Home Health & Hospice Week

Follow this compliance director’s 7 tips.

The road to a successful compliance plan is full of pitfalls. To avoid a compliance crash, consider advice offered by certified coder Jacqueline Bloink, a consultant with Coding Continuum Inc. and compliance director for a provider group in Arizona, during CMS’s webinar, "Affordable Care Act Provider Compliance Programs: Getting Started:"

1. Follow OIG Guidance. HHS Office of Inspector General compliance guidance documents for many provider types are free and can help you craft your compliance plan within the government’s guidelines. See https://oig.hhs.gov/compliance/compliance-guidance/index.asp — guidance for home health agencies is at https://oig.hhs.gov/authorities/docs/cpghome.pdf and for hospices is at https://oig.hhs.gov/authorities/docs/hospicx.pdf.

2. Access Fact Sheets. The government’s Health Care Fraud Prevention and Enforcement Team, also known as HEAT, offers free fact sheets, webinars and other reference materials that can guide you, as can the webinars within the Centers for Medicare & Medicaid Services library, Bloink said.

3. Keep It Simple. Remember that the en-tire staff will be reviewing the compliance plan, so making it too filled with legalese is going to throw off almost everyone but the compliance officer. Instead, make the plan easy to read and concise to entice more participation. It should be tailored to your organization type and size. "Don’t let the compliance plan be only window dressing for the organization," Bloink said. "Fancy does not impress anyone if the plan sits on a shelf or in a computer file."

4. Set an Annual Review Date. On that date every year, you can tweak the plan to remove features that weren’t relevant to your agency, change elements to make the plan more specific to your activities, and determine whether you need to solidify further training in any areas.

5. Make the Compliance Plan a Positive Topic. Don’t treat the compliance plan like a scary endeavor, or people will shy away from addressing it. Instead, include it as another positive feature of your organization so people are eager to discuss it.

6. Ensure the Compliance Plan is Real. If you don’t intend to follow the plan, then it’s worthless, Bloink said. Make sure it’s realistic and accessible, and that staff members always have access to the compliance officer for questions and suggestions.

7. Keep it Friendly and Fair. Compliance professionals "need to stand up to some very strong personalities and organizations," Bloink said. "So you have to have guts, but you need to play fair."