Module 06 Course Project - Final Submission

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Monitoring Tools for Compliance Plans

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Background to the project

Originally, it was established that the medical facility was violating compliance policies that have been established by the management on the account of two areas. In the first case, it was established that medical staff does not wash hands between patients as is recommended by the medical facility. This is extremely considering the prevailing health situation in the country. In April 2020, approximately 0.9 million citizens had been infected with COVID and more than 52,000 Americans had succumbed to the virus (Tam, Walker & Moreno, 2020). The situation is dire with new cases continuing to be reported in the country putting more risk to healthcare personnel that constantly interact with COVID patients. Hand washing and social distancing have been recommended as the most effective ways to contain the spread of COVID. However, it is challenging and threatening when medical personnel fails to wash hands not only to prevent the spread of COVID but rather it is standard precaution measures to prevent transmission of infectious diseases (CDC, 2018). It is the background of this COVID compliance plan has been developed, related compliance policies and also compliance procedure and in this project, monitoring tools for this compliance will be developed.

Similarly, health facilities identified cases where medical staff charged clients twice. This is not allowed and replicates to fraudulent billing practices which if not tamed, can ruin the reputation of the facility. Complicated coding and prone to errors billing systems are some reasons given for the rise of rampant billing frauds in medical facilities. However, in some cases: patients are overcharged, charges are made for services not rendered and in other cases, doctors charge for wrong services fatten their pocket tell reasons for growing fraudulent billing practices (Bothwell, 2018). To curtail facility rising to billing scandals, a billing compliance plan was created, compliance policies and procedures and in this project, monitoring tools are developed.

Monitoring Tools for COVID Compliance Plan

The impact of COVID cannot be underestimated. It brought the global economy to a standstill and hardly hit the healthcare system. The United States is not exceptional but remains one of the most hard-hit economies with the highest number of confirmed cases. In the U.S, according to available data released by CDC, for reported cases from February to June in 2020, 571,708 (22% of total cases) healthcare personnel had been infected with the virus (Hughes, M2020). Access to PPE, face mask, social distancing and hand hygiene to HCP and those attended remain critical elements to protecting healthcare workers (Hughes, 2020). Surprisingly, even with glaring statistics on the serious impact of COVID amid other infections, medical staff fail to practice hand hygiene between patients advised.

COVID compliance plan has been developed that seek to address observed violation for hand washing practices by the medical staff. On the same effect, two compliance policies were developed which are standard precaution practice and communication policy on prevention. To ensure compliance policies are executed accordingly by the medical, a compliance procedure was developed which comprises of five steps. However, as though these efforts are not adequate, two monitoring tools are developed which seek to determine the efficiency of the compliance plan, the progress that has been and also helps identify areas that need improvement. Ideally, monitoring tools track compliance of medical staff to COVID compliance plan.

Monitoring tool 1: Infection Prevention and Control Assessment Framework (IPCAF)

This is a standard monitoring tool developed by WHO to assess the implementation of protocols and guidelines in the acute care facility (WHO, n.d). However, even though this tool was developed by WHO, it is a relevant tool that can be used to monitor COVID compliance plan.

IPCAF will monitor the COVID compliance plan in four aspects. In the first case, it will assess infection prevention control in the medical facility (WHO, n.d). Data that is generated on the rate of infection in the medical facility will be used by the compliance officer to track and assess compliance COVID compliance plan. For example, when infections number in the medical facility are on the rise, it would be an indicator that COVID compliance policies and procedures are not complied with by the medical staff. However, this will require investigation to establish the reliability of such assumptions.

On the second aspect, IPCAF will be used to identify relevant shortcomings that need improvement in the COVID compliance plan (WHO, n.d). This shows that IPCAF is powerful which not only monitors and also seeks to detect possible problems in the compliance plan which require adjustment to make it stronger and increase compliance to the plan.

On the third aspect, IPCAF will help check areas that meet international standards and requirements (WHO, n.d). For example, IPCAF will determine whether PPEs that are made available to medical staff are adequate and are of recommended quality. Further, will seek to determine whether medical staff and all people served by the medical are furnished with quality and updated information on prevention and containment as released by the ministry of health, CDC, WHO and other relevant bodies on infectious control.

In aspect four, IPCAF gives a score that helps to determine the progress that has been made on the compliance journey to the policies and procedure. This is essential because the course of action is generated from the results. It is the score that is generated which helps the medical facility to determine actions that need to take to improve compliance with the COVID compliance plan.

Monitoring tool 2: Compliance Officer

The medical facility will use the office of the compliance officer to monitor compliance to the COVID compliance tool. A compliance officer is competent, versatile and well informed with all details of a Compliance plan, policies and procedure therein as well as the expected outcome. Regularly, compliance will be required to track actions of medical staff and management to establish whether responsibilities assigned to each individual are implemented. For example, management should buy PPEs and medical devices required to enforce standard practices. The compliance officer assesses whether management has its bit and whether the medical staff is putting PPEs and maintain hand hygiene. Therefore, the compliance officer is a critical component in the monitoring process and recommendation of legal action to those found non-compliant to plan.

Monitoring Tools for Billing Compliance Plan

Fraudulent billing cases are rampant. The facility would want to maintain integrity stand by having a clean and ethical billing system. Lately, the facility has identified that billing officers are engaging in unethical malpractices by billing clients twice in some cases. This is unacceptable to the facility and it is putting all measures in place to avoid its billing system becoming an avenue for criminal enterprise. Because of this development, the facility has developed a billing compliance plan. Two compliance policies have been developed-procedure emphasizes the ethical and professional conduct of billing officers and second- auditing to the billing system. Further, a compliance procedure has been developed which detail five steps followed to implement compliance policies. To effectively ensure billing compliance plan is implemented and desired results attained, four monitoring tools adopted from Strategic Management Services, LLC (2018) are suggested.

Tool 1: Risk assessment and evaluation

This tool helps to detect tools that exist in the billing compliance plan. Some of the risks could be billers that lack integrity, a billing system that is easily manipulated and cases where billers develop codes and at the same bill clients. Therefore, risk assessment and evaluation will significantly help to identify vulnerabilities in billing compliance which would prompt action taking approach.

Tool 2: Compliance work plans.

This is a tool that provides a roadmap on how auditing to the billing compliance plan is to be conducted. It equips the auditing firm with necessary information on what to look for when auditing the billing compliance plan, history of malpractices to the billers and emerging malpractices that need to be considered.

Tool 3: Sampling protocols

This is a tool that would be used to establish variations on the monitoring that is taking place. It is a critical monitoring tool because variations identified form the basis for a possible problem in the billing system.

Tool 4: Computer-assisted Audit Techniques

A compliance officer will use this tool to get an in-depth analysis of the billing system, transaction and internal controls. This helps the compliance officer to determine whether billing officers comply with billing compliance policies and procedures, determine the efficiency of the billing compliance plan and areas that need improvement.

References

Bothwell, M. (2018, October 9). Why Medicare Billing Fraud Cases Are Running Rampant and What You Can Do About It. Retrieved from https://whistleblowerlaw.com/medicare-billing-fraud-cases/

CDC. (2018, June 18). Standard Precautions. Retrieved from https://www.cdc.gov/oralhealth/infectioncontrol/summary-infection-prevention-practices/standard-precautions.html

Hughes, M. M. (2020). Update: characteristics of health care personnel with COVID-19—United States, February 12–July 16, 2020. MMWR. Morbidity and mortality weekly report, 69.

Strategic Management Services, LLC. (2018). Health Care Auditing and Monitoring Tools for an Effective Compliance Program. Retrieved from https://www.compliance.com/resources/health-care-auditing-and-monitoring-tools-for-an-effective-compliance-program/

Tam, K. M., Walker, N., & Moreno, J. (2020). Effect of mitigation measures on the spreading of COVID-19 in hard-hit states in the US. Plos one, 15(11), e0240877.

WHO. (n.d). Infection Prevention and Control Assessment Framework at the Facility Level. Retrieved from https://www.who.int/infection-prevention/tools/core-components/IPCAF-facility.PDF?ua=1