Health Care Compliance Agenda: Relieve the Pressure – Risk & Compliance Journal

× Facing an onslaught of challenges that have been magnified by COVID-19, compliance leaders in

Facing an onslaught of challenges that have been magnified by COVID-19, compliance leaders in health care may benefit from new strategies to optimize, standardize, and digitize.

Before the novel coronavirus emerged and evolved into a global pandemic, many health care organizations were already on a journey to transform care delivery. The pandemic has accelerated this shift in many ways, for example through the increased use of telehealth, which leverages advanced technology to engage with patients remotely while reducing costs.

Still, the virus caused significant financial hardship for many health care organizations as routine services were paused to reduce risk to patients and providers. Further, regulatory shifts produced some uncertainty as well.

For example, as organizations were preparing for significant changes in rules governing interoperability of providers and medical records, the U.S. Centers for Medicare and Medicaid deferred the rules and provided other waivers with respect to several requirements. Meanwhile, increases in virtual care and remote work arrangements are prompting new concerns regarding regulatory compliance, privacy, and cybersecurity.

Even before the pandemic, significant escalations in cost, technology development, and regulatory scrutiny had prompted many organizations to reconsider several aspects of operations, including compliance. These varied, significant drivers are combining to have a substantial effect on compliance programs.

Many compliance departments are facing rising resource pressures coupled with risks that are increasing, both in number and severity. What’s more, many chief compliance officers (CCOs) and other compliance leaders are being tasked to do more with less.

Tensions Can Mount

To manage these emerging pressures, some compliance departments are considering resource reductions, using a corporate framework for making difficult decisions. Others have already made some cuts, perhaps with little time or opportunity to base such reductions on a risk-based strategy. Now they must determine how to sustain operations with fewer resources amid increasing risks. In other cases, CCOs may be anticipating a mandate to reduce resources and are proactively preparing to take steps when a reduction order is delivered.

Even when CCOs are not under direct resource pressure, they may be experiencing a different kind of tension to demonstrate value. Many health care executives are aware of the risks identified by compliance leaders and may have higher expectations for CCOs, hoping to find both agility and cost consciousness in a risk-intensified environment.

An important priority for health care CCOs in this environment is developing a game plan for sustaining operations amid heightened scrutiny with limited or diminishing resources. As an initial step, leaders can assess their compliance programs relative to industry guidance and good practices.

Helpful tools for performing this assessment include the Office of Inspector General’s seven elements framework and the Department of Justice’s Evaluation of Corporate Compliance Programs. Compliance leaders can also evaluate their current and anticipated level of resources and skillsets and deploy software and data analytics that support the program’s activities.

This evaluation can help identify opportunities to improve effectiveness and efficiency as well as establish short- and long-term goals to achieve those improvements. The evaluation also could represent an inflection point for CCOs who seek to transform their programs from reactive to proactive. Where CCOs adopt a risk-intelligent framework supported by technology, they often streamline risk and control activities and create value by reducing the cost of compliance while increasing effectiveness.

Three Ways to Chart a Course Forward

A risk-based, data-driven approach to compliance can help optimize resources, standardize processes, and leverage analytics and automation, which is often the foundation of a more agile, insightful, and efficient compliance program. A trio of actions can help compliance leaders and their teams move toward this approach.

Optimize labor. Organizations can compare program priorities with current activities to institute, continue, or terminate these actions as appropriate. Compliance leaders can realign workforce and resources to make the best use of skillsets and cross-train as needed. Technology may be able to perform high-volume, low-to-medium complexity tasks to free people for other purposes.

Standardize processes. Activities such as risk assessment, auditing, and reporting can be standardized and streamlined across the enterprise. Risks can be clearly defined and mapped to relevant controls, supported by a central repository of compliance and regulatory requirements. Once the activities are standardized, technologies such as robotic process automation (RPA) and machine learning can help reduce time and effort. Consider how this approach could improve reporting—for example by reducing the time spent on mechanical activities while increasing opportunity to extract valuable insights that could inform business decisions.

Digitize with automation. When compliance processes are standardized and data repositories are integrated into compliance programs, intuitive dashboards with real-time compliance data can be developed. Further, digital automation and controls rationalization can improve risk management efficiency and effectiveness in many cases. Additional savings can be achieved with RPA and AI to create compliance programs that adjust to changing business needs and therefore remain viable and scalable over the long term.

Consider how the three actions could improve a common health care compliance process such as managing revenue cycles and physician contracts, an area of heavy regulatory scrutiny. Many organizations assign senior compliance staff to manually analyze contracts and monitor payments, which involves extensive time downloading documents and data and performing visual inspections.

Many of the component activities of this process can be standardized and performed by RPA, enabling alerts to a staff member as frequently as daily to call attention to anomalies that merit human intervention. This might free up significant amounts of time for senior talent, whose skills can be put to other uses.

For health organizations, the COVID-19 pandemic represents a global experience driving unprecedented change that may carry forward for generations to come. Despite the devastating aspects of the viral outbreak, it has sparked some opportunities for health care organizations and their compliance leaders to innovate.

As they lean into significant headwinds, CCOs may identify new opportunities to transform the way they operate—increasing efficiency while improving the value of compliance programs to the business. In so doing, they may help to shape a new era for compliance—one where compliance sheds its reactive, status quo approach to become a proactive force for change in health care organizations.

by Steven Curry, partner, Dhara Satija and Heather Hagan, senior managers, all with Deloitte Risk & Financial Advisory, Deloitte & Touche LLP


Source Article