When we hear the words "risk management," we mostly think of the process that involves the identification, analysis or mitigation of legal implications as they relate to business and operational procedures. In healthcare, risk management can involve anything from reducing injury to patients or staff members to safeguarding against government intervention, claims and other regulatory and compliance actions.
Risk management is a major challenge for many healthcare organizations. And in the coming months, risk management capacities will become more demanding. From discussion and speculation regarding the repeal of the Affordable Care Act to Trump's plan for healthcare price transparency, risk management is sure to become an increasing priority for providers moving forward into 2017.
As organizations grapple with how to efficiently delivery care and contend with changing healthcare regulations, one often overlooked solution is staffing and working with your HR Department. When you incorporate risk management into an organization's HR function, you have a surefire way to mitigate healthcare risks. After all, an organization is only as solid as the staff it employs.
How to Work with HR to Mitigate Healthcare Risks
We are all familiar with the never ending myriad of compliance investigations making news lately. One Florida incident involving negligent staff members was especially troubling. Staff members in a Florida VA hospital left a patient's body lying in a shower room for nearly 10 hours. According to the report, the patient died after receiving hospice care, after which staff members moved the corpse to the shower room. An internal review revealed staff members falsely documented the incident, failed to properly report the death, and blamed the mistake on miscommunication.
Even with thorough risk management, mistakes and lapse in judgment happen. Days before the incident at the Florida VA hospital, the facility received a Cornerstone Recognition Award from the VA National Center for Patient Safety. Clearly, risk is unavoidable, but it should never be left to chance.
There are many steps an organization can take to reduce risk. HR can help support this effort and here's how.
Develop Written Policies and Procedures
Reducing risk is a combined effort between your clinical team, Compliance Department and HR. Defining clear policies and procedures, in addition to making staff aware of the repercussions that come with a policy breach is very important. Just as staff members are accountable to their supervisors, businesses are accountable for the actions of the organization—answering to federal, state and local laws. Ensuring that policies and procedures are consistently enforced across the board and that everyone remains aware of them is what holds the team together. It's an important step towards compliance and managing risk, which is no longer just a cost-center for organizations, but a value center. Former US Deputy Attorney General Paul McNulty said, "If you think compliance is expensive, try non-compliance."
Establish a Compliance Department
If your organization does not already have a Compliance Department or compliance team, designate one. This department works in tandem with HR and typically includes representatives from multiple departments who enforce compliance, review policies, coordinate yearly trainings and education on how to handle sensitive situations, and ensures systems are in place to protect against HIPAA violations. The Compliance Department also fields employee and customer complaints.
When it comes to developing policies, specifically those related to compliance and business operations, it's the responsibility of the Compliance Department to make sure the policies are up to date and in line with current regulations. This team is further tasked with developing compliance work plans for the organization and its departments. Components of a compliance work plan typically include an awareness survey, effectiveness evaluation, risk assessment, and strategy and operational alignment.
Implement Internal Monitoring, Auditing and Due Diligence
As healthcare providers, government scrutiny is unavoidable. Claims, litigation, monetary paybacks, and license suspensions are risks associated with providing care. No one likes to hear the word "audit." It carries a negative connotation and duly so. To stay out of the spotlight or at the very least, have a fighting chance if your organization happens to become the target of an external audit, it's important to implement internal processes for monitoring and due diligence. Rely on HR to help support these functions. Your Human Resources Department should maintain current financial records, personnel files, information on background checks, as well as copies of staff and customer complaints. HR facilitates internal monitoring, auditing and due diligence by being the central access point for all records related to business practices and operations.
The internal auditing process includes: reviewing personnel and patient files for errors or omissions, checking facility accreditation status and expiration, verification of financial statements, and ensuring compliance with training and education standards. Keeping good records should be a part of every organization's due-diligence measures. Verifying documentation and records are up to date through internal monitoring processes mitigates risk in the event of an external audit.
Compose a Prompt Response and Corrective Measures
So what happens if an organization becomes the target of an investigation? HR is typically the point of contact, receiving a letter of claim or indictment from a federal, state or local agency regarding a breach or compliance concern. It's important to work with your HR and Compliance Department, to determine the most effective way to respond. Immediate action is imperative and a corrective plan of action must be put in place to avoid future incidents. A prompt response shows accountability for the incident that has taken place. Coordinate with HR to notify all involved parties—staff and customers affected by the breach. Hold a meeting to discuss the issue and determine a corrective plan of action. Immediately draft a response to the letter of claim, including your findings and how your organization can assure the incidents doesn't happen again.
For more information on how your organization can mitigate risks, or to develop and implement a plan for cross-departmental support in the event of government intervention, contact the experts at LW Consulting, Inc.