I just returned from the Health Care Compliance Associations 23rd Annual Compliance Institute. It’s always the highlight of my year to spend 3 days immersed with over 3000 compliance professionals and representatives from the OIG and DOJ learning the next areas of risk.
To summarize many sessions, coffee dates, OIG keynote speakers and brainstorming sessions, there was really one reoccurring theme:
Several sessions stressed that the government has more and more access to your data and they are focusing on outliers.
The OIG keynote address was presented by Joanne Chiedi, Principal Deputy Inspector General OIG, HHS. Her message was that the OIG has four keys areas that they are focusing on internally as an organization and how these areas should be integrated into our SNF organizations.
If it’s an OIG priority, it probably fair to say it should be a priority in your organization as well.
The four key areas of focus for the OIG expressed by Chiedi are:
- Agility and Adaptability: A key internal goal for the OIG is to become nimble and able to adapt to change. This is a pretty bold statement coming from a government agency. What does this mean to us as the provider? Chiedi recommends that organizations make sure they have full access to their data. This will help you identify compliance soft spots and liabilities before they come to the government’s attention and potentially become bigger, more expensive issues.
- Continuous Prioritization: The OIG has a priority “to scan the environment early and often and with multiple lenses—looking around at the current state of play and at the horizon for emerging issues.” It is critical to ask ourselves as an organization if we have a process in place for scanning and prioritization of our compliance activities. Do we understand our areas of risk and how we are trending as an organization? Do we have tools to place to find out these areas of risk quickly and in real time?”
- Compliance Leadership: The OIG stresses that compliance and oversight must be ”forethoughts, not afterthoughts.” This is certainly not a new concept for us in LTC. We seek leadership that is always proactive in their mission and not reactive. A specific compliance leadership recommendation from the OIG was to seek a meeting with the people planning your data or technology function. Ability to have real-time access to facility data will be pivotal to effective leadership.
- Strategic Partnerships Per Chiedi, partnerships are more vital than ever in this complex, disruptive healthcare world. Working with mission partners who share your passion for effective oversight makes a huge difference. Now is the time to look at your partners, specifically your tech partners, to make sure as an organization your partnerships are assisting your goal to remain the compliant, proactive organization you are meant to be. Chiedi made one statement that really resonated with us: “We can’t oversee what we don’t understand— those that don’t will fall behind.” Do the tools you use help you stay ahead?
Finally, the Chiedi stressed that as providers, we can’t shy away from technology. We must learn to embrace it— after all, the OIG is.