As we turn the page on what can only be described as a “one of a kind” year we have a tremendous opportunity to look back at 2020 and really evaluate how the compliance program performed, and where 2021 might provide some opportunities to improve, change direction or re-tool the program.
The pandemic forced providers to pivot in ways they never thought possible; from working remotely, to resident lock-downs, to being required to immediately terminate lines of business, healthcare providers have been through a lot in 2020. While some of the enforcement rules for things like telehealth and sharing of information for public health purposes were relaxed at the discretion of the regulators, providers still had an obligation to ensure their organizations were free from fraud, waste and abuse. Admittedly, with reduced staff due to employees who were sick, caring for sick relatives, or staying home with kids who were not in school, compliance often took a backseat. Many smaller providers simply did not have the staff needed to care for people let alone conduct normal auditing and monitoring activities. The list of how compliance programs were impacted by the pandemic goes on and on. However, it is important to remember, whether times are good or we are in the middle of a world-wide pandemic, the obligations of healthcare providers to ensure their operations were functioning in accordance to all applicable laws and regulations remains. Simply put, a pandemic is not an excuse to cut corners.
Many providers have started the process of administering the vaccine to employees and those for whom they provide care, and it looks like there is a light at the end of the tunnel. Rather than letting down our guard, now is the perfect time to take a moment to consider how the compliance program fared over the last 10 months. Investing a few hours in the process of honestly reviewing the role compliance played in this time that no one expected can be a tremendously valuable window into the effectiveness of the program. Did compliance education still happen? Were there any HIPAA issues that happened because of the impact of the pandemic? What auditing and monitoring activities took place? Do any compliance policies and procedures need to be revised due to what was learned during this time? These are just a few of the questions you can ask yourself so you can grade the performance of the organization from a compliance perspective.
We hope the world never sees another year like 2020 but we have no way of knowing what is around the corner. Taking the time to look back will enhance the ability to look forward.