It's time to lean on compliance officers
James M. Berklan
If administrators and long-term care managers were ever looking for a good time to make their mark, this is it. And they better be looking to, or creating, high-quality compliance officers as well.
That's according to Rebecca Bartle, and she should know. She's seen a lot in her rise up the long-term care ladder. It's gone from certified nurse's aide, to registered nurse and MSN, to licensed nursing home administrator ... all the way up to board chair, regulatory affairs director and prized educator for HOPE (Hoosier Owners and Providers for the Elderly).
Her group is a "third" Indiana provider association, in addition to LeadingAge and American Health Care Association state affiliates. They work closely together with one another, and state regulators, on important topics such as the massive new participation rule.
Bartle painted a busy, tricky future for providers on Tuesday at the LTC Senior Living Central CXO Summit in Chicago.
Leaders need to get involved managing regulatory change for their organizations. They also need to help shape policy at the government level, she reiterated several times.
The new nursing home requirements for participation from the Centers for Medicare & Medicaid Services are 700-plus pages of hard work. For provider veterans, it will mean revamping many processes they've acquired over the last 25 years. Some have known nothing different, so confusion and anxiety are expected.
Take a deep breath, get ready and step into action. The first implementation deadline is about six weeks away. But don't panic, and do let some of your most valuable assets earn their keep: compliance officers. They're more important than ever.
If you don't have one (or enough), get more in the pipeline, and quickly. Direct caregivers, including administrators putting out day-to-day brush fires, have plenty to worry about already. They need a dedicated professional(s) within the organization to be looking at bigger-picture compliance issues, Bartle noted. Provider associations also may be more important than ever to manage the massive number of changes. Some of the alterations might be mere tweaks and not require a lot of heavy lifting (i.e. adding email addresses in many places), but they are voluminous and need attention.
CMS is instituting the biggest set of changes since OBRA 1990, so it's naturally a bit disorienting for many LTC veterans, Bartle notes.
“There absolutely has to be increased awareness,” she told me after her panel discussion on regulatory needs. "Some [veteran providers] may be making the decision that ‘It's a good time for me to exit.' However, it's also surveyors making some of the same decisions. They might be deciding, ‘I've done this and I'm not going to redo it and just move on.'”
That is part of Bartle's message: You're in it together with the regulators, who also have their hands full. It's not known how strict they'll be the week after Thanksgiving, when changes are supposed to kick in, but common sense would say good faith efforts will not be punished, at least early on. New surveyor training is set to take place in July, in advance of new survey parameters set to take hold in November 2017. Again, a ramping up period would be reasonable to expect.
But there DOES have to be movement in the right direction in the meantime. Your compliance officer/department gets a chance to shine.
A pair of top-rate policy experts from LeadingAge — Cheryl Phillips, M.D., and Evvie Munley — will be leading a conference call at 2 p.m. Eastern today that will take a “comprehensive” overview. It costs $99 to take part and offers CE credit. Find more details about it here.
Also, at 1:30 p.m. Eastern on Oct. 27, CMS will be holding a conference call for providers to parse the inner workings of the new final rule. The Medicare Learning Network production will take a broader view, including consumers in the discussion, but providers would be wise to look into it. More information can be found here.
More, similar efforts are sure to pop up. It will pay to keep your eyes open for them. Keep calm and start codifying the changes needed in your local policies and on-site practices. You won't be the only one tackling these challenges.
"The biggest thing for people like me who have had their entire career dealing with OBRA, and who may have felt they had a really good handle on regulatory compliance, is it's back to the books again," Bartle said. "It's time to make sure you cross your t's and dot your i's."
Follow James M. Berklan @JimBerklan.