This year has not resulted in a slowdown in the need for a competent Hospital Compliance Officer. In fact, if anything, it has increased the demand for such a person or persons for that position as the scope of regulatory standards and other legal requirements have increased!
If your healthcare organization is looking to fill this position, then let’s look at what it takes to do so successfully, and what the responsibilities, qualifications, and challenges are of this all-important leadership role.
In this Article …
- Challenges for Healthcare Compliance Officers
- What is the Role of a Healthcare Compliance Officer?
- What are the Qualifications of a Healthcare Compliance Officer?
- Experience of the Compliance Officer
- A Culture of Compliance
- How a Culture of Compliance Impacts Investigations
- Carrying Out an Investigation
- Effectiveness of the Compliance Program
- Outsourcing Your Compliance Department
Challenges for Healthcare Compliance Officers
There are several newer issues for a Compliance Officer to deal with these days. Just to name a few:
- Compliance with the Cures Act and its amendments,
- Cyber security practices,
- Telemedicine services rules and regulations, and
- Value-based physician compensation arrangements.
And there are still some of the old favorites such as:
- Claims submission,
- Appropriate medical record documentation,
- Conflicts of interest, and
- OIG screening of employees and providers.
With new and old challenges has the role or the qualifications changed?
What is the Role of a Healthcare Compliance Officer?
The Compliance Officer is responsible to make sure that the healthcare organization complies with all pertinent external laws and regulations, in addition to its own internal policies, procedures, and bylaws.
So the position’s role is largely still the same. But if the role is still the same, it is certainly true that the scope of laws and regulations has increased.
And this increase in the scope relates to the qualifications for the position.
What are the Qualifications of a Healthcare Compliance Officer?
There are currently no academic degrees specifically for hospitals or any other types of healthcare Compliance Officers. However, a bachelor’s degree in a related healthcare field is the minimum. Related fields include healthcare management or clinical fields such as nursing or laboratory science. Advanced degrees in such areas would be highly desirable. In many large healthcare organizations, the Compliance Officer may be an attorney.
Several colleges and universities offer certificate programs that contain several courses on compliance and ethics. The Compliance Certification Board accredits these programs.
Being a certified professional Compliance Officer, such as through the Health Care Compliance Association (HCCA) or the American Academy of Professional Coders (AAPC) is another important qualification that can provide a solid foundation.
Professional certification as a healthcare Compliance Officer from these organizations requires learning and demonstrating competency in core areas such as regulatory compliance, ethics, fraud, and abuse detection, data security and privacy, audit processes, and healthcare policy and procedure development and implementation. The certification also requires an up-to-date understanding of the healthcare compliance landscape, including recent developments and industry trends.
Through certification programs like those mentioned, healthcare Compliance Officers can ensure they have the right knowledge and certain skills to handle the challenges of healthcare compliance in today’s environment. By doing so, they can help protect their healthcare organizations from potential liability and ensure sound compliance practices.
Experience of the Compliance Officer
The other major qualification for a healthcare organization’s Compliance Officer is experience. The HCCA requires at least one year of working experience to even apply for certification as a Certified in Healthcare Compliance (CHC) professional.
Beyond the experience required to achieve a certification, previous experience in a hospital or other healthcare organization is invaluable when it comes to actually doing the job as a Compliance Officer. Hospitals, whether large or small, are complex organizations. There are staff members with advanced credentials such as physicians, clinical laboratory scientists, and advanced practice nurses. There are also staff members who register patients, prepare meals and provide housekeeping services. Understanding the roles and interrelationships between all these various employees is one of the keys to becoming an effective hospital Compliance Officer.
Experience in the healthcare field also gives a Compliance Officer insight into how to develop compliance policies and procedures that make sense within the hospital setting.
A Culture of Compliance
The Compliance Officer may be knowledgeable, talented, and industrious. But the effectiveness of the compliance program is really the sum total of the efforts of all employees and staff members. One of the most important duties of the Compliance Officer is to foster a culture of compliance. Just like many other aspects of organizational performance such as quality and safety, a Compliance Officer cannot ensure adherence to federal and state laws and regulations as an individual. The phrase we use to describe the compliance culture is “Do the right thing, always!”
It is also essential that healthcare Compliance Officers consistently strive at improving compliance practices, policies, and procedures in order to create an environment in which healthcare compliance is a top priority. Developing trust within the staff and encouraging open dialogue about best practices are just some of the methods Compliance Officers can use to foster this culture of compliance. In doing so, Compliance Officers create a safe and secure environment that allows healthcare professionals to focus on providing quality patient care.
How a Culture of Compliance Impacts Investigations
There are several good guides describing how to conduct investigations – just ask Google! And these guides are very useful when there is a suspicion of misconduct. But many compliance investigations are opened to deal with mistakes that people have made in one risk area or another. This is another circumstance where the culture of compliance is important.
Staff is much more likely to ask questions about the processes they are using if they know that asking these questions is part of doing the right thing.
Similarly, the staff is more likely to be open with the Compliance Officer if they know that mistakes are an opportunity for learning and improvement. In dealing with investigations, a Compliance Officer needs to remember that simply uncovering and punishing mistakes is not going to lead to more effective and efficient healthcare delivery. The goal is to optimize patient care, not to find fault.
Carrying Out an Investigation
Healthcare Compliance Officers should take into account the purpose of the investigation and ensure that those objectives are met. It is important to use a structured approach to ensure that the investigation is conducted effectively and efficiently. This will involve collecting evidence in a manner that will ensure its integrity, interviewing persons of interest, and ensuring that the investigation is conducted in a fair and impartial manner.
The Compliance Officer should also be aware of the legal implications of their actions, as it is among their responsibilities to ensure that the investigation does not lead to any further legal issues.
The Compliance Officer will also need to ensure that proper documentation is kept and that any information generated by the investigation is accurate and complete. Finally, it is important to remember that proper communication with all parties involved is essential to ensure that the investigation is successful. The Compliance Officer should be mindful of these tips when conducting investigations, as they are crucial to safeguarding the health and safety of patients.
Effectiveness of the Compliance Program
Evaluating the effectiveness of the compliance program is another important part of the Compliance Officer’s duties. Having or developing a plan for improving compliance practices is an ongoing process when it comes to maintaining compliance. Everything from policies and procedures, Board reporting, compliance education, and communication should be evaluated periodically. This will help ensure the activities and linkages necessary for a successful program remain in place.
Additionally, monitoring changes in the healthcare industry and legislation can help ensure compliance policies are up-to-date.
Moreover, hospital Compliance Officers should always be looking out for potential risks and vulnerabilities that could cause the hospital to run afoul of healthcare regulations. Being able to identify areas and issues of concern early can help protect the hospital from costly fines or penalties down the line by keeping in line with federal and state regulations.
Outsourcing Your Compliance Department
On the one hand, you cannot outsource a cultural concept. But you can outsource the management of a compliance department to knowledgeable and talented consultants who have compliance expertise! An outsourced chief Compliance Officer and an outsourced corporate compliance program are effective tools for smaller and rural hospitals lacking expert resources.
A few potential benefits of outsourcing a hospital compliance program include …
Cost savings – By outsourcing a compliance program, hospitals can save on the cost of hiring and training staff to administer the program.
Improved compliance monitoring – Outsourcing a compliance program allows for an independent, unbiased view of the healthcare provider’s daily operations which can help detect issues early on before they become major problems.
Increased efficiency – A hospital compliance program is designed to ensure that hospital staff is following proper processes, procedures, and policies. This can help improve operational efficiency and reduce errors.
Overall, outsourcing a hospital’s compliance program can be a beneficial solution for hospitals that lack the necessary resources to manage the program internally. It allows them to access expert resources, stay compliant, and reduce risk while focusing on core activities.
If you’re considering outsourcing a compliance program, choosing the right partner is important. Look for an experienced provider that understands the needs of healthcare providers and can provide guidance, support, and resources needed to implement and maintain a successful compliance program.
Hospital Compliance Officers play a critical role in the healthcare industry. They are responsible for ensuring government regulations and policies are followed, protecting patient health information, and minimizing potential risks. While they must have certain qualifications and experience to effectively fulfill this role, it is possible to outsource the entire responsibility to an outside expert. It ultimately comes down to the individual needs and budget of the healthcare facility when deciding which option will best serve its objectives.
No matter which route is taken, it is essential that hospitals and other healthcare entities have a robust compliance program to ensure a safe and healthy environment for patient privacy and safety. Compliance Officers are the backbone of this program, and by understanding their role, qualifications, experience, and challenges, healthcare executives can make a more informed decision about providing the best care for their organization.