How to be an Effective Compliance Officer
Scott Kraft, CPC, CPMA
Senior Compliance Consultant for DoctorsManagment, LLC
Being a Compliance Officer can often feel like a thankless job. When something goes wrong within the healthcare facility, the Compliance Officer is one of the first people considered when it is time to assign blame.
The challenge is that the Compliance Officer is charged with ensuring the organization functions properly across multiple departments, following the policies of multiple payers including state and federal government agencies, without the ability to individually supervise each person responsible for ensuring compliance.
In addition, leadership in many organizations is quick to view compliance as an expense that doesn’t generate revenue, sometimes failing to truly appreciate the impact the Compliance Officer has on the organization’s ability to generate and keep revenue.
Here are some tips to think about when determining how to be an effective Compliance Officer.
Earning buy-in is important. The Compliance Officer has to demonstrate to the practice’s ownership and/or Board of Directors that compliance needs to be funded properly to ensure that the organization isn’t facing unnecessary risk for lack of compliance. Uses for this funding include the on-boarding and training of all new employees, annual ongoing training as needed for new policies and procedures, the ability to audit and review documentation generated by the practice to ensure claims are correctly filed, as well as the ability to address each potential compliance risk the practice can face on an annual basis.
It’s not just management that has to buy-in. The Compliance Officer must ensure that front-line managers and their employees are performing each day in a way that ensures compliance. It’s important to build strong relationships throughout the organization and outline the goals of compliance in a way that feels critical to each individual’s success and integrated into what each employee sees as his or her role.
One size does not fit all – at least when it comes to compliance. The last thing any member of your organization wants to do is sit through compliance training that has nothing to do with their day-to-day job function, or touches on their role in the context of everyone else at the group. If your practice has individual job titles and roles and responsibilities mapped out, it’s important to adapt the training programs and modules to each of those roles. Naturally, there will be some overlap when it comes to employee responsibility, but an employee should be able to engage in compliance functions that matter most to their own performance.
Ensuring ongoing clean claims performance. One of the most critical functions in a medical office is making sure that claims filed to insurance for payment are for medically necessary services supported by the documentation. That includes a lot of practice personnel: physicians, billers, coders, and other compliance workers.
The Compliance Officer needs to know the exact claims filing process followed by the practice, including how claims are reviewed and corrected and how necessary feedback is given to the rendering provider. The Compliance Officer must also be able to determine where any breakdowns in that process may occur and how to hold the right people accountable to ensure corrective actions are taken when needed.
Ability to take decisive action or conduct fair investigations and take no action. Building a culture of compliance involves empowering employees to consistently report what they believe to be violations to compliance policy. These violations can be improper actions taken by individuals or flaws within the compliance process identified through day-to-day work.
Create multiple mechanisms for all employees to feel comfortable reporting violations, whether through their manager or an anonymous tip line. Take all complaints seriously and investigate and respond – even when complaints are found to not have merit or require corrective action. Employees talk to each other, and few things can derail a compliance program like the organizational belief that lip service is paid to employee feedback.
It’s critical that all employees can see the seriousness of the compliance program and the attention paid to feedback from individual workers. In addition, don’t take employee feedback to compliance programs personally or lightly. If the Compliance Officer creates a compliance training program that doesn’t work for the individual employees, be willing to accept that feedback and remain open to making revisions for the employees.
Here’s why thousands of providers trust DoctorsManagement to help improve their coding and documentation.
Quality of coders and auditors. Our US-based auditors receive ongoing training and support from our education division, NAMAS (National Alliance of Medical Auditing Specialists). All team members possess over 15 years of experience and hold both the Certified Professional Coder (CPC®) as well as the Certified Professional Medical Auditor (CPMA®) credential.
Proprietary risk-assessment technology – our auditing team uses ComplianceRiskAnalyzer(CRA)®, a sophisticated analytics solution that assesses critical risk areas. It enables our auditors to precisely select encounters that pose the greatest risk of triggering an audit so that they can be reviewed and the risk can be mitigated.
Synergy – DoctorsManagement is a full-service healthcare consultancy firm. The many departments within our firm work together to help clients rise above the complexities faced by today’s healthcare professionals. As a result, you receive quality solutions from a team of individuals who are current on every aspect of the business of medicine.