As I write this column, I have just completed a full day of
education at a conference for health care compliance officers. The
attendees range from attorneys and high-level executives from major
Fortune 500 companies to nurse case managers and consultants
representing both the acute and post-acute sides of the
industry.
It was no surprise to learn that no matter what the set-ting, we
all have the same issues. Basically, consistent inconsistency.
All of the meeting attendees are actively dealing with changes
they must manage in Medicare and Medicaid. Everyone also faces the
unique requirements imposed by various other third-party payers.
They find themselves needing to stay abreast of everything that is
happening in the health care industry and trying to look ahead to
see what next crisis may be on the horizon.
Those of us involved in the home medical equipment sector are
not alone. We face the same challenges as do our colleagues in
other health care environments: holding our organizations
accountable for compliance with regulatory, payer and accreditation
guidelines while managing all of the new requirements imposed on an
ongoing basis.
One common activity we share is the need to audit and review our
records, documentation and processes — constantly — to
ensure that we are consistent with our requirements. And in
performing this review, we find that routinely, we are not.
Accreditation surveyors and consultants alike find that HME
providers can be very poor in maintaining consistent processes. A
policy or procedure might be written describing how the provider
does a certain thing one way, but in practice, the surveyor finds
that the company does another.
Providers are on their toes during the accreditation preparation
period and survey window, but shortly thereafter, these same
companies can let things slip or may not be as judicious at dotting
their “i's” and crossing their “t's.”
There are many examples where it is easy for providers to slide,
and they can be found in various areas within the company.
One common area where things slip is in human resource
activities. The provider's policy may state that all employees will
have a background check completed prior to interacting with
customers. But when auditing the HR files, I often find that this
is not performed consistently.
Maybe that check does not get processed during the orientation
period or maybe that check does not come back prior to the date the
employee starts to work. Either way, inconsistency begins to occur
within the organization.
A second common inconsistency in HR is the employee annual
review. In many cases I find that supervisors do not stay on top of
the time frame in which an annual evaluation or review is due for
their staff. Providers getting accredited for the first time get
these reviews done in time for their survey, but then going
forward, sometimes state that they are “too busy” or
“can't get around to it in time.” Or, long after survey
I might hear, “Last year we didn't get to it.”
Another area that can be troublesome is keeping up with the
current materials provided to customers. In a little over a year,
we've gone from 21 Supplier Standards to 26. Are you handing out
the correct copy of these standards to your customers? Are your
packets up to date with all of the correct information needed?
Of course, one of the biggest areas to address is documentation.
Even HMEs that are completely electronic are constantly deficient
with complete documentation. And it is not just making sure that
drivers or retail clerks are obtaining all of the required
paperwork from customers.
Are they signing as a witness to a customer's signature when
required? Are they documenting the relationship to the customer
when a caregiver signs for them? Do you retain verification that
all of the required paperwork was provided to the customer?
Maintaining accreditation compliance may not be easy, but
ensuring that your processes remain consistent is one of the keys
to staying on track.
Read more Accreditation Now
columns.
Mary Ellen Conway, RN, BSN, is president of Capital
Healthcare Group, LLC, Bethesda, Md., which provides health
care management expertise in accreditation preparation and survey
follow-up, operations assistance, design of quality improvement
programs and outcome measures. She can be contacted by phone at
301/896-0193 or through www.capitalhealthcaregroup.com.
