PROGRAM OVERVIEW

Have you ever wondered how your freestanding dialysis facility compares to the large dialysis chains (your competitor) in terms of business operations? Where is your profit coming from? Are your margins in jeopardy due to managed care companies discounting your fee schedules? Let HDS provide a program overview to identify areas where improvement will help your financial or clinical outcomes.

COMPLIANCE AUDIT PROGRAM

Overview

The Office of Inspector General (OIG) of the Department of Health and Human Services (HHS) continues in its efforts to promote voluntarily developed and implemented compliance programs for the health care industry. Standards have been developed or accepted by the federal government to promote performance levels necessary to insure patient safety in the outpatient dialysis facility. Compliance with these standards is necessary to receive and maintain Medicare certification and subsequently Medicare reimbursement.

As the National Renal Administrators Association (NRAA) notes in its manual titled " NRAA Compliance Program Guidelines for ESRD Facilities", tools such as this must be tailored to meet the needs of the entity for which it is intended. The NRAA guidelines focus is one of finances and billing. Keeping these guidelines in mind Healthcare Design Specialists (HDS) has created a compliance audit program (CAP) with an operational orientation. The goal of CAP is to assist dialysis facilities in developing effective internal controls that promote adherence to applicable Federal and State law. This tool can be integrated into the existing facility compliance program process and procedures or it can be the basis upon which the facility compliance program is built.

The implementation of a compliance program requires strong and vocal support from the leadership of the facility. The introduction of the program within the facility requires clear and timely communication to the staff and patients. The benefits of the program should be clearly stated and noted as a process not an event.

Benefits of a Compliance Audit

The compliance audit modules are designed to be used by either the dialysis facility to perform an internal audit or to be used by an external resource. These audits provide a baseline for the purpose of identifying areas of weakness or Medicare noncompliance and support the CQI process. Subsequent issues of efficiency, economy and quality will arise from the results of the compliance audit. Identification of these issues will lead to recommendations ® ® implementation ® ® ongoing monitoring. As always the goal of ESRD should be quality, cost effective, ethical care to the clients served.

Development of a Compliance Program

HDS supports the model for development of a compliance program outlined by the NRAA in its guidelines. Those seven elements are:

• Development and distribution of written compliance policies and procedures;
• Designation of a compliance officer or compliance committee
• Education and training of employees
• Implementation of a process to receive complaints or reports of potentially noncompliance conduct
• Consistently enforced disciplinary policies
• Use of audits and monitoring functions to ensure ongoing compliance
• Investigation and corrective action protocols to handle instances of noncompliance

The focus of CAP is in the area of number six, Use of audits and monitoring functions to ensure ongoing compliance.

Compliance Modules:

Clinical practice		Patient care policies		Billing/Finance
Reprocessing Equipment CQI Operational /integrated practices		Water treatment Personnel Universal precautions/OSHA		Environment/Physical Surroundings Medical Records Purchase Inventory