Medicare Compliance & Reimbursement
How To Bulletproof A Hospital's Staffing Compliance
Even if a hospital has buckled down on federal and state staffing laws and has controls in place to ensure every employee gets a background check and a drug test, it still isn't ready to ace an audit.
Without proper follow-up procedures, even a compliant facility could run into snags. Case in point: In a Sept. 22 audit of Emily P. Bissell Hospital (A-03-03-00223), the HHS Office of Inspector General found the Wilmington, DE-based facility was in full compliance with federal and state staffing laws and regulations. But missing results on drug tests and background checks for 15 direct-care employees marred an otherwise seamless audit.
Here's how the hospital tidied up:
1. Drug test delays. State laws required Bissell to obtain drug-test results within two months of hiring an employee.
Problem: Although it had internal procedures to verify that it completed the drug testing, the facility did not follow-up when the results were not received within that time frame. This lapse allowed 12 employees to continue working directly with residents with no results on file. Remedy: According to director Charles Thompson, the hospital switched dug-testing laboratories because of the previous lab's "administrative issues" that caused unnecessary delays in reporting test outcomes.
2. Missing background checks. Bissell hired employees on a conditional basis while awaiting results of federal and state background checks.
Problem: Bissell lapsed on follow-ups. As a result, two direct care employees remained on the payroll for three years without any background check results received. Remedy: A new tracking system is now in place that will alert human resources when a criminal background check (or drug test) is not obtained within the required timeframes.
To read the report, go to www.oig.hhs.gov/oas/reports/region3/30300223.pdf.
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