Tips for a Successful Compliance Oversight Committee

Compliance is the golden word in the home health industry. With the incredible amount of regulation surrounding home health, it’s no wonder that anyone trying to sell anything in the industry uses and abuses the word. Why wouldn’t they? There are so many regulatory bodies to be compliant with. Every home health agency has their standard 2,000+ page policies and procedures books, their OASIS Guidelines manuals, their OBQI/OBQM manuals, and the list goes on.

Today, we’re discussing the elements of a successful compliance oversight committee within your organization. Using OIG’s “Practical Guidance for Healthcare Governing Boards on Compliance Oversight” book as a guide, we’re going to dissect how to create and maintain agency-wide compliance.

A Realistic and Manageable Schedule

The first thing to do is set a realistic and manageable compliance review schedule. For example smaller agencies may not have the resources to consistently spend time on compliance review, while larger agencies may need to review compliance issues more often. Understanding the needs, but also the limitations of your organization will help set a manageable yet sufficient schedule for compliance review.

A quarterly compliance schedule allows agencies regular organizational review without overkill.

Appointing Personnel

Appointing personnel to your committee is an important decision. Committee members should be knowledgeable in the field without being biased to overlook certain problems. Many agencies even opt to outsource this process in order to get the most un-biased review possible. Depending on an agency’s resources, this may or may not be a good option for you.

Setting Your Review Goals

The amount of ground covered will depend on the size of your agency and compliance review committee. Don’t overstretch. Set realistic objectives for each review session. Make sure you allot time for re-visiting previously deficient areas to make sure that the plan you’ve put into motion is working. If it’s not working, it’s critical to spend time altering your plan to ensure success. Setting a realistic set of objectives will allow your agency to actually enact and maintain plans set in motion from review activities.

Areas for Review

Areas that should be revisited often include, but are not limited to:

  • HR

  • Admission and Discharge Activities

  • Care Coordination

  • Incident Handling

Culture of Compliance Reviews

Whether your agency outsources compliance reviews or not preparing your staff for the process is essential. For many staff members, a compliance probe can feel intrusive and threatening. To avoid this, meet with staff members before the process begins and explaining that the focus is on fixing issues, not finger pointing. Make sure that the person conducting your compliance review will also take a cooperative approach with staff members. Creating an educational culture for compliance reviews will ensure that staff members will be cooperative, not defensive with the reviewer.