Constructive Feedback

Let’s continue to challenge conventional views of regulatory compliance programs. Our premise has been that any homecare company that does not yet have in place a working, effective compliance program has, in effect, decided that the benefits of such programs are not worth the costs, and therefore has decided to wait as long as possible to implement as little as possible into its daily operations. As my columns in HomeCare magazine have suggested, this decision is shortsighted. Indeed, an effective compliance program improves reimbursement, prevents trouble with government agencies, and produces both internal and external benefits for homecare companies.

There are dozens of ways in which a compliance program can produce ongoing and immediate benefits for a homecare company. In the past we have discussed ways an effective compliance program can help a homecare company stay out of trouble with the government, improve the accuracy of submitted claims, increase reimbursement amounts, help providers respond to and defend against CERT, RAC and ZPIC audits, and reduce the danger and impact of whistleblowers.

We continue our discussion of compliance program benefits, which can improve efficiency and employee morale within your company. These benefits can help a homecare company nurture a more loyal, effective and savvy workforce. Our December 2012 column in HomeCare magazine explored how an effective compliance program can improve internal communication generally. Let’s now explore more related benefits.

A compliance program creates efficient structures which the homecare company can use to disseminate information. An effective program creates and utilizes internal channels of communications so that problems and solutions can be reported and investigated efficiently.
The company communicates best practices and pertinent legal requirements through training, ongoing education and dialogue with affected personnel. Personnel communicates concerns, problems or violations of policies through suggestion boxes, hotlines, dialogue with supervisors or compliance personnel and similar reporting methods. Compliance personnel communicate a need for, and results from, internal compliance investigations, and further communicate recommended improvements to the program and to company operations.

In addition, a homecare company can use some of these communication procedures to distribute other types of information as well. For instance, if compliance issues are reported to senior management on a regular basis, this reporting process can be expanded to include reporting of other useful information, such as growth opportunities, strategies for gaining visibility with referral sources, potential beneficial collaboration among departments, etc. As another example, if compliance requires changes in departmental procedures, these must be communicated in some formal fashion. This same communication system can convey new departmental information or policies even if unrelated to compliance issues.

If you can accept that internal communication is the key to a homecare company’s compliance program’s effectiveness, then why not utilize its communication systems to benefit information flow?

Fortunately, the same internal communication mechanisms used in an effective compliance program can also become the cornerstone of a general program that encourages focused and constructive feedback to forge sensible solutions for operational problems.

In this regard, it helps to recognize that the underlying theme of an effective compliance program is, as follows: “We want to do things correctly. We need everyone’s help to identify when things are not being done correctly and why. We want procedures in place to make it easier to fix problems once identified.” This is a useful philosophy for a homecare company to embrace, and to communicate, in most aspects of its operation. Homecare companies should encourage personnel feedback on all topics, not merely compliance-related items, as long as the feedback facilitates identifying a problem, the reasons for the problem, or an approach for resolving the problem.

A system that encourages focused, constructive problem solving can also be used to explore new ideas or business opportunities. Why not utilize compliance efforts as a springboard for a wide range of focused employee feedback?