This year has not resulted in a slow-down in the need for a competent hospital compliance officer. In fact, if anything, it has increased the need for such a person or persons.
The scope of the regulatory and legal requirements has increased!
Challenges for a Hospital Compliance Officer
There are several newer issues for a hospital 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, what is the role of the hospital compliance officer? Has the role or the qualifications changed?
Role and Qualifications of the Hospital Compliance Officer
The role is still largely consistent with the role in the past. “The role of the compliance officer is to “ensure the firm is in compliance with its outside regulatory and legal requirements as well as internal policies and bylaws.” But if the role is still the same, it is certainly true that the scope of the regulatory and legal requirements has increased.
This increase in scope relates to the qualifications for the position.
There are currently no academic degrees specifically for hospital compliance officers. 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 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.
Experience of the Compliance Officer
The other major qualification for a hospital 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.
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 compliance with laws and regulations as an individual. The phrase we use to describe the compliance culture is “Do the right thing, always!”
There are several good guides for conducting 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.
Effectiveness of the Compliance Program
Evaluating the effectiveness of the compliance program is another important part of the hospital compliance officer’s duties. 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.
Outsourcing Your Compliance Program
On the one hand, you cannot outsource a cultural concept. But you can outsource the management of a compliance program to knowledgeable and talented consultants! An outsourced chief compliance officer and an outsourced corporate compliance program is an effective tool for smaller and rural hospitals lacking expert resources.
However, if you choose to find and retain a hospital compliance officer, look for a healthy combination of qualifications and experience. Your hospital may depend on it!