Leveraging a Culture of Compliance

by | Aug 8, 2011

The 2010 college football season kicked off last weekend and I, for one, couldn’t be more excited.  For the first time since 1993, my beloved Alabama Crimson Tide are starting the season as the defending national champions and I’m optimistic we can repeat – as opposed to doing what we did in 1993. For you non-members of Bama Nation, the 1993 season was the beginning of a very big black eye for the university as we ended up getting busted by the NCAA for a “lack of institutional control” by failing to keep our players from having inappropriate contact with agents and receiving improper benefits.

I was reminded of this during the offseason as the USC football program took a similar punch to the face when the NCAA came down on them for turning a blind eye to improper benefits being received by some of their star players and executing a lack of institutional control.”

Interesting phrase: “lack of institutional control”.

If you’re wondering what this has to do with healthcare and WFM, stay with me…

I recently read an excellent article on the Healthcare Finance News blog titled “USC Football Shame: Lessons About RACs and Compliance.” The author, after watching an HBO special on USC, walked through in detail the circumstances that resulted in USC’s punishments and related it back to hospital compliance.

Without regurgitating every point of the article back to you, let me summarize it for you with the following:

  1. The USC athletic department, from top to bottom, ignored the sometimes obvious signs that something could be wrong and did not prioritize compliance.
  2. Now that they have been penalized, USC is working to create a “culture of compliance” so that everyone at every level understands the importance of following the rules.
  3. There is a significant threat of negative consequences for both football programs and healthcare organizations for compliance failures.
  4. Healthcare providers should learn from USC’s experiences and start taking “proactive compliance measures”.

It is no stretch whatsoever to apply this to WFM in healthcare as well. The focus in WFM tends to be on the computer systems and automation, but in reality, the effectiveness of WFM systems are largely a function of behavior. And when it comes to ensuring compliance to either corporate policies or DOL or state laws, it is that behavior that is the primary factor, not the system.

It’s not hard to find practical examples of the importance of compliance in healthcare. Missing meals is a good one. Management can sometimes require it or nurses can habitually skip them. The constant pressures of patient care make it easy for everyone to overlook hospital rules or even state laws requiring lunches to be taken and employees to take a break. That can result in a organizational culture that bends the rules when it feels justified.

Did you know that one of the metrics that the Joint Commission asks hospitals to consider measuring is matching up “patient falls” to “missed meals” to see if there is a correlation? Even they know the importance of WFM and how employees directly affect patient care. And they do not look very favorably on hospitals that could be labeled with a “lack of institutional control”!

The good thing about this is that most healthcare executives understand the importance of compliance. They want their hospitals to have a “culture of compliance” where clinical rules are followed. And because executives want it, they influence their hospital’s culture to be compliant and value things like excellence and patient care.

This culture is a perfect tool to leverage when it comes to implementing a WFM system. Because WFM systems are more about practice and behavior, they are heavily reliant on manager and employee compliance with WFM processes and rules. A good implementation leverages the culture to be compliant with system process AND leverages the system to ensure they are compliant with WFM laws.

See the title of this blog entry? Leveraging a culture of compliance. That’s what you have the ability to do with WFM systems.

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