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Mock Surveys – A Best Practice

By Amy Boykin, CHC SVP of Quality, Patient Safety and Care Management

 

Hospital accreditation is considered a standard of excellence for safe, high-quality care. Accreditation helps organize and strengthen patient safety efforts, improves risk management and risk reduction, and provides deeming authority for Medicare certification.

 

Mock surveys are a best practice to keep hospitals in a “stay ready” mode for an actual survey from a state survey agency on behalf of the Centers for Medicare and Medicaid Services (CMS) or accrediting organizations such as The Joint Commission or the Center for Improvement in Healthcare Quality (CIHQ). The good news – proactive community hospitals are following the practices of larger healthcare systems and implementing a mock survey process. Simply, it’s an industry best practice.

 

Mock surveys conducted every 12 to 18 months are a valuable component of quality improvement initiatives. This process provides a “snapshot” of compliance before an actual survey, while helping to teach, train and educate leaders and staff members. The goal is to improve care and patient care processes.

 

Like actual CMS certification or accreditation surveys, mock surveys are often unannounced and can be conducted by an outside consulting firm. Community Hospital Corporation conducts mock surveys for its owned and managed hospitals, involving a team of generally three to five “CHC surveyors.” Onsite at the hospital, the mock survey team conducts a review following guidelines outlined by CMS or the accrediting organization. Following the mock examination, CHC reviewers address hospital leaders personally in a verbal debrief. Within two weeks, the hospital receives a written report summarizing any deficiencies and recommendations for an action plan for improvement. Also, after a hospital goes through its actual survey, CHC compares the mock survey report to the final report from the accrediting organization to see how recommendations align.

 

Here are some insights and best practice tips for mock surveys.

  • Keep the ultimate goal in mind — improving the organization and patient care — when it comes to the mock review. Don’t think of it as a time-consuming, intimidating task.
  • Examine patient care processes. Are processes compliant with survey standards and requirements? Pay particular attention to environment of care and life safety categories, including new or revised standards such as fall prevention.
  • Focus on the process, not people. Your survey preparation should be process-driven. The responsibility for meeting any standard rests with the organization, not the individual in a particular role or position.
  • Infection control is a high-focus area. For instance, is a patient room clean or dusty; is equipment properly cleaned and disinfected? In kitchens, are food prep areas clean and orderly? Are designated isolation rooms kept at negative pressure?
  • Hospital buildings and the physical plant are part of the review process. Related to the environment of care, is an older facility in disrepair? Are electrical systems well maintained? Are floors and ceilings well-kept; are there stains on ceiling tiles? It may be necessary to call in a plant manager or engineer to remediate issues.

CHC Consulting also provides mock surveys for consulting hospital clients upon request. For more information on mock surveys, including how this process dovetails with a hospital’s Compliance Program described in last month’s CHC blog, see CHC Clinical Quality services.

Tags: Mock Surveys
How-to Basics for an Effective Hospital Compliance Program

By Doug Kent, CHC VP Internal Audit/Compliance Officer

 

As healthcare becomes more complex, there is also more emphasis being placed on financial considerations, and on preventing and detecting violations of state and federal healthcare laws. What can your hospital do? Start by creating a compliance program to self-police your hospital and staff activities.

 

Since its inception in 1976, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) has led the charge to fight waste, fraud, and abuse in Medicare, Medicaid, and more than 100 other HHS programs. In 2010, as part of the Affordable Care Act, OIG mandated that all healthcare providers have a Corporate Compliance Program in place as a condition of enrollment for Medicare, Medicaid, and Children’s Health Insurance reimbursement.

 

Along with assuring that needed dollars go to patient care, compliance programs serve to engage and inform employees and community members that your hospital is committed to “doing the right thing.” It’s also key to have compliance policies in place should you ever face regulatory review or inquiry.

 

Here are some best practice recommendations to develop or enhance your hospital compliance program.

 

1. Assemble a compliance committee representing a cross-section of employees. Compliance “belongs” to everyone. It’s a team effort and extends beyond the role of the designated compliance manager or leader. C-suite members, case management, revenue cycle, IT/security, and other employee representatives should serve on your compliance committee. Establish a group charter, meet at least quarterly, and ensure confidentiality of information shared with this group.

 

2. Develop a robust education and training program. Provide compliance education/information as part of new employee orientation. Offer online education courses to meet yearly training requirements on topics including billing and collections, Medicare rules, HIPAA, compliance issues, EMTALA, and conflicts of interest.

 

3. Establish a compliance hotline. Make sure employees know the hotline is an anonymous reporting system assuring the confidentiality and protection of individuals who may come forward; communicate the purpose of this hotline (it’s not an employee “complaint” line).

 

4. Include sanction screenings in your compliance plan. The hospital is required to check state and federal exclusion lists monthly to identify if employees, contractors or third-party vendors have had adverse actions taken against them by federally funded programs. Screenings demonstrate you have a routine process in place to monitor potential compliance issues.

 

5. Define and document conflicts of interest. To protect patients’ well-being and ensure public trust, board and management team members should sign a conflict of interest statement as part of the compliance plan. Keep these documents on file.

 

6. Manage compliance risk issues through ongoing monitoring and auditing. Make sure your compliance work plan includes a continuous control process to keep current on changes in rules, regulations and laws. Your work plan should outline internal controls to comply with these guidelines. For auditing, the approach is more proactive. Steps could incorporate chart review to examine how codes are being used and applied, or charge tracking for certain procedures or supplies.

 

7. Measuring compliance programs. It’s important to measure the effectiveness of your existing hospital compliance program. Authorities recommend that you conduct an internal evaluation yearly to assess your program’s effectiveness, and an external audit every other year with a report back to you that outlines program improvements.

 

For additional compliance education materials see the OIG Compliance 101 resources.

Tags: Hospital Management, Hospital Performance Improvement, Operational Improvement
Rethinking Supply Costs: Good to Great

by Philip Trent, VP of Business Development, CHC Supply Trust

 

Many rural hospitals today — health care providers whose mission is to serve their community’s health care needs — are apprehensive about their own financial health. Increasing expenses, decreasing reimbursement and declining patient populations and hospital admissions place these hospitals at risk, threatening financial viability.

 

Behind salaries, supplies are the second-highest expense for hospitals. By reducing supply costs and better managing the supply chain, a hospital can move its savings margin from good to great.

 

CHC Supply Trust, the supply chain services arm of Community Hospital Consulting, works with hospitals to help them evaluate potential savings opportunities by uncovering “hidden” dollars to offset shortfalls due to reimbursement cuts and reduced payments. Unlocking supply chain savings can support mission-critical objectives such as equipment upgrades, development projects or hiring additional staff as necessary.

 

Supply chain support services to help hospitals reduce costs while prioritizing clinical quality and patient safety through CHC Supply Trust include:

  • Supply Chain Consulting
  • GPO Access Only (a GPO for community hospitals with preferred pricing formerly available only to their bigger counterparts)
  • Customized Support Services Agreement
  • Outsourced Materials Management.

CHC Supply Trust delivers access, savings, and support

 

Teaming up with community hospitals, CHC Supply Trust offers a Complimentary Supply Spend Analysis. Whereas annual savings have averaged greater than 10 percent, recent CHC supply spend analyses have identified savings opportunities reaching 15 to 20 percent. Along with 100 percent of GPO rebates returned to participating facilities, CHC Supply Trust hospitals can keep their bottom lines healthy.

 

For example, 25-bed Community Hospital in McCook, Nebraska previously bought its supplies and services from a nationwide hospital network. As part of the network’s supply contracting company and GPO, Community Hospital was subject to volume-based tier pricing and paid approximately 35 percent more than larger hospitals for orthopedic implants. By purchasing those same items through CHC Supply Trust in FY 2013, savings on orthopedic implants alone totaled $334,000. Today Community Hospital continues to see approximately 18 percent savings annually on its supply spend.

 

About the Supply Spend Analysis process

 

It’s easy to get started on your Complimentary Supply Spend Analysis. Follow these simple steps:

  1. Sign the CHC Supply Trust confidentiality agreement (we protect the confidentiality of your data).
  2. Provide 12 months of medical and surgical supply data in Excel format (easily available by contacting distributers who have this information in a standardized report already).
  3. Provide 90 days of pharmacy supply data in Excel format (from their wholesaler).

With this information, CHC Supply Trust will conduct your Complimentary Spend Analysis and calculate how much your hospital can save by accessing preferred pricing through our GPO for the exact same items you already buy. No MMIS mining is required. We will provide you with a letter template requesting your pharmaceutical wholesalers’ and med/surg distributors’ reports, which can be generated with a few mouse clicks.

Tags: Hospital Performance Improvement, Supply Chain, Supply Spending
Negotiating Health Plan Contracts: Best Practice Tips

by Dave Koford, CHC VP Health Plan Contracting

 

For hospitals, “care” typically refers to providing patient care. Yet a hospital’s financial health requires care and attention, too.

 

A sound financial strategy supports the provision of patient care and services communities need, and a significant component of healthcare organizations’ revenue frequently comes from health plan contracts.

 

So what do your health plan contracts look like? Have you reviewed them recently? Are there opportunities to modify those arrangements to maximize your reimbursement?

 

Here are some best practice tips for health plan contracting.

 

Review your health plan contracts regularly – at least every year. Place this task at the top of your to-do list to help prevent future revenue loss.

 

Request full access to Policy and Procedure Manuals for each of your contracted health plans – before you “sign off” on those contracts. Your signature reflects your agreement with the current policy and procedure manual, but plans can (and do) change their policies. You’ll want to stay abreast of changes to make contract adjustments when necessary.

 

Know the health plan options offered by the largest employers in your community. In addition to the hospital, sizeable employers in a service area often include the school district and the city. Have these employers changed their health plans recently? For instance, has the local school district switched from a lower-paying plan option available to employees to one offering more favorable compensation or the reverse? Monitor these activities and changes. Keep information up to date.

 

Analyze reimbursement rates by payer. Are you receiving the appropriate compensation for the care you provide? Here are some factors to consider.

How does reimbursement for your commercial health plans compare to Medicare rates? Comparing one health plan’s reimbursement to another’s makes good sense. However, all health plan rates should be measured against Medicare. Plans with rates below Medicare could compromise the hospital’s financial health.

 

Unearth internal claims data. Review claims history before negotiating with an existing payer. Study how much revenue the payer brings to your hospital by service line. This reimbursement data could significantly influence the negotiation process since patient care and service lines are always changing.

 

Evaluate fixed rates and patient deductibles in rate negotiation to maximize revenue reimbursement. Hospital compensation under many health plan contracts features a fixed rate. Although this provides a level of predictability for the payer, fixed rates aren’t always the hospital’s best reimbursement option (and at a minimum, fixed rates should be adjusted up each year due to inflation, supply costs, etc.).

 

Also, for high-deductible health plans (HDHP), consider how easy will it be for a hospital to collect patient charges before a patient’s deductible has been met? HDHPs benefit the employer and the health plan, not necessarily the hospital.

Assess your payer-provider relationships. Look beyond the rates.

Establish or nurture long-term payer-provider partnerships, particularly when health plan payers represent a significant portion of your revenue. Are there new product offerings or risk-sharing models? Enhance positive working relationships to facilitate communication and negotiation.

 

What’s the revenue cycle telling you? Evaluate the processes associated with claims processing, payment and revenue generation. Are there opportunities for improvement to more effectively support the billing and collection efforts? (See a related CHC blog post for more on this topic.)

 

Keep up with health insurance changes for consumers covered through the Affordable Care Act (ACA). Many health plans have left the ACA marketplace and others are raising premiums and narrowing provider networks. What percent of patients do you see through the ACA? What impact do their high deductibles have on your collections? Under the new U.S. Administration, it is unclear how changes to the ACA or proposed health reform would impact care delivery – so staying abreast of what’s known will help your hospital going forward.

 

Learn more about the CHC Health plan evaluation process to review health plan relationships resulting in improved contract terms and reimbursements.

Tags: Affordable Care Act, Health Plan Contracting, Operational Improvement, Revenue Cycle
Billing and Collections: Whether or Not to Outsource

by Alice Fleetwood, CHC VP Revenue Cycle

 

Many rural hospitals find it a struggle to achieve positive cash flow and maintain enough days cash on hand to meet their capital and operational needs. This intensifies the importance of ensuring that patient accounting processes, especially billing and collection, are performing at optimal levels.

 

One option many turn to for managing this process is to outsource billing and collections functions. This effort may be seen as a way to improve accurate and timely billing of patient accounts, lower costs, and improve collections. The CHC Consulting Revenue Cycle team is often called upon to evaluate the pros and cons of outsourcing compared to maintaining a hospital-based employed business office.

 

CHC’s experienced staff has assisted hospitals in improving the entire Revenue Cycle process by helping to determine the best solution, avoid common pitfalls, and achieve a hospital’s cash goals. Here are some insights and best practice tips for evaluating whether outsourcing is right for your facility.

 

Define the Need.

 

Based on your business needs and in-house capabilities, determine what can be improved and maintained internally and what would benefit from outsourcing. For instance, evaluate each of the following functions:

  • Billing 
  • Cash posting
  • Account Follow-up
  • Appeals
  • Patient balances
  • Credit balances

Assess Departmental Billing Skills.

 

A keen understanding of Medicare and Medicaid billing requirements is essential, supported by regular claims management system edits. Having an experienced and strong Medicare biller is essential.

 

Review your organization’s billing and collections functions – determine which tasks could benefit from outsourcing.

 

  • Examine insurance balances. Go over payments and payer mix, starting with Medicare and Medicaid A/R to assess the percentage of payments made in less than 30 days. Because these payers are prompt when billing is handled correctly, timely collection is a good indicator of your hospital’s internal capabilities.
  • Appeals. Will you handle the first appeal in-house? For a second appeal, could an outsourcing group provide services not offered locally, such as an attorney or clinical services support?
  • Which categories of A/R might be the most appropriate to subcontract? Motor vehicle accidents (MVAs) for patients without a third-party payer, or workers’ compensation accounts with pending legal concerns are often outsourced due to legal filing and state compensation laws.
  • How long will you need outsourcing services and why? Do staffing concerns or system conversions make outsourcing selected services a reasonable alternative for a specified period?
  • Consider the responsibilities, which will remain at the hospital level. Some of the most common needs for outsourcing include support for customer service, financial counseling, scanning and managing correspondence, and coordination with other departments to resolve concerns.

Evaluate Results.

 

Managing your vendor extends beyond relationship management. Measure the results. Is your outsourcing partner collecting the needed cash? They should be accountable for all accounts you’ve agreed on — not just the “easy” ones. — Follow up through tracking metrics, audits and surprise on-site visits.

 

Consider the Cost.

 

For hospitals with strong internal resources, it’s key to weigh potential staff reduction savings against the loss of revenue the hospital will experience with outsourced collections. Compensation arrangements vary and may include:

  • A percent of total collections. These are typically based on the age of the account and the effort needed to achieve collection.
  • The number of accounts. A fee based on the number of accounts worked (not often preferred by vendors).
  • Hourly rates. The challenge with this method is in assessing and evaluating effectiveness of collections vs. cost.

Choosing the “right” outsourcing partner is rooted in trust. Select a team who understands your needs – ; an organization committed to a shared relationship. Discuss the scope of the outsourcing and define specific Revenue Cycle metrics with your contractor. They must be able to meet or exceed the stated goals, including cash targets and A/R aging metrics.

 

Learn more about CHC Financial Improvement Services including assistance with outsourcing.

Tags: Hospital Performance Improvement, Outsourcing, Revenue Cycle

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