Module 06 Course Project – Final Submission
It’s time to put your two compliance plans all together into one report. Be sure to implement your instructor feedback and proofread all your work one last time. In addition, check the requirements in the original assignment.
Be sure to write a summary statement and insert it at the end of the project before the References Page. (See the outline below.) In your summary statement, describe your own journey in working on this project. Explain how this project has strengthened your understanding of compliance rules and regulations.
Your final plan should include the following. Note the overview at the beginning and the summary statement at the end. Remember to check details to insure that your plans will be understood by all employees at a large medical facility where you are the Compliance Officer.
- Cover Page
- Overview of Compliance
- First Compliance Plan
Policies
Procedures
Monitoring Tools - Second Compliance Plan
Policies
Procedures
Monitoring Tools - Summary Statement
How this project has strengthened your understanding of compliance rules and regulations.
- References Page
At least twelve research references for both compliance plans.
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Compliance Plan
Name
Course
Professor
Date
Compliance Plan
Following the outbreak of COVID-19, the institution took numerous measures to mitigate the spread of the virus among the staff and also the patients. It is sad to note that country has lost thousands of healthcare personnel which calls for each healthcare facility to remain vigilant and enforce all Covid-19 protocols without reservation. Reliable sources indicate that more than 570,000 healthcare workers have been infected while more than 3,000 have succumbed to diseases (Lewis, 2020; PAHO, 2020). This is not exceptional in our facility hence need strict compliance with protocols that have been issued by the ministry of health and also facility management to keep the virus at bay in the concerted effort to protect vulnerable clinical staff members as well as dear parents. It is worrying to note that some of the clinical staff members violate COVID protocols and measures that have been put in place by failing to wash hands between patients. Management of facility has severally pronounced itself on this matter and would wish to restate that clinical staff members must wash hands between members. This does not only apply because of the existence of a pandemic but is a cardinal principle for our operation. Considering the severe impact of Covid-19 and the fact that no cure has been established, developing a compliance plan will necessary to protect the spread of the virus in the facility among health workers and also to the members of the public. Further, this will also help to protect the families of healthcare workers and also to ensure the facility remains operational.
Finally, it has been established that medical staff members charge extra for the application of the initial cast. However, the application of the initial cast is included in the cost of the visit. This might ruin the reputation of the facility because patients could feel that they are being exploited. As a result of this, a compliance plan is necessary that guides medical staff members on what each charge entails to avoid overcharging patients.
References
Lewis, R. (2020, December 23). Did they have to die? How America’s Covid response left 3,000 health workers dead. Retrieved from
https://www.theguardian.com/us-news/2020/dec/23/us-healthcare-workers-died-covid-coronavirus
PAHO. (2020). COVID-19 has infected some 570,000 health workers and killed 2,500 in the Americas, PAHO Director says. Retrieved from https://www.paho.org/en/news/2-9-2020-covid-19-has-infected-some-570000-health-workers-and-killed-2500-americas-paho
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Compliance Procedures
Name
Course
Professor
Date
Compliance Procedures
In module 3, compliance policies were developed for two compliance plans. Normally, policies set out rules and parameters of what needs to be done. However, what needs to be done and how should be done are two different concepts. It is possible medical facilities could be having progressive compliance policies but the effect will be determined by how these policies are implemented. Process or steps which outline how compliance policies are implemented in the medical facility for two compliance plans is known as compliance procedure.
Compliance Procedure for Covid Protocols.
It has been established that the health sector is one most hit by COVID-19 in the United States with approximately 4% of healthcare professionals succumbing to the virus. However, even with such a glaring dangerous infectious which continues to destabilize the healthcare system, cases of violation to handwashing were noted in our medical facility. It is on the background of this compliance policies were written in project 3- that is standard protocols that entail precaution practices such as hand washing and PPE and, communication policy to relay information on prevention to medical staff and clients (Beyamo, Dodicho & Facha, 2019). However, having compliance policies is not adequate and that is why compliance procedure has been developed.
Compliance procedure to implement standard COVID protocols and communication policy comprises of five steps/processes. These processes are outlined below and every medical staff is invited to read and familiarize themselves with the laid down procedure.
Step 1: The compliance officer develops standard precautions that medical staff should comply with to minimize the spread of the virus. Compliance officer needs to research and consult with the ministry of health, world health organization and CDC to establish standard precaution that relates to COVID protocols.
Step 2: Compliance officer shares with management on standard Covid protocols that is a standard precaution which facility need to implement to prevent the spread of the virus. This will enable management to procure medical devices such as an apron, gloves, surgical face mask, and sanitizers and hand washing points to be put in the medical facility (World Health Organization, 2020; Beyamo et al…, 2019). This is very important because it helps to ensure necessary medical devices required to implement precaution measures are available.
Step 3: Compliance officer avail publication to medical staff which outlines standard precaution measures that have been recommended by management. In the publication, another standard precaution which medical staff should implement, a statement of administrative and disciplinary action statement which is meant to reinforce standard precaution. Additionally, the publication states that medical staffs have the right to demand to be provided with effective and adequate PPEs before they attend to the clients (Sheldon, 2019). Therefore, management must ensure that the medical facility has adequate and recommended PPEs to offer medical staff protection and minimize the spread of the virus among colleagues, family members and clients.
Step 4: Training session for medical staff. A compliance officer will organize a training session that will incorporate management officials and guests from the ministry of health. The training session will seek to educate medical staff on how to put PPEs and other standard precautions measures that should be observed when attending to patients. Further, training will create awareness of the importance of observing standard COVID protocols that relate to precaution measures.
Step 5: The compliance manager will develop a communication framework that is tailored to educate clients on COVID regulations which are implemented in the medical facility. At the entrance of the medical facility, clients will be made aware of the existence of COVID, prevention measures that have been put in the facility and obligations of clients in containment effort.
Procedure for Billing Plan
A billing compliance plan was developed for the medical facility after it was revealed some staff that bill clients charge them twice. This is unacceptable and against the code of ethics for Medical facilities. The facility is against the exploitation of clients and is committed to remaining a truthful and trusted institution. However, this cannot be attained when some employees want to take advantage of clients who possibly do not have knowledge of systems used to charge clients. Such practices are not only rampant in our medical facility and also in public health facilities. It is for this reason Medicaid Fraud Control Unit instituted a system to prosecute healthcare personnel that fraudulently exploit clients by charging healthcare services that otherwise are provided freely (Flasher & Lamboy-Ruiz, 2019). Cognizant of billing violations in the medical facility, related compliance policies were developed, which entails ethical standards of professionals in the billing process and also auditing. However, to ensure that compliance policies are complied with and implemented to the latter, a compliance procedure for billing compliance plan has been developed.
Procedure 1: Compliance officer liaises with diagnosis medical officers to develop codes that will be used coding. It is the medical officers that see patients determine what to charge depending on the service rendered. Therefore, it will be necessary for the compliance officer to connect with healthcare personnel that attends to patients and comes up with codes that will be submitted to the billers.
Procedure 2: Compliance officer shares with billers developed codes. To enhance clarity to the biller, codes that have been developed will be shared by the individuals that bill clients, prepare and submit claims to Medicaid, Medicare, private health care insurance providers and third parties. This will help to ensure billing is systematic and consistent and issues of duplications in the billing are avoided.
Procedure 3: Training on compliance with billing codes. A compliance officer will undertake a training exercise that seeks to educate billing officers on the need to comply with billing codes that have been developed.
Procedure 4: Auditor’s requirement. A compliance officer will outline the requirements of auditors and the job description of auditors recruited by the medical facility. The medical facility is determined to enforce internal control systems to strengthen its billing system and also enhance transparency and fairness of the system. This compels the facility to institute a monitoring system through recruiting internal and external auditors. For internal auditors, the company will recruit individuals with a high code of ethics for auditors, qualified auditors with knowledge of international auditing standards and also, an individual conversant with the billing process in a healthcare setting. Internal auditors will regularly monitor billing systems and establish whether billers are complying with coding systems that have been developed as well as management policies.
For external auditors, the medical facility will recruit auditing firms that have demonstrated a strong stand for audit independence. External auditors will annually audit billing systems and establish whether internal controls are adequate and implemented and two, will help detect whether there are fraudulent activities committed by billers (Younas & Kassim, 2019).
Procedure 5: Legal action will be taken against billers that do not comply with the billing compliance plan. Reports of both internal and external auditors will be evaluated and when malpractices are identified amongst billers, a medical facility under leadership and direction of compliance will determine disciplinary and legal action to be taken against billers that violate the billing compliance plan.
References
Beyamo, A., Dodicho, T., & Facha, W. (2019). Compliance with standard precaution practices and associated factors among health care workers in Dawuro Zone, South West Ethiopia, cross sectional study. BMC health services research, 19(1), 381.
Flasher, R., & Lamboy-Ruiz, M. A. (2019). Impact of enforcement on healthcare billing fraud: Evidence from the USA. Journal of Business Ethics, 1-13.
Sheldon, L. K. (2019). The Importance of PPE Use. AJN The American Journal of Nursing, 119(4), 10.
World Health Organization. (2020). Handwashing an effective tool to prevent COVID-19, other diseases. Retrieved from
https://www.who.int/southeastasia/news/detail/15-10-2020-handwashing-an-effective-tool-to-prevent-covid-19-other-diseases
Younas, M. A., & Kassim, A. A. M. (2019). Essentiality of internal control in Audit process. Int J Bus Appl Soc Sci [Internet], 1-6.
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Module 2 – Statistics and Quality Methods
Jamie Raines
Rasmussen College
H340/HSA3422 Section 01 Regulation and Compliance in Healthcare
Rebecca Mangali
January 12, 2021
Job Description
In human resource management, hiring and recruitment is one of the main functions that is performed by the human resource managers. During the recruitment process, human resource managers are required to develop a job description for vacant positions outlining requirements, duties and roles that would be performed by the applicants that wish to be considered in the recruitment drive. It has been established that staff members have not been observing COVID-19 protocols and also have been charging those applying initial cast twice. Violation of COVID protocols creates a lot of concern because more than 557,000 healthcare workers have been infected with a virus and more than 3,000 have succumbed to the diseases (Lewis, 2020; PAHO, 2020). Full-Circle Medical facility is in the process of recruiting a safety and compliance manager hence develops a job description for the said position that would address compliance violation issues that have been identified.
Vacancy: Safety and Compliance Manager
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Job Type |
3-year contract subject to renewal based on performance |
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Qualification |
Master’s degree in Health Management |
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Location |
New York |
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Department |
Health and Legal Compliance |
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Reference |
234/NYC77/001575 |
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Application Duration |
4/1/2021-31/1/2021 |
Major duties
· Ensure all staff members comply with Covid-19 protocols in the facility.
· Conduct compliance risk assessment training for staff members.
· Regularly update staff members of emerging compliance guidelines.
· Follow up Compliance issues that require investigation.
· Recommend actions the medical facility should take against defiant staff members.
· Assess ethical compliance with billing and general operational standards.
· Follow up charge sheet for patients to ensure outline payment plans are followed.
· Enhance legal medical compliance in the facility.
· Motivate employees to comply with established Covid regulations
Requirements and Skills
· Must have a master’s degree in Health management.
· At least 2 years’ experience in enforcement legislation/guidance.
· Awareness of health and safety issues.
· Good understanding of health billing practices.
· Excellent communication skills.
Compliance Plans
Having a brand new vehicle does not necessarily mean the destination would be reached safely but depends on whether the driver on the steering is qualified. This means the safety of the journey is inseparable from skills, competence and experience possessed by the driver. Practically, organizations spend a substantial amount of time searching for talented employees that have the right skills and competencies (Czarniewski, 2016). In human capital management, knowledge, skills and abilities (KSAs) are optional but rather a priority because the success and innovative nature of an organization depend on its talent management and right human resources (Lawler III & Boudreau, 2012). Ideally, it is factual that the medical facility has been experiencing compliance violations. However, to successfully implement compliance plans, a medical facility requires a good captain that understands the value of compliance, an individual with the necessary skills and experience to steer compliance implementation plan.
Coercive compliance theory which entails threats and punishment has been practiced but has not borne effective results. Similarly, catalytic compliance theory which entails dialogue and suggestion has been applied and has neither delivered optimal results (Weske et al…, 2018). However, a compliance plan with pre-existing motivation for compliance has been identified to be most effective (Weske et al…, 2018). It is based on the approach, a job description for safety and compliance manager states motivation skills, training and expertise on enforcement as key elements which are essential in motivating employees to comply with compliance plans.
With the outbreak of Covid-19, evidence shows that different countries took varying containment measures such as the closure of schools, travel restrictions, gathering restrictions and emphasis on the washing of hands with soap and running water for at least 20 seconds (Chan et al…,2020). Many individuals observed and complied with measures taken some due to extrinsic motivations such as social pressure while others were forced to comply out of intrinsic motivations such as moral and social norms (Chan et al…, 2020). To successfully implement Covid rules and ensure all employees comply with laid down protocol and at same ensure billing system operate as per rates determined by the management, safety and compliance officer is sought with management skills. Further, the applicant should have a high level of integrity to promote an ethical culture in the organization.
In the nutshell, critically evaluating the job description, the medical facility would wish to recruit a safety and compliance manager that would motivate employees to implement compliance plans. The office bearer should have experience and skills to successfully help medical staff members to navigate compliance violations and instead develop in-built compliance culture. Knowledge, skills and abilities outlined in the job description are pivotal to implementing compliance plans.
References
Chan, H. F., Brumpton, M., Macintyre, A., Arapoc, J., Savage, D. A., Skali, A., … & Torgler, B. (2020). How confidence in health care systems affects mobility and compliance during the COVID-19 pandemic. PloS one, 15(10), e0240644.
Czarniewski, S. (2016). Conditions for the Effective Management of Human Capital-The Trends and Mechanisms Of Power In The Organization. European Journal of Research and Reflection in Management Sciences Vol, 4(3).
Lawler III, E. E., & Boudreau, J. W. (2012). TALENT MANAGEMENT-Creating an Effective Human Capital Strategy-Use questions—And findings—From survey research to help gauge your progress on the road to becoming a strategic HR business partner. HR Magazine-Alexandria, 57(8), 57.
Lewis, R. (2020, December 23). Did they have to die? How America’s Covid response left 3,000 health workers dead. Retrieved from https://www.theguardian.com/us-news/2020/dec/23/us-healthcare-workers-died-covid-coronavirus
PAHO. (2020). COVID-19 has infected some 570,000 health workers and killed 2,500 in the Americas, PAHO Director says. Retrieved from
https://www.paho.org/en/news/2-9-2020-covid-19-has-infected-some-570000-health-workers-and-killed-2500-americas-paho
Weske, U., Boselie, P., van Rensen, E., & Schneider, M. (2018). Using regulatory enforcement theory to explain compliance with quality and patient safety regulations: the case of internal audits. BMC health services research, 18(1), 62. https://doi.org/10.1186/s12913-018-2865-8
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Compliance Policies
Name
Course
Professor
Date
Compliance Policies
In the previous project, two compliance plans were developed and a job description developed for safety and compliance manager. However, strength for any compliance programs depends on compliance policy and procedurals which outlines applicable laws, regulations and standards that should be followed to implement developed plans. Compliance policies should be clear and simple to eliminate confusion or difficulties which may be experienced by implementers of compliance plans. Considering there are two compliance plans, to enhance clarity on the developed compliance, each compliance plan would be considered individually constituting two sections for two compliance policies under each compliance plan.
Compliance Plan For Covid protocols
The impact of Covid-19 has been felt in all sectors of economies and health sectors is not exceptional. Even though numerous professionals have been affected by the virus, significant healthcare providers have succumbed to the virus on the line of the duty. According to a study conducted that assess the impact of Covid-19 on the health sector, as of April 2020, countries that reported the significant number of healthcare providers that had succumbed to the virus are Italy with 44%, Iran with 15%, Philippines with 8%, Indonesia with 6%, and China, Spain, U.S each with 4% (Iyengar et al…,2020). Healthcare providers are the first line of defense at high risk of infection because they constantly engage and interact with Covid protocols. Given there is no cure for the virus, hospitals are implementing prevention measures to contain the spread of the virus, protect clients and also its staff. However, it has been noticed that staff members have been violating Covid protocols such as washing hands between patients necessitating the development of a Compliance plan for COVID. In the following two sections, compliance policies for the compliance plan for COVID are outlined.
Section 1: Compliance Standards for COVID Protocols
Healthcare providers should comply with standard precaution practices when treating patients regardless of the nature of diagnosis (Beyamo, Dodicho & Facha, 2019). In the healthcare facility, healthcare workers are at high risk of infection. Covid-19 is an infectious disease which means healthcare workers are at high risk of being exposed to the virus. For example, it is reported that more than 570,000 healthcare personnel had been infected with the virus in America (PAHO, 2020). This underscores need to take standard precaution which constitutes of policies which aimed at reducing the risk of transmitting infection in the healthcare (facility Beyamo et al…, 2019). Standard precautions are not selective to particular diseases because medical personal handles clients with a variety of infections.
To minimize the spread of Covid in the healthcare facility, standard precaution policies entail hand hygiene which requires healthcare providers to wash their hands with soap and water before and after attending to clients, use hand antisepsis and also to apply surgical hand scrub. According to the World Health Organization (2020), hand washing is the most effective way to contain the spread of COVID-19. Therefore, hand hygiene is an integral part of standard precaution that healthcare providers should seek to implement to minimize the spread of the virus.
Protective Personal equipment (PPE) which includes uses of surgical face masks, aprons, goggles and closed boots is another ingredient of standard precaution that should be implemented in the healthcare facility (Beyamo et al…, 2019). To prevent the spread of COVID-19, healthcare providers need to cover key entry points (nose, eye and mouth) which pathways for viral droplets hence the need for healthcare facilities to ensure all healthcare workers have effective PPEs (Hung et al….,2020). Healthcare facilities procure adequate PPEs which are recommended by the ministry of health as one of the standard precaution policies that not only protect healthcare providers but also the patients.
Section 2: Communication Policy on Prevention Information
Communication is a powerful tool which when exhausted, the violation of COVID rules and protocols can be avoided. Lack of information could be the reason for the violation of COVID protocols. Under the communication policy, the safety and compliance manager should provide accurate and timely information on the COVID protocols to the medical staff. Further, safety and compliance officers should deliver the message to the employers on what they need to do to protect their families from contracting the diseases. Communication policy outlines channels of communication to medical staff and visiting clients. A medical facility should seek to ensure it has effective communication systems and structures to pass COVID prevention information.
Billing Compliance Plan
Billing fraudulent cases have been reported severally and control such incidences, Medicaid Fraud Control Unit prosecute healthcare providers that charge people healthcare services that should be provided freely (Flasher & Lamboy-Ruiz, 2019). Auditors need to be furnished latest fraud insights so that when auditing systems and transactions, can easily identify fraudulent billing activities. However, fraudulent billing activities do not only happen in public health facilities but they do happen across the board. This calls for a need for private health care facilities to be extra cautious and institute monitoring programs that can help them detect fraudulent activities.
It is noted that the up coding and misrepresentation of clinical information is rampant with a total value of about $100 billion (Drabiak & Wolfson, 2020). Physicians are using unorthodox methods to make a profit and the amount of money reimbursed in the concerted effort to optimize profit (Drabiak & Wolfson, 2020). This demonstrates the seriousness of fraudulent activities in the health sector which sometimes lead to wrong prescription and treatment to siphon more from the clients.
In the case of the medical facility of our concern, it has been established that medical staff charge clients for application, a cost that already has been paid on the cast. This questions knowledge of the medical staff on the billing system that is applied by the facility whether they have information on the distribution, composition and nature of charges. It is believed that medical staff are not strangers to the billing system and double billing could collusion to fraudulently extort money from the client. It is on this background billing compliance plan has been developed that constitutes two compliance policies outlined in sections three and four as shown below.
Section three: Procedure
The person that undertakes the billing exercise must demonstrate ethical and professional standards. This requires personnel to consistently comply with ethical and professional standards by being honest and fair in charging the clients. Violation of integrity and fairness principles is tantamount to violation of personal responsibility that attracts disciplinary action against the officer.
Medical staff must comply with the billing process and system that has been developed by the healthcare facility. This requires medical staff to familiarize themselves with the billing system, applicable charges for all treatment and treatment procedures, reimbursement programs and inclusive and non-inclusive charges to avoid double charging clients.
Section four: Auditing
The medical facility will recruit an internal auditor that will regularly determine compliance of billing officers with a legal requirement. Further, the internal auditor will monitor transactions in the medical facility to ascertain adherence to the billing compliance plan.
Annually, the medical facility will recruit an external auditor to carry out control and substantive test. The control test establishes whether the facility has enhanced a strong internal control system (Mahaluça et al…, 2019). On the other hand, substantive test checks the accuracy of transactions and whether there is a material error in the financial statement (Mahaluça et al…, 2019). Auditing is an important policy in billing compliance plan for monitoring purposes.
References
Beyamo, A., Dodicho, T., & Facha, W. (2019). Compliance with standard precaution practices and associated factors among health care workers in Dawuro Zone, South West Ethiopia, cross sectional study. BMC health services research, 19(1), 381.
CDC. (2020). COVID-19 Communication Plan for Select Non-healthcare Critical Infrastructure Employers. Retrieved from
https://www.cdc.gov/coronavirus/2019-ncov/community/communication-plan.html
Drabiak, K., & Wolfson, J. (2020). What Should Health Care Organizations Do to Reduce Billing Fraud and Abuse?. AMA Journal of Ethics, 22(3), 221-231.
Flasher, R., & Lamboy-Ruiz, M. A. (2019). Impact of enforcement on healthcare billing fraud: Evidence from the USA. Journal of Business Ethics, 1-13.
Hung, O., Lehmann, C., Coonan, T., Murphy, M., & Stewart, R. (2020). Personal protective equipment during the COVID-19 pandemic (Letter #2). Canadian journal of anaesthesia = Journal canadien d’anesthesie, 67(11), 1649–1650.
https://doi.org/10.1007/s12630-020-01785-3
Iyengar, K. P., Ish, P., Upadhyaya, G. K., Malhotra, N., Vaishya, R., & Jain, V. K. (2020). COVID-19 and mortality in doctors. Diabetes & metabolic syndrome, 14(6), 1743–1746.
https://doi.org/10.1016/j.dsx.2020.09.003
Mahaluça, F., Chissengue, G., Uamba, J., Pereira, I., Mabjaia, E., & Vilanculos, A. (2019). Importance of Applying Statistical Sampling to Increase Confidence in Financial Statements. Int J Account Res, 7(198), 2.
World Health Organization. (2020). Handwashing an effective tool to prevent COVID-19, other diseases. Retrieved from
https://www.who.int/southeastasia/news/detail/15-10-2020-handwashing-an-effective-tool-to-prevent-covid-19-other-diseases
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Monitoring Tools for Compliance Plans
Name
Course
Professor
Date
Background to the project
Originally, it was established that the medical facility was violating compliance policies that have been established by the management on the account of two areas. In the first case, it was established that medical staff does not wash hands between patients as is recommended by the medical facility. This is extremely considering the prevailing health situation in the country. In April 2020, approximately 0.9 million citizens had been infected with COVID and more than 52,000 Americans had succumbed to the virus (Tam, Walker & Moreno, 2020). The situation is dire with new cases continuing to be reported in the country putting more risk to healthcare personnel that constantly interact with COVID patients. Hand washing and social distancing have been recommended as the most effective ways to contain the spread of COVID. However, it is challenging and threatening when medical personnel fails to wash hands not only to prevent the spread of COVID but rather it is standard precaution measures to prevent transmission of infectious diseases (CDC, 2018). It is the background of this COVID compliance plan has been developed, related compliance policies and also compliance procedure and in this project, monitoring tools for this compliance will be developed.
Similarly, health facilities identified cases where medical staff charged clients twice. This is not allowed and replicates to fraudulent billing practices which if not tamed, can ruin the reputation of the facility. Complicated coding and prone to errors billing systems are some reasons given for the rise of rampant billing frauds in medical facilities. However, in some cases: patients are overcharged, charges are made for services not rendered and in other cases, doctors charge for wrong services fatten their pocket tell reasons for growing fraudulent billing practices (Bothwell, 2018). To curtail facility rising to billing scandals, a billing compliance plan was created, compliance policies and procedures and in this project, monitoring tools are developed.
Monitoring Tools for COVID Compliance Plan
The impact of COVID cannot be underestimated. It brought the global economy to a standstill and hardly hit the healthcare system. The United States is not exceptional but remains one of the most hard-hit economies with the highest number of confirmed cases. In the U.S, according to available data released by CDC, for reported cases from February to June in 2020, 571,708 (22% of total cases) healthcare personnel had been infected with the virus (Hughes, M2020). Access to PPE, face mask, social distancing and hand hygiene to HCP and those attended remain critical elements to protecting healthcare workers (Hughes, 2020). Surprisingly, even with glaring statistics on the serious impact of COVID amid other infections, medical staff fail to practice hand hygiene between patients advised.
COVID compliance plan has been developed that seek to address observed violation for hand washing practices by the medical staff. On the same effect, two compliance policies were developed which are standard precaution practice and communication policy on prevention. To ensure compliance policies are executed accordingly by the medical, a compliance procedure was developed which comprises of five steps. However, as though these efforts are not adequate, two monitoring tools are developed which seek to determine the efficiency of the compliance plan, the progress that has been and also helps identify areas that need improvement. Ideally, monitoring tools track compliance of medical staff to COVID compliance plan.
Monitoring tool 1: Infection Prevention and Control Assessment Framework (IPCAF)
This is a standard monitoring tool developed by WHO to assess the implementation of protocols and guidelines in the acute care facility (WHO, n.d). However, even though this tool was developed by WHO, it is a relevant tool that can be used to monitor COVID compliance plan.
IPCAF will monitor the COVID compliance plan in four aspects. In the first case, it will assess infection prevention control in the medical facility (WHO, n.d). Data that is generated on the rate of infection in the medical facility will be used by the compliance officer to track and assess compliance COVID compliance plan. For example, when infections number in the medical facility are on the rise, it would be an indicator that COVID compliance policies and procedures are not complied with by the medical staff. However, this will require investigation to establish the reliability of such assumptions.
On the second aspect, IPCAF will be used to identify relevant shortcomings that need improvement in the COVID compliance plan (WHO, n.d). This shows that IPCAF is powerful which not only monitors and also seeks to detect possible problems in the compliance plan which require adjustment to make it stronger and increase compliance to the plan.
On the third aspect, IPCAF will help check areas that meet international standards and requirements (WHO, n.d). For example, IPCAF will determine whether PPEs that are made available to medical staff are adequate and are of recommended quality. Further, will seek to determine whether medical staff and all people served by the medical are furnished with quality and updated information on prevention and containment as released by the ministry of health, CDC, WHO and other relevant bodies on infectious control.
In aspect four, IPCAF gives a score that helps to determine the progress that has been made on the compliance journey to the policies and procedure. This is essential because the course of action is generated from the results. It is the score that is generated which helps the medical facility to determine actions that need to take to improve compliance with the COVID compliance plan.
Monitoring tool 2: Compliance Officer
The medical facility will use the office of the compliance officer to monitor compliance to the COVID compliance tool. A compliance officer is competent, versatile and well informed with all details of a Compliance plan, policies and procedure therein as well as the expected outcome. Regularly, compliance will be required to track actions of medical staff and management to establish whether responsibilities assigned to each individual are implemented. For example, management should buy PPEs and medical devices required to enforce standard practices. The compliance officer assesses whether management has its bit and whether the medical staff is putting PPEs and maintain hand hygiene. Therefore, the compliance officer is a critical component in the monitoring process and recommendation of legal action to those found non-compliant to plan.
Monitoring Tools for Billing Compliance Plan
Fraudulent billing cases are rampant. The facility would want to maintain integrity stand by having a clean and ethical billing system. Lately, the facility has identified that billing officers are engaging in unethical malpractices by billing clients twice in some cases. This is unacceptable to the facility and it is putting all measures in place to avoid its billing system becoming an avenue for criminal enterprise. Because of this development, the facility has developed a billing compliance plan. Two compliance policies have been developed-procedure emphasizes the ethical and professional conduct of billing officers and second- auditing to the billing system. Further, a compliance procedure has been developed which detail five steps followed to implement compliance policies. To effectively ensure billing compliance plan is implemented and desired results attained, four monitoring tools adopted from Strategic Management Services, LLC (2018) are suggested.
Tool 1: Risk assessment and evaluation
This tool helps to detect tools that exist in the billing compliance plan. Some of the risks could be billers that lack integrity, a billing system that is easily manipulated and cases where billers develop codes and at the same bill clients. Therefore, risk assessment and evaluation will significantly help to identify vulnerabilities in billing compliance which would prompt action taking approach.
Tool 2: Compliance work plans.
This is a tool that provides a roadmap on how auditing to the billing compliance plan is to be conducted. It equips the auditing firm with necessary information on what to look for when auditing the billing compliance plan, history of malpractices to the billers and emerging malpractices that need to be considered.
Tool 3: Sampling protocols
This is a tool that would be used to establish variations on the monitoring that is taking place. It is a critical monitoring tool because variations identified form the basis for a possible problem in the billing system.
Tool 4: Computer-assisted Audit Techniques
A compliance officer will use this tool to get an in-depth analysis of the billing system, transaction and internal controls. This helps the compliance officer to determine whether billing officers comply with billing compliance policies and procedures, determine the efficiency of the billing compliance plan and areas that need improvement.
References
Bothwell, M. (2018, October 9). Why Medicare Billing Fraud Cases Are Running Rampant and What You Can Do About It. Retrieved from
CDC. (2018, June 18). Standard Precautions. Retrieved from
https://www.cdc.gov/oralhealth/infectioncontrol/summary-infection-prevention-practices/standard-precautions.html
Hughes, M. M. (2020). Update: characteristics of health care personnel with COVID-19—United States, February 12–July 16, 2020. MMWR. Morbidity and mortality weekly report, 69.
Strategic Management Services, LLC. (2018). Health Care Auditing and Monitoring Tools for an Effective Compliance Program. Retrieved from https://www.compliance.com/resources/health-care-auditing-and-monitoring-tools-for-an-effective-compliance-program/
Tam, K. M., Walker, N., & Moreno, J. (2020). Effect of mitigation measures on the spreading of COVID-19 in hard-hit states in the US. Plos one, 15(11), e0240877.
WHO. (n.d). Infection Prevention and Control Assessment Framework at the Facility Level. Retrieved from https://www.who.int/infection-prevention/tools/core-components/IPCAF-facility.PDF?ua=1
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Monitoring tool procedure for: Infection Prevention and Control Assessment Framework (IPCAF)
Infection prevention and control assessment framework is one of the monitoring tools which has been developed to be used for the COVID compliance plan. Having a monitoring tool is one thing and using it appropriately is another thing. To make better use of IPCAF, the following procedure will be used:
1. Compliance officer responds to questions on three aspects. On the first aspect, the compliance officer will assess the infection rate at the facility. An increase in the infection will require the compliance officer to evaluate whether medical staff complies with the COVID compliance plan. On the second aspect, a compliance officer will assess the rate of compliance to standard precaution practices. On this part, compliance will respond to numerous question which pertains accessibility and availability of PPEs, hand hygiene skills to medical staff and its implementation and correct use of face masks and gloves by the medical staff. On the third aspect, the compliance officer will respond to questions that evaluate the effectiveness of communication on prevention and control to COVID 19.
2. Compliance officer determine shortcomings to COVID compliance plan based response to three aspects in step 1. Shortcomings help compliance officer establish actions which should be taken to improve compliance to plan.
3. Compliance officer communicate to medical staff on the findings of compliance score, improvements to the plan and disciplinary actions to those that fail to comply with compliance. This ensures that the monitoring tool achieves desired outcome because after assessment and detection of shortcomings, the action is taken to improve compliance to plan.