Bogged Down by the Unrelenting Complexities of Compliance?
Have you ever had a day, week, month, or year where you feel overwhelmed by the complexities of compliance? Many compliance professionals are meticulous, conscientious people by nature, and their tendency to consider all the nuances of compliance issues can become overpowering.
When this happens, it might be helpful to step away from the complexity of the moment and go back to the basics. Doing so might not make the issues less complex, but it might provide some calm clarity that can lead to workable solutions. Leonardo da Vinci is attributed with saying, “simplicity is the ultimate sophistication” and Albert Einstein reportedly said, “genius is making complex ideas simple, not making simple ideas complex.” Simplifying your approach can be the beginning of finding a very sophisticated answer. Some of the most basic principles to remember are values that most of us have been taught since childhood.
For example, Augustine of Hippo is reported to have said, “the truth is like a lion; you don’t have to defend it. Let it loose; it will defend itself.” Sometimes compliance is as ‘simple’ as calling a spade a spade. That might be easier said than done, but if a compliance professional can be a truth-speaker without giving offense, half the battle might be over. Because once the truth is shown, it will likely defend itself. In other words, unless someone is deliberately trying to break the law, hide their action and get away with it, shedding light on the facts will often begin the process of resolving the problem. If you work in an organization that is willing to see and accept the truth, then speaking the truth is often the start of a resolution. And if you don’t work in an organization that is willing to accept truth, wouldn’t you like to know that sooner rather than later?
John C. Maxwell is credited with saying, “transparency breeds legitimacy.” When it comes to compliance, be transparent with what you are trying to accomplish. Transparency often leads to respect and trust. Transparency in processes outside of compliance might also be an answer to concerns about specific risks. For example, assume a large hospital system has a revenue cycle department that is responsible for capturing charges, accurately submitting claims and monitoring reimbursement. Perhaps the compliance department wants to ensure these activities are being performed in a compliant manner but they don’t have the resources to audit every single claim. If the revenue cycle department can agree to regularly reporting analytics regarding charges, claims and reimbursement in a transparent manner, perhaps those involved in these processes will seek for accuracy and improvement. And on the other hand, if a department would rather not be transparent, that might be a reason to ask more questions.
Trust is an important principle in healthcare. The HHS OIG (Office of Inspector General) shared the following about trust in the patient-physician relationship: “Trust is at the core of the physician-patient relationship.” They then expand that concept of trust to compliance when they say, “The Federal Government also places enormous trust in physicians...When reimbursing physicians and hospitals for services provided to program beneficiaries, the Federal Government relies on physicians to submit accurate and truthful claims information." Recall, most claims are submitted and reimbursed on a system of trust. For example, claims are typically paid without the payor first reading the medical record to ensure the service billed matches what the medical record states was done. In this way, hospitals and physicians are being trusted to submit accurate and truthful claims.
Before going down too many rabbit trails or getting lost in the weeds, remember some basic, but important principles about compliance, namely truth, transparency and trust.
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