Wondering if you should attend clinical compliance trainings? The following paragraphs will explain to you the criticality of clinical compliance trainings. We hope this article will help you understand why you should attend clinical compliance trainings.
First, let us start with an understanding of clinical compliance, after which we will lead to into an understanding of why you should attend clinical trainings: Clinical compliance, as different from laboratory compliance, is mainly about adhering to the guidelines relating to areas of healthcare such as billing, coding, medical claims, insurance and related ones, although it is common to come across terms that use the two words, “clinical” and “laboratory” together, somewhat loosely and interchangeably.
The Office of the Inspector General (OIG), which comes under the US Department of Health and Human Services (HHS), set out these guidelines for clinical compliance in August 1998. This guideline, formally termed the Compliance Program Guidance for Clinical Laboratories, which replaced the model compliance plan of March 1997, is considered more accurate and consistent with the current clinical practices.
It sets out guidelines for clinical compliance by suggesting seven areas to which a clinical setting must comply. The OIG suggests that a clinical practice must have these systems in place to show compliance with its guideline of 1998:
- It must have written policies, procedures and standards in place, which will set out its rules of conduct
- The clinical practice must have a compliance officer and a compliance committee
- It should impart effective training and education
- It should keep effective lines of communication open
- It should enforce compliance standards through well-publicized disciplinary guidelines
- It should implement a mechanism for internal monitoring and auditing
- It should put in place resources that help it to respond promptly to any error or offense it could detect. It should develop corrective action.
Now, here’s why you should attend clinical compliance trainings
No doubt, the OIG recommends guidelines and doesn’t mandate implementation of any of them. But this is no comfort because a look at the guidelines makes it clear that effective training and education is a must. Noncompliance with this, or for that matter, any of these guidelines is taken seriously. What happens if an organization fails to meet these requirements?
A cursory look at some of the random cases in which the OIG, under its Project Lab Scam has imposed penalties on clinical practices that have not complied with the regulations will shed light on the need for clinical compliance trainings:
- Laboratory Corporation of America (LabCorp) had to pay nearly $200 million to resolve civil penalties under the False Claim Act (FCA). The reason: it allegedly submitted claims for medically unnecessary tests
- As far back as in the mid-1990’s, Damon Clinical Laboratories entered into a settlement agreement with the Department of Justice (DOJ) of close to $120 million in civil and criminal penalties. Its crime: submitting false claims to the Medicare and Medicaid programs
- By far, the biggest catch has been of the highly reputable SmithKline Beecham Clinical Laboratories. It was made to pay astronomical settlement charges of $325 million because the OIG detected violations in the company’s Medicare, Medicaid, CHAMPUS, and Railroad Retirement Board health care programs.
Seemingly simple reasons for penalizing
While these are some of the high-profile cases that have made the headlines, as recently as July 18, 2018, eClinical Works, LLC was made to cough up $132,500 in penalties. The nature of its offence: noncompliance in reporting Patient Safety Issues as Reportable Events in a timely manner as required by the OIG!
If this is the extent to which a clinical practice can be penalized, aren’t these enough reasons for why should attend clinical compliance trainings? Here’s why you should attend clinical compliance trainings:
The HHS considers a clinical practice to be compliant when it has satisfactorily met all the guidelines it has set out. According to it, a practice is considered compliant when it carries these out among other things:
- It charges, bills and documents rightly
- Its facility is approved
- Reimburses accurately
Another reason for why you should attend clinical compliance trainings: A clinical setting cannot take chances with any of these guidelines. It is only through the right clinical compliance trainings that it will be able to do this. There are those who complain about the upper cost of clinical compliance trainings. Now, this is cynical at best and poor low-level thinking at worst. Any clinical practice that thinks on these lines has to decide which of these is more prudent: spending a few hundred dollars on compliance training or save them to cough up millions!