Accreditation documentation requirements for the human resource files are relatively straightforward, yet the human resource (“HR”) standards continue to be some of the most frequently cited standards and generate the most questions from DME customers. HQAA’s recent standards revisions and updates included several of the HR standards. This fact, along with the continued questions and citations for HR standards suggest it was time to revisit the personnel file and review expectations.
In our January 2022 blog, we talked about fraud, waste, and abuse and touched on compliance programs. The article prompted questions and comments from quite a few organizations and questions of late suggest it might be a good time to do a deeper dive on compliance programs.
Compliance “programs” are sets of policies & procedures specifically designed to help an organization adhere to law and regulation. These policies and procedures are specifically set up to detect, prevent, and correct fraud, waste, and abuse. Medicare requires any provider to have such a program and they have very specific content they want these policies to contain.
Harry Truman, the 33rd President of the United States had a famous slogan, which appeared on a plaque on his desk: “The Buck Stops Here”. Referring to “passing the buck”; that is, shifting blame or responsibility, the saying demonstrates a person’s willingness and ability to take responsibility, find solutions, and lead by example.
A dictionary defines disclosure as “the action of making new information known or the action or process of revealing information.” In the medical world, healthcare providers define disclosure as “a release of information to persons or entities other than the patient who is the subject of the information.”
You could write a book about “employee vs. contractor” pros, cons, legality, and operational efficiency. In fact, there are books written about that very subject. There are also lawyers who specialize in employment law who advise companies about how to structure their staffing around those two broad categories of staff. While accreditation organizations won’t delve into the legalities (that’s for the lawyers to do), accreditation standards DO in fact address both categories of staffing.
Topics: Employee Training, Personnel Files, HQAA Accreditation, Clinical Practice Guidelines, Quality Care, Retail, Delivery, Clinical Respiratory Services, Competence, Customer Service, Business Practices, Surveys, Equipment
Those of us who have been in the DME industry for enough years remember when every DME organization in the country had a storage room full of vertical files and/or bank boxes full of old patient records. The boxes were stored in piles, often piled up to the ceiling. Usually there were labels or writing on the boxes—something like “April 1987-January 1988” or “1990—A-L”. The boxes and filing cabinets were full of manila and Pend-a-flex folders labeled with patient names and chock full of medical records, billing information, social security numbers, dates of birth, and enough demographic information to make a telemarketer’s day.
The pandemic has changed how we look at employment in the United States in a multitude of ways. Many of us now “telecommute” to work, which opens up the opportunity to live farther from the office than ever before. Young people have new and different considerations and priorities when it comes to accepting a job. And of course, there’s the fact that it is increasingly more difficult to recruit and retain good long-term employees. Complicating these issues specifically in our industry are the pesky and sometimes misunderstood background check requirements.
Nothing strikes fear into the hearts of DME owners, managers, and staff more than the Office of the Inspector General (the “OIG”). The fear is perhaps deserved by an extremely small handful of industry people. The vast majority of our industry rank and file have nothing to fear from this sometimes maligned and misunderstood government agency.
Many durable medical equipment company employees equate “OSHA” with those plasticized posters typically hung in a breakroom or kitchen in the organization. Training requirements by both accreditation standards and OSHA itself have gone a long way to educating employees about the various OSHA mandated requirements and led to a better understanding of OSHA. This in turn has led to better adherence to the rules and regulations and ultimately to a safer workplace.
Imagine how hard it would be to adequately assess whether a person could do some specific task (such as teach school, perform surgery, re-wire a house’s electrical system, or build a bridge) without actually observing them doing that task. We hire employees based on applications and resumes, we evaluate their performance in a job by checking their attendance record to insure they show up to work on time, and we monitor a delivery person’s driver’s license or a clinician’s clinical license to make sure they haven’t expired or been revoked. But no tool works as well to assess a person’s ability to do their job as well as actually watching them do their job. Competency assessments are an integral part of the evaluative process and some would say, THE most important part of that process. If you are hiring a marksman for their ability to hit a target, at some point, you’re going to go out into the field and say “Show me what you’ve got!”