Compliance has been too often relegated to a mandatory all-staff lecture held in a conference room one day per year. It’s not exactly an event that Complex Rehab Technology (CRT) and home medical equipment (HME) teams look forward to … or perhaps think much about, after that meeting is over.
But is that the best strategy, from either a business or an employee perspective?
Noel Neil, the chief compliance officer at ACU-Serve, shared a different approach with attendees of the August FUTURE conference hosted by HME Business, Mobility Management’s sister publication. In his presentation, Neil made the case for a more active, vigorous and organic strategy that keeps compliance in play all year long.
Changing the way compliance is perceived
Neil advocated for making compliance an active, ongoing goal that can ultimately support a CRT or HME provider’s success.
“There’s this joke amongst sales teams that compliance is the revenue-prevention department, because compliance tells you what you can and cannot do,” Neil said. “But I always chuckle in response and say, ‘Well, compliance is the revenue retention department, right?’ Because there’s no point in you getting that money if, when the government come knocking, you cannot keep it. So it’s important for you to do the right thing and make sure that when the money is collected, it stays in the bank.”
Neil also advised business leaders to encourage compliance-related conversations among their teams — and to create a safe space for discussing compliance.
To support open communications, Neil said, “We have a non-retaliatory policy. I don’t believe in stupid questions. We’ve gotten questions from folks in the industry for a very long time, and we might think, ‘Hmm, interesting.’ But it’s not a dumb question. If someone asks us, it’s because they want to know.
“So it’s really about creating that atmosphere where your staff feels comfortable asking you. One of the things that we emphasize is our non-retaliatory policy. If someone sees something that might cross the line, they can bring it to our attention without fear of retaliation, retribution or any other adverse effect, if they do it in good faith.”
Creating that safe environment is the job of leadership, Neil added. “Culture starts from the top. You have to have someone who is just not walking around with a whip and saying, ‘You did this wrong!’”
Instead, aim for creating an atmosphere where compliance is all about education and communication — as Neil suggested, “Hey, let us help you do your job better and compliantly, okay?”
Making compliance an everyday strategy
Making room for robust conversations about compliance can support a company culture in which compliance is positively perceived and routinely considered.
“As it relates to a culture of compliance, compliance should not just be a check box,” Neil said. “It should not be just something that you do once a year. Compliance has that negative connotation associated with it. But what we try to do within ACU-Serve, and for the clients that we work with, is to help folks to understand that compliance is a source of knowledge.
“If you’re in doubt about whether or not you can do something, ask compliance. We’re not monsters; we try to make ourselves very accessible to our staff. If you’re in doubt, just ask us.”
Neil recommended creating expectations for open communication and plenty of room for compliance-related questions.
“If you just tell someone not to do something, and if they have an inquisitive mind, they’re going to ask why or why not,” Neil said.
Some conversations, he added, could be as simple as talking about the potential danger of a staffer doing favors for a referral source.
“It’s really just explaining why it’s not okay for Johnny to wash Dr. Smith’s car every Sunday so that he sends you all the referrals,” Neil said. “It’s knowing that’s something like that can land you in prison. It’s understanding that these are the rules, and that’s important, rather than just saying, ‘Don’t do it.’ We try to break it down and explain to them why it’s prohibited.”
And he gave an example of how to encourage all team members to think and talk more about compliance.
“One of the things that we started last year — and we’re bringing it back this year within our company — is annual compliance week,” Neil said. “We spend that entire week providing education to our staff. This is information that they probably already know. But we make it fun; we create games and have different prizes for the individuals who complete certain assessments in a timely manner.”
So … compliance can actually be fun?
“It shouldn’t just be about strict rules and regulations, but it’s important to get the buy-in of all the staff, because really, compliance is everyone’s responsibility,” Neil said. “It’s not just the responsibility of the compliance team, it’s not just the responsibility of executive leadership. All of us have to play our part. All of us have to do what we need to do to ensure that our organizations and our partners remain compliant.”