An Ounce of Compliance by Wiks Moffat

The government is broke - so regulatory enforcement is up, way up. It’s the new source of fiscal solvency and our nation’s medical practices are increasingly caught up in the scramble for fine and penalty “revenue”.

The old saw “An ounce of prevention is worth a pound of cure.” takes on even more significance. So what goes into your “ounce” (comparatively) of proactive prevention?

There are three areas where the medical practice faces the most risk:
• HIPAA –HITECH
• Corporate Compliance
• OSHA

For your HIPAA-HITECH compliance you need to do a privacy and security risk assessment to insure that you have site specific and up to date manuals, practices and procedures. HIPAA-HITECH training of all current and new hire staff. Additionally, annual refresher training is highly recommended as current knowledge is what will be evaluated. What’s been taught two years ago is certainly no going to be top of the mind recall. Keeping up with changes is also critical as changed areas tend to be the focus of compliance audits.

For Corporate Compliance you’ll again have to insure you have an up to date site specific manual, practices and procedures. Some of the main points to be covered include the anti-kickback and Stark self-referral provisions, billing practices and your ongoing audit of provider charts. Prospective audit of at least 10 charts for each provider annually, with follow-up training as necessary, is recommended.

For your OSHA Compliance you will want to assess your programs for:
• Hazard Communication (including MSDSs, now revised to SDSs).
• Infection Control / Bloodborne Pathogens
• Fire Safety
• General Duty Requirements
With OSHA compliance it is especially important that your practices and procedures are site specific and that your staff is regularly trained.

In summary: Assess, Implement and Maintain (AIM). If you get your programs developed and implemented, maintaining them becomes relatively painless. Compliance should no longer be a time intensive full time project – as software and internet alternatives can now produce superior programs that can be coupled with online training for a very effective “ounce” of prevention…. Because believe it, you don’t want the pound of cure.

Wiks Moffat is a proven entrepreneur and is a pioneer in the healthcare compliance industry with over 23 years of experience and expertise. Wiks has performed compliance assessments in over 3,000 medical practices, urgent care centers and ASC’s of all sizes. He has been a requested speaker and author to both national and state associations. His company, MedSafe, has served over 5,000 medical practices in implementing regulatory compliance plans.
Please visit Wiks website or contact him directly for further compliance related information. wmoffat@medsafe.com