Managing for Compliance A Presentation with Homework. The Plan for the Day. Some Starting Questions

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1 Managing for Compliance A Presentation with Homework Presented for Susan Balfour, RN Hospice Fundamentals susanbalfour@hospicefundamentals.com The Plan for the Day 1. Costs of Non Compliance 2. Why Is It Important? 3. If You Could Wave a Magic Wand 4. The Seven Links Some Starting Questions 1. What are three common compliance challenges at your hospice? 2. How do they impact quality of care? 3. How do they impact the health and long term viability of the organization? All Rights Reserved

2 Link #1 A Culture of Compliance 1. Commitment to doing the right thing 2. An understanding of a. our place in the healthcare system b. what agreeing to accept Medicare payment entails Link #2 Regulatory Competency 1. Defined expectations of regulatory knowledge by position 2. Assigned responsibility for monitoring regulatory changes 3. Plan for teaching regulatory content in orientation and at regular intervals 4. Plan for communicating changes at appropriate levels 5. An internal process to use when there is no answer 6. Ability to assess risk of any action or inaction 7. Understanding of The Path of the Prudent Hospice Who Needs to Know What? I. Line Staff what to do and when to do it II. Supervisors what to do, timeframes and where to find it in the regulations III. Managers what to do, time frames, where to find it in the regulations and working knowledge of overall framework IV. Compliance what to do, timeframes, where to find it, when it came to be (and when possible, why it came to be), risk areas, what s new and how it all fits together All Rights Reserved

3 42 CFR 418 Subparts A. General Provision and Definitions B. Eligibility, Election and Duration of Benefits C. Conditions of Participation Patient Care D. Conditions of Participation Organizational Environment E. Conditions of Participation Removed and Reserved F. Covered Services G. Payment for Hospice Care H. Coinsurance What s the Difference? Conditions of Participation Care Delivery / All Patients Subparts C & D Conditions of Coverage Payment / Medicare Patients Subparts B & F A hospice can t submit a timely plan of correction if there is no one there to write it. Roseanne Berry, MSN, RN Partner, Hospice Fundamentals All Rights Reserved

4 Link #3 Agency Standards & Processes This is how we do it here Link #4 Supervisor Development 1. Guiding the Work 2. Organizing the Work 3. Developing Your Staff 4. Managing Performance 5. Managing Relations Skill Sets Conceptual Skills Human Relations Skills Technical / Professional Skills Staff Member Front Line Supervisor All Rights Reserved

5 Buy One (or Both) of These Books Why Employees Don't Do What They're Supposed To and What You Can Do About It Coaching for Improved Work Performance Author: Ferdinand F. Fournies Link #5 Education When? How? By whom? Outcome? Link #6 Monitoring Monitoring Agency Standards Education All Rights Reserved

6 Link #7 Celebrating It s hard work pat yourselves on your backs and have a party! Case Example: Documentation 1. A Culture of Compliance 2. Regulatory Competency 3. Agency Standards & Processes 4. Supervisor Development 5. Education 6. Monitoring 7. Celebrating Susan Balfour Partner, Hospice Fundamentals susan@hospicefundamentals.com All Rights Reserved

7 Managing for Compliance Homework Sheet Link / Score 1 to 10 In Place What It Would Take to Increase Score 1 Culture of Compliance 2 Regulatory Competency 3 Agency Standards & Processes 4 Supervisor Development 5 Education 6 Monitoring 7 Celebrating 1. Working individually, score each of the 7 link areas (10 is the highest possible score; 1 the lowest) 2. Compare as a group; discuss and compile group score (calculate average score based on individual scores or come to consensus as a group) 3. Complete columns 2 and Formulate plan with assigned responsibility and time frames. All Rights Reserved 2015 Susan Balfour