“ABC Health, a mid-sized midwestern provider, was thriving. With a regional flagship hospital, six outpatient clinics, a home health division, and a solid reputation for quality care, the CEO had just signed a five-year partnership with a major insurance network.
There didn’t seem to be any cause for worry. The compliance officer insisted they ran exclusion screenings every quarter—plenty often, the executive claimed.
But in Q3, the exclusion screening software glitched. It missed a monthly sync. Then a second. By the third missed month, the compliance officer dismissed it as “a minor lag,” promising the HR department everything would be rerun soon.
Unfortunately, even a seemingly small glitch can have major consequences for healthcare compliance.”
Traditionally, many healthcare compliance programs have left the work of patient safety and quality to other departments. However, according to the Health and Human Services (HHS) Office of Inspector General (OIG), “Entities should incorporate patient safety/quality oversight into their compliance programs.”
OIG’s recent emphasis on patient safety and quality is not necessarily a call for compliance programs to take over these efforts. Rather, it’s a reminder that a compliance program should be designed to address the significant risks health care organizations face, which includes patient safety and quality of care.
How to Incorporate Quality and Safety into Compliance Practices
How can your compliance program answer the OIG’s call and include patient safety and quality in your oversight efforts? This blog explores four practices to integrate safety/quality concerns into compliance practices.
1. Build a Strong Compliance Committee
2. Provide Safe Reporting for Safety/Quality Concerns
3. Get Your Governing Board Involved with Quality of Care
4. Nurture Relationships with Quality and Safety Leaders
Four Ways to Drive Greater Connection Between Compliance and Safety/Quality
1. Build a Strong Compliance Committee
Most mature compliance programs have a compliance committee in some form or fashion. To build stronger safety and quality representation, include individuals responsible for quality assurance and patient safety as members of the committee.
A strong compliance committee should ensure that appropriate auditing and monitoring of patient safety and quality take place on a regular basis. The OIG goes as far as suggesting that “Compliance committees of entities directly furnishing patient care, particularly entities such as hospitals, long-term care facilities, and other entities providing residential care, should also assess staffing for nursing, therapy, and other clinical services to ensure that the entity has the appropriate quantity, quality, and composition of care providers.”
2. Provide Safe Reporting for Safety and Quality Concerns
Compliance programs establish lines of communication for reporting concerns, and anyone aware of patient safety or quality concerns must know how to report such incidents or issues. They must also have confidence they won’t face retaliation.
Awareness of incidents involving safety or quality is often the first step in developing a correction plan, so it’s essential that those who report know how their information is protected.
Steps have been taken at the federal level to encourage reporting and analysis of medical errors. The Patient Safety Act and Rule provide federal privilege and confidentiality protections for patient safety information called the Patient Safety Work Product (PSWP). PSWP includes data, reports, records, analyses and written or oral statements related to patient safety events.
3. Get Your Governing Board Involved with Quality of Care
Governing boards of healthcare entities have ultimate accountability for ensuring quality of care, and their involvement can also ultimately benefit compliance outcomes.
There are many resources available to educate your board on their responsibilities related to quality. These include:
Read and share these with board members to help them stay informed more easily.
4. Nurture Relationships with Quality and Safety Leaders
Compliance departments aren’t expected to take over the detailed, day-to-day management of quality and patient safety programs. However, it’s essential that compliance leaders develop productive working relationships with leaders and in-house experts within the organization’s quality and patient safety programs.
One way to develop productive working relationships is to better understand what quality and safety leaders do. A good resource for learning more about the standards, goals and language often used by quality and safety leaders is the Institute for Healthcare Improvement or IHI (https://www.ihi.org/).
This organization offers both introductory, intermediate and advance learning opportunities for those who want to become better-versed in quality and patient safety topics. The IHI Open School (https://www.ihi.org/education/ihi-open-school) is a great place to start. And for those looking for more formal recognition, the IHI offers certifications, such as the Certified Professional in Patient Safety (CPPS)™.
Compliance, Quality and Safety — Together for Common Good
The call for compliance programs to become more involved in an organization’s patient safety and quality efforts is getting louder from agencies such as the OIG. It’s also smart business practice.
In summary, this blog has covered four ways to begin the process:
Considerations for your compliance committee
Ensuring confidentiality of incident reports
Involving the governing board
Broaden understanding of what safety/quality leaders do
With these practices in your toolkit, you’ll be on the path to a stronger, more effective compliance program.
And to help with overall regulatory analysis and operations, learn more about how YouCompli compliance software can support your mission. The tools include capabilities to easily map and track responsibilities across functions.
CJ Wolf, MD, M.Ed. is a healthcare compliance professional with over 22 years of experience in healthcare economics, revenue cycle, coding, billing, and healthcare compliance. He has worked for Intermountain Healthcare, the University of Texas MD Anderson Cancer Center, the University of Texas System, an international medical device company and a healthcare compliance software start up. Currently, Dr. Wolf teaches and provides private healthcare compliance and coding consulting services as well as training.
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