untangling the Web of VBP – and all of the many acronyms therein. The presentation itself is meant to break down each of the components and programs within the Value Based Purchasing initiatives from the Centers for Medicare and Medicaid Services (CMS).
In a world of multiple audit agencies looking at providers’ claims for the sole purpose of identifying inappropriate payment, not to mention additional scrutiny from Medicare Administrative Contractors (MACs) and other federal agencies under the direction of the Centers for Medicare and Medicaid Services (CMS) and the Office of the Inspector General (OIG), it cannot be said enough how important it is for Skilled Nursing providers to audit themselves first. The most effective way to accomplish this is through the Triple Check Process – prior to submitting claims for payment.
Policy & Procedure is the root of all PROCESS, and process is everything in the LTPAC organization. Without process, we have inconsistency and inefficiencies. Policy & Procedure is not a manual on a shelf that collects dust. It is a “living” document that is updated to meet the needs of regulatory requirements and the organization – it has to weather changes (as these come fast and furious these days). Policy is the backbone of WHY we do WHAT we do, WHO does it, WHEN it is done and WHERE we document it. Procedure is HOW we do it. Without these components, we do not have PROCESS, and process is everything.
Remember Y2K? At the time many providers were concerned that their systems would break down at the stroke of midnight on January 1st. People anxiously anticipated the drop of the ball on New Year’s Eve and there were widespread fears that the electrical grid would shut down altogether. Some providers had maintenance and IT staff on site at midnight to deal with whatever was to come. Thankfully, those fears did not live up to the hype. One thing I took away from that time is that our industry does not handle change management all that well – we wait for the pain. Not much has happened to change my mind since. Recent examples that come to mind are the transitions to MDS 3.0 and ICD-10. Some providers were up to date and ready to go on day one, but so many others were scrambling to get processes in place.
It seems as though changes in our industry are coming fast and furious now. The implementation of the Affordable Care Act (ACA) has resulted in an increased scrutiny of our processes. With a larger focus on audits and overpayments, we are facing a future with a much different payment landscape – including bundled payment programs based on clinical outcomes.