Plans help hospices prepare for scrutiny
A new industry has emerged in the wake of Operation Restore Trust and the current national focus on health care fraud teaching providers how to develop plans to prevent compliance breakdowns and mitigate potential problems arising from regulatory scrutiny. "These are voluntary efforts, and people put them in place to try to troubleshoot," says Chris Cody, RNC, MSN, director of professional and regulatory affairs for the Arlington, VA-based National Hospice Organization (NHO).
NHO staff met recently with representatives of the Office of Inspector General to discuss developing a voluntary model compliance plan for hospice. This is to be done by a compliance plan task force representing NHO and the Hospice Association of America. However, experts recommend that providers get started on their own compliance programs, without waiting for NHO’s to be completed sometime next year.
The growing national focus on compliance issues is a good reason for hospices to develop their own plans, says NHO general counsel Ann Morgan Vickery, JD. "But don’t do it unless you intend to comply with it. Having a policy in your manual and not following it is worse than not having one in the first place."
Although some of the pieces of what might go into a compliance plan may already be in place, for example, as part of quality assurance, consultants and other resources are emerging to help hospices develop a more formal policy.
The first step is to do an internal agency audit prior to implementing the plan to see what is there now and to generate baseline data. Then the hospice needs to appoint a compliance officer with the time and the authority to implement the plan, perhaps with the help of a compliance committee.
"You should have policies that state it’s [a requirement] of the program to comply with all applicable laws," Vickery says. "Then you need to do education and reeducation of staff, so they know it is your policy. You also need to have some kind of evaluation process and a policy of what do to about staff who don’t comply." There should also be a procedure to allow staff with concerns about regulatory violations to report them without fear of recrimination.
The Alliance of Community Hospices in Louisville and Elizabethtown, KY, has developed such a compliance plan, proposing to measure appropriate admissions and discharges, billing practices, intensity of services, and marketing practices. The plan also designates a chief compliance officer and includes procedures to protect the anonymity of complaints, an education and training program for staff, a code of activity, compliance and evaluation audits, and corrective actions.
[For more information, contact co-executive director Stephen Connor, PhD, at (502) 737-6300.]
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