HELP WHERE HOSPITALS NEED IT ®
HELP WHERE HOSPITALS NEED IT ®
Community Hospital Blog
By Doug Kent, CHC VP Internal Audit/Compliance Officer
As healthcare becomes more complex, there is also more emphasis being placed on financial considerations, and on preventing and detecting violations of state and federal healthcare laws. What can your hospital do? Start by creating a compliance program to self-police your hospital and staff activities.
Since its inception in 1976, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) has led the charge to fight waste, fraud, and abuse in Medicare, Medicaid, and more than 100 other HHS programs. In 2010, as part of the Affordable Care Act, OIG mandated that all healthcare providers have a Corporate Compliance Program in place as a condition of enrollment for Medicare, Medicaid, and Children’s Health Insurance reimbursement.
Along with assuring that needed dollars go to patient care, compliance programs serve to engage and inform employees and community members that your hospital is committed to “doing the right thing.” It’s also key to have compliance policies in place should you ever face regulatory review or inquiry.
Here are some best practice recommendations to develop or enhance your hospital compliance program.
1. Assemble a compliance committee representing a cross-section of employees. Compliance “belongs” to everyone. It’s a team effort and extends beyond the role of the designated compliance manager or leader. C-suite members, case management, revenue cycle, IT/security, and other employee representatives should serve on your compliance committee. Establish a group charter, meet at least quarterly, and ensure confidentiality of information shared with this group.
2. Develop a robust education and training program. Provide compliance education/information as part of new employee orientation. Offer online education courses to meet yearly training requirements on topics including billing and collections, Medicare rules, HIPAA, compliance issues, EMTALA, and conflicts of interest.
3. Establish a compliance hotline. Make sure employees know the hotline is an anonymous reporting system assuring the confidentiality and protection of individuals who may come forward; communicate the purpose of this hotline (it’s not an employee “complaint” line).
4. Include sanction screenings in your compliance plan. The hospital is required to check state and federal exclusion lists monthly to identify if employees, contractors or third-party vendors have had adverse actions taken against them by federally funded programs. Screenings demonstrate you have a routine process in place to monitor potential compliance issues.
5. Define and document conflicts of interest. To protect patients’ well-being and ensure public trust, board and management team members should sign a conflict of interest statement as part of the compliance plan. Keep these documents on file.
6. Manage compliance risk issues through ongoing monitoring and auditing. Make sure your compliance work plan includes a continuous control process to keep current on changes in rules, regulations and laws. Your work plan should outline internal controls to comply with these guidelines. For auditing, the approach is more proactive. Steps could incorporate chart review to examine how codes are being used and applied, or charge tracking for certain procedures or supplies.
7. Measuring compliance programs. It’s important to measure the effectiveness of your existing hospital compliance program. Authorities recommend that you conduct an internal evaluation yearly to assess your program’s effectiveness, and an external audit every other year with a report back to you that outlines program improvements.
For additional compliance education materials see the OIG Compliance 101 resources.
by Dave Koford, CHC VP Health Plan Contracting
For hospitals, “care” typically refers to providing patient care. Yet a hospital’s financial health requires care and attention, too.
A sound financial strategy supports the provision of patient care and services communities need, and a significant component of healthcare organizations’ revenue frequently comes from health plan contracts.
So what do your health plan contracts look like? Have you reviewed them recently? Are there opportunities to modify those arrangements to maximize your reimbursement?
Here are some best practice tips for health plan contracting.
Review your health plan contracts regularly – at least every year. Place this task at the top of your to-do list to help prevent future revenue loss.
Request full access to Policy and Procedure Manuals for each of your contracted health plans – before you “sign off” on those contracts. Your signature reflects your agreement with the current policy and procedure manual, but plans can (and do) change their policies. You’ll want to stay abreast of changes to make contract adjustments when necessary.
Know the health plan options offered by the largest employers in your community. In addition to the hospital, sizeable employers in a service area often include the school district and the city. Have these employers changed their health plans recently? For instance, has the local school district switched from a lower-paying plan option available to employees to one offering more favorable compensation or the reverse? Monitor these activities and changes. Keep information up to date.
Analyze reimbursement rates by payer. Are you receiving the appropriate compensation for the care you provide? Here are some factors to consider.
How does reimbursement for your commercial health plans compare to Medicare rates? Comparing one health plan’s reimbursement to another’s makes good sense. However, all health plan rates should be measured against Medicare. Plans with rates below Medicare could compromise the hospital’s financial health.
Unearth internal claims data. Review claims history before negotiating with an existing payer. Study how much revenue the payer brings to your hospital by service line. This reimbursement data could significantly influence the negotiation process since patient care and service lines are always changing.
Evaluate fixed rates and patient deductibles in rate negotiation to maximize revenue reimbursement. Hospital compensation under many health plan contracts features a fixed rate. Although this provides a level of predictability for the payer, fixed rates aren’t always the hospital’s best reimbursement option (and at a minimum, fixed rates should be adjusted up each year due to inflation, supply costs, etc.).
Also, for high-deductible health plans (HDHP), consider how easy will it be for a hospital to collect patient charges before a patient’s deductible has been met? HDHPs benefit the employer and the health plan, not necessarily the hospital.
Assess your payer-provider relationships. Look beyond the rates.
Establish or nurture long-term payer-provider partnerships, particularly when health plan payers represent a significant portion of your revenue. Are there new product offerings or risk-sharing models? Enhance positive working relationships to facilitate communication and negotiation.
What’s the revenue cycle telling you? Evaluate the processes associated with claims processing, payment and revenue generation. Are there opportunities for improvement to more effectively support the billing and collection efforts? (See a related CHC blog post for more on this topic.)
Keep up with health insurance changes for consumers covered through the Affordable Care Act (ACA). Many health plans have left the ACA marketplace and others are raising premiums and narrowing provider networks. What percent of patients do you see through the ACA? What impact do their high deductibles have on your collections? Under the new U.S. Administration, it is unclear how changes to the ACA or proposed health reform would impact care delivery – so staying abreast of what’s known will help your hospital going forward.
Learn more about the CHC Health plan evaluation process to review health plan relationships resulting in improved contract terms and reimbursements.
by Jim Coleman, CHC SVP of Southeast Hospital Operations
Rural and community hospital leaders – at the forefront in meeting community healthcare needs – frequently encounter challenges that may significantly impact operations and an organization’s long-term financial viability. From variations in patient mix to marketplace mergers and legislative reform, the environment continues to change.
To better position your facility for success, here are some best practice tips to strengthen access to care and delivery of services. Market customization, operational performance, and collaboration opportunities should be at the top of the list.
Customize your hospital’s action plan to your market
Use market demographics and payer mix data to think “outside the box” – every community is different. What works for one hospital may not be right for another. Adopt a strategic approach to evaluating new services and programs. Here are a few specific ideas that have worked for several CHC Consulting clients:
Plan for the future
Annual strategic planning is vital to long-term success. The process should include an environmental assessment reviewing marketplace health needs along with medical staff planning. Proactive retention, succession planning and recruitment efforts are especially important in smaller markets where it can take longer to fill vacant positions.
Improve operational performance
Labor is the largest portion of a hospital’s budget. This means it’s critical to closely monitor and manage labor. Analyze staffing and match your workforce to the services needed; research scheduling options and cross-training opportunities to capitalize on efficiency. Could nurse practitioners, physician extenders or others benefit the hospital or community? In addition to labor, supply costs are one of the fastest-growing hospital cost centers. Carefully review your facility’s potential for savings on supplies and pharmaceuticals through a group purchasing organization (GPO) that specializes in community hospitals. Also, look closely at your revenue cycle for opportunities to improve revenue capture and collections.
Team up with area providers and agencies to meet community needs
Collaborative efforts including clinical affiliations with other hospitals or systems can improve population health management and care delivery. For instance, an affiliation agreement could bring a needed physician specialist to your community, a reasonable alternative to recruiting and supporting a medical practitioner on a full-time basis.
Government support can also improve access to community-based health care to broaden the services you provide. State and federal grant dollars support clinical and preventive services such as mammograms; funding is available for telemedicine services and health information technology as well.
By Mike Williams, President and CEO, CHC
As we usher in 2017 with our country’s new administration, it’s not surprising that hospitals, healthcare providers, insurers, and consumers alike are asking “what’s next?” related to healthcare. There’s no question that some changes will occur, although they won’t happen overnight. Many details are forthcoming in the weeks and months ahead.
Regardless of the road in front of us, we must continue to position community and rural hospitals in optimal fashion. CHC will be looking at innovative ways to help community hospitals during these times of change, by lending our expertise, and upholding our mission to guide, support and enhance the mission of community hospitals and healthcare providers.
Strong community hospitals are critical to the vitality of entire populations, especially in rural environments, because they support both the health and economy of the communities they serve. Here are some top-line recommendations to stay the course for continued success, even with impending healthcare reform changes on the horizon:
Even with health care changes ahead, I’m confident community hospitals can persevere by focusing on and optimizing their strength and position as we welcome the New Year.
Learn more about strategies for success moving ahead in 2017.
by Karen Barber, CEO, Yoakum Community Hospital
Leveraging Resources for Change
When I joined the Yoakum Community Hospital team in 2006, one of the biggest hurdles I faced was improving board-management relationships. I realized that addressing this challenge would be essential to paving the way for a better, more secure financial and operational future for the hospital and community. Elorine Sitka, Yoakum Board Trustee and Chair, shared this vision, and together, we turned ideas into reality.
As a 25-bed critical access hospital in rural Yoakum, Texas, it became apparent that trustees had not been receiving all the information they needed — in a timely way — to make well-informed decisions. We realized that trustees were challenged in performing their basic fiduciary and financial duties, and change was necessary to inspire and create a high-performing board dedicated to the hospital’s success.
As partners, our goal was to improve the hospital for the good of the community. We developed recommendations on ways to improve board relations and engagement – laying a solid benchmark for success for many rural hospitals.
Five Steps to Success
Certain basics are “must-haves” for continuous improvement in board-management relationships, including:
1. Clarify expectations regarding roles and responsibilities
Governance and management are distinct functions. At Yoakum today, board members view their role as strategists and overseers. They leave management and operations to hospital leaders and managers, although that wasn’t the case previously. Board members provide direction. Managers create and implement tactics to support board strategies. One significant consideration is to provide board members with updates to keep them in the loop.
Identifying specific responsibilities in written form can also help prevent confusion related to roles. Discussions about mutual expectations are important, too. What do trustees expect of the CEO? What types of things can a CEO do without prior board approval?
2. Foster open, consistent communications
Regular, informal phone calls and a weekly newsletter are great tools to keep board members informed. An online portal provides members with meeting materials to review at least a week in advance. Trustees are encouraged to reach out to leaders if they have a question or concern, as well as participate in meeting discussions and respectful debates.
3. Make meetings purposeful
Make board meetings organized and action-oriented. Take informational items off the agenda for trustees to read on their own. Focus face-to-face time on several major issues that require voting at board meeting time.
I strongly suggest that everyone “stick to the agenda.” The entire team is busy, so keep meetings short and on point. And set aside time to socialize. Sharing a meal together before getting down to business inspires fellowship and teamwork.
4. Create resourceful onboarding and continuing education
New trustee orientation is vital and should include meetings with key stakeholders, including the CEO and CFO, as well as important partner organizations. A tour of the hospital and distribution of educational materials including an organizational chart and a glossary of healthcare industry terms and acronyms are part of the process.
5. Identify potential trustees
A specific recruitment process for new trustees is key. At Yoakum, we maintain a running list of potential board members, keeping in mind leaders and colleagues with diverse backgrounds. Another consideration is to identify potential board members without any sort of personal agenda. The focus should be on improving the hospital for community health.
We also encourage board members to listen to presentations offered by hospital staff, and take advantage of state and other sponsored trustee education programs. At Yoakum, we also invest in an annual board retreat and involve trustees in monthly birthday celebrations and other hospital events.
Building on Success
Looking back, the difference at our board meetings today is obvious. Today we have a strong board and dependable, trustworthy leadership committed to a common purpose.
To learn how Yoakum Community Hospital developed a high-performing board, read this CHC case study.
CHC | 7800 N. Dallas Parkway, Suite 200, Plano, TX 75024 | 972.943.6400Copyright © 2017 Community Hospital Corporation