The United States Sentencing Guidelines for Organizations (FSGO) lays out seven elements that sum up an effective compliance program. These include – implementing written policies and procedures, designating a compliance committee, designing and offering effective training, establishing a solid system of reporting, running internal audits, strengthening ethical standards using well-publicized disciplinary actions, and promptly undertaking corrective actions.
In the world of healthcare, these elements serve as the north star for managing healthcare compliance. Implementing these elements, however, makes up only half the story. The other half determines how well this implementation actually works. This is where compliance KPIs or Key Performance Metrics for compliance save the day. Here, we learn the types of compliance metrics your healthcare organization needs, how to deploy them, and how to analyze, track and work on the results to establish a solid culture of compliance.
KPIs Should Measure the Effectiveness of your Compliance Program
In a gist, compliance metrics determine whether your organization’s compliance measures are showing real results. They serve as valuable measurements that help compliance officers and committees shield the organization from risks and stay ahead of regulatory changes. A great way to foolproof your healthcare organization against non-compliance would be to deploy metrics designed around the seven elements of an effective compliance program.
KPIs Must Measure Outcomes, Not Just the Processes
Building a solid healthcare compliance program demands more than deploying several compliance-related processes. Valuable change emerges only when these processes are thoroughly reviewed and corrected. Some key outcomes to measure include:
- How many times and how often the Code and policies are reviewed and updated
- The type and number of violations of policies and the code
- Training frequency, effectiveness, and completion
- Training program update rates
- Training engagement and test results
- Compliance engagement and communication rates
- The nature and number of misconduct incidents by staff who have completed training
- The number and nature of known and anonymous reports
- Volume of retaliation allegations (especially if you are able to track allegations of retaliation to stakeholders reporting non-compliance)
- The number of compliance issues detected from external sources such as outside auditors, regulators, and customers
Should There Be a Compliance Team?
Perhaps the most critical element of creating an ethical and thereby successful healthcare business is to let a strong compliance team steer the compliance wheel. The compliance and control personnel you hire must have in-depth experience, qualifications, and of course, the technical and emotional know-how to handle any compliance hiccup. In the world of healthcare compliance, many teams have benefited by elevating a medical professional, such as a former nurse or quality control coordinator, into their teams.
If you already have a reliable compliance team in place, the next critical questions to ask would be, “How often do they meet and what kind of progress do they bring to the table?”, “How often do they report to the management?”, “How convinced is the top management in terms of bringing in new compliance revolutions?” “Are they truly convinced that compliance goals are business goals?” “What metrics do they collect when it comes to detecting misconduct,” and “How efficiently do they handle resolutions?”, and so on.
Analyzing Incident Reporting Rate?
The way misconduct is reported and resolved can make or break the ethical pillars of any healthcare organization. For this, it is critical to consider KPIs that generate data regarding the way your anonymous reporting and investigation system works. The metrics to consider here include:
- The number of incidents reported
- How quickly they were reported
- How many days did it take to complete investigations into allegations
- How many “simple” investigations took place compared to “complex” investigations
- For substantiated allegations, how many instances of remediation, retraining, or disciplinary actions took place
- What patterns emerged in the volume of reporting based on locations or departments
- What patterns emerged from the content of the issues
Whichever systems are used by compliance must gather, track, analyze, and record all data that comes from them. This is an important step to help avoid the emergence of any similar issues down the line or promptly resolve a case should such a scenario arise again. When your healthcare organizations continue to collect, analyze, and investigate these metrics, it shields itself against certain patterns of misconduct and takes on the role of a revenue protector.
Your metrics also record how quickly each issue was detected and resolved. The goal here is to narrow down the time between incident occurrence and issue resolution.
What is the Compliance Hotline Usage Rate?
An anonymous hotline not only encourages stakeholders to report issues without hesitation but it also protects them from any form of retaliation. However, to make the most out of these hotlines, it is critical to track the hotline usage rate. Address questions like: How quickly do your employees report misconduct they’ve witnessed or experienced? How easy-to-use is your hotline system? How quickly does a caller get to speak with a real person? How effective are your response times?
The Number of Compliance Investigations that Took Place
The quantity, quality, and consistency of your compliance investigations matter when establishing a solid culture of compliance for your healthcare business. The response, tracking, and escalation of investigations all come together to decide how effective and prompt your resolutions are.
Aside from measuring the quantity, quality, and consistency of these elements, include other metrics to measure the training, independence, and professionalism of the investigators. Measure the involvement of the legal counsel (if any), the timeliness of the response, the adherence to your non-retaliation policy, and the management of government inquiries.
Include Metrics for Screening and Tracking Vendors
Hiring employees, choosing vendors, and working with other agents is not enough. Your compliance program isn’t just limited to the doors of your healthcare facility. Make sure you set solid metrics in place to screen vendors, record any cases of incidents related to them, and understand how well they understand the value your organization places on ethics.
Measure the Outcome of your Incentive System
As with everything, incentives are a great way to motivate staff to stay compliant. If you already have an incentive system in place, make sure you analyze the advantages it brings to your institution’s table. A great way to start would be to ask questions about whether there are any specific examples of steps taken (promotions offered or awards denied) as a consequence of actions related to compliance. Whose responsibility is it to come up with bonuses, compensation, promotions, or discipline of compliance personnel?
Over to You!
While gathering essential compliance metrics is critical, it’s equally important to determine where, when, and how frequently your internal audits will take place and what is the goal behind each process.
The results that pour in from each metric analysis will help answer questions like, “How often should you conduct these audits?”, “What are the risk areas your organization needs to work on?”, “How frequently must your healthcare business update its risk assessment?”, “How often must your compliance team review compliance policies, practices, and processes?, and “What steps can your teams take to create a solid foundation of ethics?” Although the types and number of compliance metrics are endless, gaining clarity on which ones to deploy will help your healthcare facility align its resources with strategy.
