Five steps to reestablish routine procedures once regulations are less flexible.
The Centers for Disease Control (CDC) recommends that every business has COVID-19 guidelines for reopening. As a result, many practices are reviewing their policies and procedures while there’s time available.
It’s likely that some standard compliance processes were shelved or modified during the outset of the COVID-19 pandemic to align with daily business. At the time, this made perfect sense — some practices were completely closed, while others were seeing urgent patients only. However, temporary regulatory flexibilities will eventually be revoked.
Knowing this, consider how the steps outlined below will help you reestablish routine compliance procedures in the next phase of a COVID-19 world.
Map out your plan.
If you have not started documenting the plans you are making to reopen your practice — along with your references — now is the time to begin. Practice workflows are being completely overhauled to accommodate personal protective equipment and social distancing measures. Maintaining excellent compliance documentation verifies the efforts you’re taking to ensure staff and patient safety, keeps tabs on what is working, and monitors any workflow adjustments.
Furthermore, documenting new procedures as you implement them will allow you consistency, training tools, and the ability to detect and employ any necessary changes.
Also, don’t forget to delegate. Given the amount of time we have now and with less interruption, we can demonstrate more patience to help develop skill sets among other staff members for assistance with practice compliance efforts long-term.
Commit to compliance.
If your obligations to routine compliance activities (e.g., internal auditing, exclusion database checking, safety walkthroughs) have not been completed due to COVID-19, don’t fret; this is certainly understandable and was likely not a great risk during the pandemic. However, you should document the reason(s) why standard procedures were not completed in your compliance plan.
As you begin to return to normal, recommit to a plan for the rest of the year, prioritizing what makes sense for your practice’s activities.
Complete mandatory training.
With little to no patients to see, now is a great time to complete mandatory staff and provider compliance training for the year.
Utilize this advantageous time (and keep staff on your payroll) by rolling out the CMS Fraud, Waste & Abuse; HIPAA; OSHA; and Harassment and Diversity trainings. You will be grateful you did, as your schedules for the back-half of the year will (hopefully) not be nearly as flexible.
Prepare for MIPS.
While MIPS flexibilities were abundant for the 2019 performance year, at the time of this article we do not yet know if the same or additional considerations will apply for 2020. Regardless, MIPS is moving forward in 2020, so if you have not started your efforts to ensure you are tracking measures well, now is the time. Check on quality performance, maximize IRIS mapping, start your security risk analysis update, perform and document your improvement activities, and work on ratcheting up your promoting interoperability measures’ scores.
Picking up this work now will benefit you greatly when your practice becomes busy again and you have already checked these items off of your to-do list.
Rather than lament how COVID-19 has affected your practice, consider how you can implement that long list of deferred ideas. Be sure to prioritize the have-to’s (like compliance) while there is ample time to do them well, and then sit back and enjoy being ahead for the rest of the year! OP