News and Upcoming Quality Program

Yesterday, I wrote a post regarding health systems and providers looking at finding efficiencies and, in some cases, cutting staff – particularly at the administrative and executive levels. Providers are being tasked with making do with less as the economic headwinds remain stiff, even gale force in some cases.

Part of the challenge for providers is the overwhelming level of regulations requiring constant attention to various dimensions from reimbursement to patient satisfaction to ethics and compliance. Every post-acute provider (and acute too) is required to have an ethics and compliance program to assure compliance with Federal Conditions of Participation in the Medicare program. The elements required include policies, procedures, education, reporting mechanisms, audits, and for most, a dedicated compliance officer.

I am as in-favor of program integrity and compliance as anyone. H2 Healthcare, my firm, has a significant commitment to health care compliance and, one of the premier clinical compliance specialists in the country as a partner. The issue however, for providers today, is that the required level of compliance activity to be in “compliance” with regulations/conditions of participation is expensive, time consuming, requiring specialized staff and training, and a process for conducting billing integrity audits to assure systemic compliance with anti-fraud and abuse provisions. The infrastructure can seem daunting and the monitoring of the program, a time-consuming process.

As a means of helping providers become more efficient and become even more fluid in meeting their ethics and compliance requirements, my firm, H2 Healthcare, is soon to launch a virtual compliance officer/ethics and compliance program that providers can use, saving funds, accessing the best resources, and having a team of professionals focused (and current) on ethics and compliance requirements and trends. Most important, the virtual program will meet all Condition of Participation requirements/accreditation requirements for SNFs, Home Health Agencies and Hospices. A quick list of what to expect is below.

  • A low annual engagement fee, flat, based on the size of the provider/organization.  The fee will be a fraction of the cost of a compliance officer.  
  • All policies and procedures.
  • Reporting hotline (toll free) and email (secure).
  • Posters and staff communication tools.
  • Education for staff, new hire and ongoing.
  • Monthly one-on-one time or staff meeting time for questions and for ongoing engagement.
  • Annual report to the organization’s CEO or Governing Body.
  • Event reports as necessary, to appropriate designees and CEO/Governing Body.
  • At least one annual claims review audit, randomly sampled, with report on results and recommendations for improvement. We will offer more as necessary or in response to any government (Medicare, Medicaid) action or in support of any billing/claim probe.
  • Quarterly webinar in-services/education sessions that can be recorded and repeated as desired.
  • Internal audit tools and QA process forms and best practice materials.

The goal is to have this program ready for Beta testing with a few prospects at a significant discount, within the next two months.  More to come on this exciting service!

Finally, and I enjoyed the honor, I was recently interviewed by, a web platform for entrepreneurs. From their site: “IdeaMensch is an interview platform for entrepreneurs, makers, and doers“. My interview, including my comments (within the interview) on the development of the new quality program, is available here:


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