Consistent Inconsistency

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.