YouCompli

CEO Jerry Shafran has prepared a festive video to help us wrap up the year. We wish you a safe and happy Holidays and New Year! Explore More and Subscribe - https://hubs.la/Q030298G0 #compliance #healthcare #YouCompli

As of right now, covered entities under HIPAA must comply with Executive Order 14076, officially titled Protecting Access to Reproductive Healthcare Services (the “Rule”), by December 23 – less than two weeks from now. 🗓️ However, as a consequence of the 2024 presidential election results, there are questions regarding the enforcement of this regulation. Here’s what you need to consider. 🤔 The Rule was one of many actions taken by the Department of Health and Human Services (HHS) to protect access to and privacy of reproductive health care after the Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization. ⚖️ The Dobbs decision has led to extreme state abortion bans and other restrictions on reproductive freedom in 21 states. 🚫 The Rule directs HHS, the Federal Trade Commission (FTC), and the Department of Justice (DOJ) to take and consider steps in their respective fields to protect reproductive healthcare services and access to them. 🏥 It establishes a ban on the use or disclosure of PHI by a HIPAA-covered entity (i.e., healthcare provider, health plan, healthcare clearinghouse) or their business associates (BAs) for any of the following: 🔹Criminal, civil, or administrative investigations into any person for the mere act of seeking, obtaining, providing, or facilitating reproductive healthcare. 🚨 🔹Imposing criminal, civil, or administrative liability on any person for the mere act of seeking, obtaining, providing, or facilitating reproductive healthcare. ⚖️ 🔹Identifying any person for any purpose described above. 🔍 A covered entity or BA must obtain a written attestation that the information is not for a prohibited purpose before PHI potentially related to reproductive healthcare can be used or disclosed in many circumstances. 📝 The attestation must be in plain language, signed by the requester, and must clearly state that the PHI is not for “criminal, civil, or administrative investigation into or proceeding against any person in connection with seeking, obtaining, providing, or facilitating reproductive healthcare.” 🖋️ With Donald J. Trump set to return to the White House in January, the healthcare industry should expect to see changes in the enforcement of the Rule. 🏛️ It is likely that the Trump administration will not support the changes that enhance the privacy of reproductive health information. It is also reasonable to expect the new administration to downplay any compliance obligations stemming from the Rule, and perhaps even a total lack of enforcement efforts. ❌ It is recommended that healthcare compliance and privacy professionals continue to take steps to achieve compliance with the requirements of the Rule, while keeping in mind that significant changes may be on the horizon. 📋 Read the full article from Susan Thomas here ➡️ https://hubs.la/Q02_9HCW0 #compliance #healthcare #HIPAA #HHS

Most quality professionals never build an educational program for their organizations before they’re asked by someone to do so. It will probably happen to you too, so don’t get down – everyone else ended up with a fully functional program, and you will too. 💪🩺 The first thing that you should understand is this: you don’t have to build the perfect program. Your education program just needs to be good enough to ensure employees have the training needed to demonstrate core knowledge and pass audits and inspections. 📋✅ First, it’s all about policies. At a bare minimum, have your employees sign off on all your policies, procedures, administrative work instructions, etc. early in their tenure with you. From there, look at the regulations that govern your organization and see what applies so you include it. Build your program to train people in whatever applies to your organization. Also be sure to look at recent inspections that you have received from auditors, inspectors, or other regulators. 📝🔍 When you have this ready to go, you just roll it out. There isn’t just one right way to do that, but the best place to start is to require all newcomers to undergo some sort of orientation onboarding. While human resources generally lead that, all key leaders should participate so employees get familiar with everyone. Orientation also should present a high-level overview of the entire organization with departmental specifics mixed in. 👥🏢 You also need to have a plan for ongoing education. The best way to find out what needs to be in this part of your program is to ask your employees. Many employees will tell you where they feel they need more training if you ask them. Give them the resources, either internally through your department or externally from educational modules. The development of employees is your responsibility. 📚💡 When it comes to building a quality education program, none of this would be seen as reinventing the wheel; it’s all stuff that people have been doing for a long time. But it’s essential that you build an education program that works. Doing that right means covering the basics well more than adding fancy bells and whistles; this is what will lead to sustainability for you and the organization. 🔄🏥 Read John R. Nocero PhD, CCRP and Andrea Bordonaro's full article here ➡️ https://hubs.la/Q02-drky0 #compliance #healthcare #quality #qualityeducation #qualitycontrol #quality management

For Thanksgiving week we're revisiting a fitting post from Susan Thomas! 🦃 In a football game, the Fourth Quarter can define the moment for either the team defending its lead or the team trying to reverse its fortune. Effective play action, clock management, and teamwork help maintain possession and run the clock down. Conversely, the trailing team must regroup and often change its game plan. 🏈 Similarly, a Compliance Officer is accountable to leadership and the Board for the compliance program’s effectiveness. This depends on accurate data to assess the team’s status and plan the best path forward. As the Fourth Quarter approaches, compliance initiatives must be evaluated before the year’s end. 📊 The coach and key players typically provide a wrap-up at a post-game news conference, offering insights into the team’s plays and outcome. Similarly, one key Fourth Quarter responsibility for the Compliance Officer is producing the Annual State of the Compliance Program Report. This report provides valuable insight into the organization’s compliance with laws, regulations, and industry standards, highlighting control weaknesses and compliance risks. 📋 A valuable Annual Report demonstrates credible outcomes of the compliance program’s progress and planned enhancements for the next year. It highlights opportunities for improvement and planned actions to enhance effectiveness. 📈 Leadership and the Board need the necessary information to ask informed questions and carry out strategic objectives. While the Annual Report offers an overview, the Compliance Officer must also provide detailed reporting on program initiatives. 📝 Successful teams produce fan satisfaction and revenue for stakeholders. High-quality compliance programs protect the organization from non-compliance consequences and contribute to quality patient care and financial success. 💼 As we enter the Fourth Quarter, both football coaches and Compliance Officers must take inventory, assess progress, and report results to demonstrate positive outcomes. This review will reveal accomplishments and future opportunities. 🚀 Read Susan Thomas' full article here: https://hubs.la/Q02ZCKDD0 #compliance #healthcare #FourthQuarter #OIG

In the hustle and bustle of today's business world, speed often takes precedence over everything else—especially in the world of a compliance officer. As regulations change or investigations are needed, we often get pushed to work faster, meet tighter deadlines, and juggle multiple tasks simultaneously. 🚀 While this approach might seem efficient on the surface, it often leads to several downsides—burnout, decreased productivity, and a decline in the quality of work. 😓 Here are five tips to help you and your compliance team slow down: 1️⃣ Lead by Example 2️⃣ Define Productivity 3️⃣ Set Realistic Expectations 4️⃣ Encourage Regular Breaks 5️⃣ Educate Them on the Importance of Quality Over Speed Compliance work is complex, and in today’s environment there is a constant push to be faster. If you follow the approaches outlined above, you will help your employees find a more balanced approach to their work and improve the efficiency and overall performance of your compliance program. 🌟 Read Jay Anstine's full article here ➡️ https://hubs.ly/Q02YQykq0 #compliance #healthcare #culture

How would you define quality?🤔 We bet that if we asked ten of you, we’d get ten different answers ranging from doing the right thing ✅ to ensuring patients are protected 🛡️ and data integrity 📊. Why is there no clear-cut answer? Why are we getting so many different responses? Think of quality this way: you may not be able to explicitly define it, but you know it when you see it. While there are seven elements, as the Office of Inspector General will tell you, quality assurance (QA) and quality control (QC) are not explicitly included. Much like the terms that define quality, QA and QC are often used interchangeably. Although similar, there are distinct differences between the two and we argue that you need both for an effective quality management program 🏥. According to the American Society for Quality (ASQ), QA is defined as "part of quality management focused on providing confidence that quality requirements will be fulfilled." Alternatively: "all the planned and systematic activities implemented within the quality system that can be demonstrated to provide confidence that a product or service will fulfill requirements for quality." The confidence provided by quality assurance is twofold—internally to management and externally to customers, government agencies, regulators, certifiers, and third parties 🏢. ASQ defines QC as "part of quality management focused on fulfilling quality requirements." While quality assurance relates to how a process is performed or how a product is made, quality control is more the inspection aspect of quality management 🔍. An alternate definition is: "the operational techniques and activities used to fulfill requirements for quality." QA sets guidelines and standards and establishes a foundation for an entire team to follow 📋. This approach slightly differs from QC, which identifies and corrects defects or deviations in the final product or service. Unlike QA, which works to prevent issues throughout the entire process, QC is specifically concerned with evaluating the result to ensure it meets the predefined quality criteria ✅. For example, your organization probably has an internal audit program. QA would pertain to creating a plan and process to ensure that a procedure is being followed. QC would be routinely checking data to ensure that the appropriate data was entered within a specified time frame ⏱️. Understanding the differences between QA and QC helps organizations implement effective quality management systems, ensuring high-quality products and services that meet customer expectations 🌟. Both of these are tools in your toolkit, so why limit yourself to just one? Use QA to prevent problems and ensure adherence to standards – and take a proactive approach and use it before you start. Use QC to identify and correct issues after the product or service is produced and the work has started 🔧. ➡️ https://hubs.la/Q02Y516M0 #compliance #healthcare #qualityassurance #qualitycontrol #qual...

In this week’s post on the YouCompli Blog, we revisit a favorite of ours from Lisa Herota. She writes about the benefits of strong partnerships between Compliance and HR teams – and how to create them. 🤝 Integrating Compliance and HR builds trust on many levels of an organization – among employees, up and down organizational charts, among leadership, etc. Compliance and HR partnerships also reinforce to employees that their organization is an ethical place to work. ✔️ Compliance and HR can integrate and form partnerships using three primary strategies: 1️⃣ Developing Standard Interview Questions – Having a set list of questions to ask candidates will reinforce the company’s compliance and ethics focus from the outset. It also will help identify the best fits for that culture, so they can be hired and onboarded. 📝 2️⃣ Building Leadership Competencies – Starting with interviews for executive positions and continuing from ongoing meetings to input on performance reviews, set baselines for activity among leaders that stress compliance and ethics. ✍️ 3️⃣ Sticking Your Neck Out – It often falls to Compliance to make the first move in establishing these partnerships. Show up, put in the effort, check in regularly and offer support however you can. 💡 When done well, strong partnerships with HR can be the secret to a great Compliance department’s success. 💪 Read Here ➡️ https://hubs.la/Q02X7Sty0 ⬅️ #healthcarecompliance #Compliance #LisaHerota #HR #HumanResources #Culture

🚨NEW BLOG ALERT🚨 Advancements in medical diagnosis and treatments often begin with clinical research and services performed at academic medical centers. Yet most compliance pros don’t realize there are unique compliance issues involved with research and services in academic settings. Here are three of the issues. 🔸Issue 1: Teaching Physician Billing Rules Academic medical centers usually offer graduate medical education (GME) where recent graduates can train in a specialty as part of a residency. Medicare makes GME payments to support these new physicians’ residencies and training – but does not allow additional payment to attending or supervising physicians unless they are involved in direct patient care and meet certain requirements. These requirements are often known as teaching physician billing rules. 🔸Issue #2: Clinical Trial Billing Academic medical centers are frequently involved in clinical research through participation in clinical trials. When medical services are provided in conjunction with these clinical trials, some may be reimbursable by Medicare (for example) and other services might not. These coverage rules are explained in a Medicare National Coverage Determination (NCD) titled “Routine Costs in Clinical Trials (310.1).” By not following these rules, and billing Medicare for services that should have been billed to other entities such as a clinical trial sponsor, organizations can get themselves into compliance trouble. 🔸Issue #3: Conflict of Interest Disclosures Many recipients of grants awarded by the National Institutes of Health (NIH) are researchers at universities and academic medical centers. These federal dollars come with many requirements, including accurate and truthful conflict of interest disclosures – especially as they may relate to any influence or collaboration with foreign actors or organizations. If you work in or partner with an academic medical center, these three unique scenarios are likely to come into play. Be sure you have a plan for ensuring compliance with them or create and implement one at your earliest opportunity. Read CJ Wolf, MD, CPC, CPC-I's full article here ➡️ https://hubs.la/Q02Wg-W_0 #compliance #healthcare #coding #academic #research

🚨 NEW YouCompli BLOG 🚨 Leaders in compliance often come from a variety of backgrounds, each bringing unique perspectives and skills to the table. Whether their expertise lies in law ⚖️, business management 📊, or clinical care 🩺, these professionals play a critical role in ensuring that healthcare organizations meet their regulatory obligations while maintaining high standards of patient care and operational efficiency. Let’s review how the backgrounds of compliance leaders in legal, business (MBAs/MHAs), and clinical fields often shape their approach to compliance leadership, and why each’s approach is valuable. 💠Legal Background: Navigating Regulations with Precision ⚖️ Compliance leaders with a legal background have significant experience working with healthcare laws and regulations. Their strength lies in their deep understanding of regulatory frameworks, including the nuances of state and federal laws such as HIPAA, the False Claims Act, and Stark Law. 💠Business Background: Strategic, Big-Picture Thinkers 📊 Compliance leaders with a background in business – often holding MBAs or MHAs – bring a different perspective focused on strategy, operations, and organizational efficiency. These leaders often have experience in healthcare administration or executive management, which gives them a comprehensive understanding of the business side of healthcare. 💠Clinical Background: Patient-Centered and Ground-Level Insight 🩺 Compliance leaders from clinical backgrounds, such as nurses, physicians, or other healthcare providers, bring an invaluable, patient-centered perspective to compliance management. Their experience in direct patient care allows them to understand how compliance affects both patient outcomes and day-to-day operations. Healthcare compliance is a multifaceted challenge, and compliance teams benefit from having people from diverse leadership backgrounds. Leaders with legal, business, and clinical expertise each bring unique strengths to the role, ensuring that compliance initiatives are legally sound as well as strategic and patient-centered. The most successful compliance programs often come from a collaborative approach, where legal precision, business strategy, and clinical insight intersect to create a robust framework that promotes both regulatory adherence and high-quality care. Regardless of who is leading the team, it’s critical to include staff on compliance teams from all backgrounds. No single background has all the answers, but by combining the strengths of these diverse perspectives, healthcare organizations can navigate the complexities of compliance with agility and confidence. Read Amy L.'s full article and explore other helpful articles here ➡️ https://hubs.la/Q02Vtnv30 #compliance #healthcare #regulation #diversity #Culture

🚨 NEW BLOG POST 🚨 Radiology services can be accompanied by some unique compliance challenges that do not always exist with other types of health care services. The following tips can help compliance professionals as they develop strategies to monitor compliance associated with typical radiology services. Tip 1️⃣: Document Clinician Orders for Diagnostic Tests Tip 2️⃣: Document Medical Necessity for Imaging Services Tip 3️⃣: Read, Understand, and Follow Local Coverage Determinations Tip 4️⃣: Know the Rules for Teaching Physicians in Radiology Radiology services have unique characteristics, and some unique compliance considerations that accompany them include compliance rules associated with physician orders, medical necessity, local coverage determinations, and teaching physician settings. Compliance professionals need to be aware of these and others as they develop strategies to follow rules and regulations associated with typical radiology services. #compliance #healthcare #coding #Medicare #radiology 📘 Read CJ Wolf, MD, CPC, CPC-I's full article and download the tip sheet here ➡️ https://hubs.la/Q02TQs6s0