Healthcare compliance for providers: An introduction

What is compliance? Compliance is:

1. Following the law and regulations at all times, under any circumstance
2. Adhering to ethical behavior
3. Integrity
4. A culture of doing the right things, a mindset, an awareness
5. Transparency and willingness to learn and correct any errors no matter the cost
6. Communication and a fundamental stance in professional and personal dealings

 
Healthcare is essentially about a high calling and ethical behavior, about caring and compassion, about trying to help heal and improve others. It is fundamentally something positive and soul-ful. But in daily activities we sometimes tend to forget that. Compliance is essentially an attempt to raise everything to the highest standards of what we already do, ensuring that we do not forget who we are at all times, and pulling up everything that begins to gravitate downwards by inattention or carelessness or slow degeneration and venality.
 
Human nature tends to find the easy way out sometimes. Our goal is to ensure that we listen to our higher nature, follow our heart and never forget or allow ourselves to forget that we have to ensure the highest standards of our practice. We have to become responsible to ourselves and others and realize that we enjoy a high station in the community and society for which we need to be answerable and we cannot allow bad behavior, no matter what the temptation.
 
Only compliance can ensure true quality and proper evidence-based medicine, safety of patients, staff and providers, positive outcomes and a long term growth and success of the organization. Without compliance, it remains a house of cards that will be only more likely to collapse upon itself the higher and bigger it grows due to its own weight.
 
Healthcare compliance requires a clear vision and mission statement, code of conduct, a culture and a structure to the compliance team in the hierarchy of the organization. It requires establishment of standards which need to be communicated unequivocally across the company education and training, oversight and review, monitoring and auditing as needed. All these require clear policies, procedures and processes to be established. It may require reporting and risk-assessment, enforcement and discipline and eventually mature to a state where it is preventative and pro-active rather than reactive and after the fact.
 
Such are the elements that the OIG, DOJ and the federal guidelines have suggested. Eventually, compliance is mandatory and it is incumbent upon any and responsible organizations to embrace it whole-heartedly and implement it as effectively as possible.

A compliance score for all activities in the organization can be created which can be benchmarked and followed. An annual compliance plan prioritizes risks after evaluating them, involves subject matter experts and legal counsel as needed, creates a reporting structure to the Board of Directors and works at the highest level to educate and adapt with advancements in technology and changes in regulations.

The Compliance Officer is not part of management and has an innate independence of outlook and insight and should be objective and unbiased. He or she should not be implementing changes but rather work with management to make them happen. A compliance committee which includes the leadership of the organization should be constituted as champions of the compliance program, to support it with SMEs, to bring in a wealth of wisdom, experience and diversity of opinion and open up channels of communication among all the departments.
 
Compliance effectiveness should be measured regularly and addressed on a real time basis. Compliance is a process in constant evolution and is never finished. It should be the living and breathing all-pervasive essential nature of the organization, its chi, its prana, its life-blood.
 
Why compliance for Providers?

1. To keep them safe, personally and professionally
2. To ensure quality for patients
3. To establish ethics in the company and a culture of the highest standards of our profession
4. It is mandatory
5. To ensure long-term success and survival
6. To create a positive value and true prosperity
7. To create true happiness and a sense of fulfilment
8. Brand value of the company

Compliance is not a rule-based approach but a value-based one. Moreover, it is not enough to create policies that are not followed. If policies are created just for the sake of creating them, that can be held against the organization. Compliance should be tailored to the needs and specific niche of the organization and needs to be customized to each entity.

Compliance is about creating the right environment, the framework and influencing individual choice in alignment with the goals of the company.