As 2024 draws to a close, physical therapy organizations should turn their attention to operational compliance strategies that ensure adherence to both regulatory requirements and the promotion of objective evidenced-based patient care.
As 2024 draws to a close, physical therapy organizations should turn their attention to operational compliance strategies that ensure adherence to both regulatory requirements and the promotion of objective evidenced-based patient care. Both a well-structured approach for anticipating future operational needs as well as a meaningful compliance program not only mitigate risks and exposure but also enhance overall productivity. Below are seven essential elements to guide your practice’s compliance efforts as you close out the year.
Start at the top and conduct a thorough review of all existing company policies and procedures. Determine if they are still relevant and effective by assessing if they align with current regulations at both the state and federal level; also identify areas for improvement or updates. Once this is complete, analyze your risk profile by identifying potential compliance risks related to documentation, coding and billing practices. Clinical operations and front desk patient management, including privacy and security, should also be evaluated. Prior concerns or incidents should be reviewed in order to determine their level of exposure to the company and what corrective action was taken as part of their resolution.
Now it’s time to ensure that all workplace and compliance training materials reflect the latest regulatory changes and organizational policies and procedures. Industry specific employee training is the gold-standard for demonstrating meaningful workforce education. Role-based training is another layer that an organization can include to ensure that all employees are provided with consistent communication across the company based on their positions’ expectations and job functions. Competencies and other checklist tracking tools can be implemented to allow employees the opportunity to attest to their experience and skill level. Webinars, online courses, or in-person sessions that focus on the unique obligations of a position can enhance an organization’s overall commitment to compliance.
Building a culture of compliance within an organization takes time. Encourage and actively promote open communication for “all things compliance.” Ensure that employees know what resources are available and with whom to communicate regarding compliance concerns. A compliance specific email address, anonymous employee hotline and other modes of communication can all help create an environment where employees can discuss concerns and ask questions without fear of retaliation. Don’t forget to also educate employees about channels of communication and how to report suspected violations or unethical behavior confidentially.
Don’t worry about discovering something that needs to be corrected! Schedule time on the calendar to complete an Internal Audit of your operations. Department specific audits are a great way to learn if performance matches expectations. Your established policies and procedures should outline the benchmarks for each audit including timeframe, target goals and corrective actions based on identified deficiencies. Follow-up monitoring of operational performance allows your quality assurance function to identify any additional areas of concern. Once you have these two components in place, Key Performance Indicators (KPI’s) can then be used to track objective success or limitations overtime within your scope of reviews.
Claiming that compliance activities are taking place within an organization is different from being able to prove that compliance is active and effective within your practice. Make sure you have an outline of all the compliance program related activities on an annual basis. Maintain comprehensive records of all compliance education, staff training, audits, quality assurance and risk assessments. These records are critical to the future health and security of your business.
Doing everything at once is not practical or expected. Establishing a culture of compliance is rooted in the routine and ongoing workflow of your operational goals. Based on your internal assessments and audit findings, set specific compliance objectives throughout the upcoming year. Quarterly or annual tasks are a great way to hold leadership accountable for a strategic compliance plan. Allocating staffing and financial resources will also be required to meet the needs of compliance objectives. Luckily, you have options, such as outsourcing this function with industry experts or internally filling this position. With either option, start with a simple business associate agreement audit (BAA Audit) and examine your findings. The cost, risk and time to do this are as minimal as possible and your workplan has been initiated!
Regularly review updates from the APTA, your state practice act and other regulatory and payor organizations. Subscribe to newsletters from your top insurance payors in order to stay informed directly without a filter. Consider engaging legal counsel specializing in physical therapy compliance to review your contracts, lease agreements, vendor relationships or other negotiated documents. You may also want access to legal strategies to ensure that you are up to date with current laws and professional best practices.
Effective physical therapy compliance is an ongoing process that requires constant attention and adjustment. As you celebrate the end of 2024, don’t forget to plan for next year by focusing on these critical areas, which will help ensure that your organization remains compliant. By being proactive and strategic, your physical therapy practice can navigate the complexities of compliance and thrive in a never-evolving regulatory landscape. Regardless of being a rookie or a seasoned practice owner, an independent review from industry experts is a smart use of time.
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