3 Things Your EMS Compliance Plan Could Be Missing

EMS providers now find themselves facing down more and more complex regulatory issues and ever-evolving reporting requirements. And while most agencies do have a compliance plan in place, maintaining operational compliance is an ongoing initiative that takes consistent, progressive effort on everyone’s part.

Think back on the last time your compliance plan was reviewed or updated. Has it been a while since it’s had a refresh, and can you be sure that it’s currently the best protection that you have?

The truth is, neglecting your organizational compliance could be the ‘silent killer’ that’s been contributing to some of the key issues plaguing your EMS agency all along. Maybe it’s a disrupted revenue cycle. Maybe it’s the inability to focus on caring for your patients or serving your community. Whatever the circumstance,  EMS providers typically face these issues due to an ineffective compliance plan that’s unable to protect them against erroneous claims or the criminal penalties associated with non-compliance.

If this sounds familiar, don’t worry — it’s never too late to establish or update your compliance plan. And if you decide to, here are some key elements that you should make sure to revise or include.

3 Questions to Ask About Your Compliance Plan

1. Are Your Written Policies and Procedures up to Date?

 Written policies and procedures are the key cornerstones for any EMS agency to develop consistent and compliant business practices. Without them, you’re missing the roadmap that you need to make sure that you’re on the right track.

So how should you approach your written policies and procedures? While each agency differs in their approach, your policies and procedures should be reviewed and revised periodically based on the latest EMS regulations, and redistributed to all of your employees every time you update it.

Remember to make sure that your written policies and procedures have obtained leadership endorsement and approval, and that you continue to develop your policies consistently as time goes on. We recommend the best practice of referring to the following resources:

  • The 1998 OIG Guide for 3rd Party Medical Billing Companies
  • The 2003 OIG Guide for Ambulance Suppliers
  • The 2020 DOJ Evaluation of Effective Compliance Programs

2. Is There Anyone Overseeing Your Program?

Every official initiative needs someone at the helm, and your agency’s compliance program is no different. Many EMS agencies make the mistake of treating their compliance programs as a “set it and forget it” initiative — that is, until an audit happens. But it’s essential for someone to oversee the program and continue to run it efficiently. Without a designated Compliance Officer or compliance committee, compliance programs often fall short, mainly because there’s no one dedicated to operating and monitoring it.

When designating a Compliance Officer for your agency, it should be a high-level individual that reports directly to upper management and has the express authority to provide unfiltered reports to your board of directors.

Some of the key responsibilities of your Compliance Officer and compliance committee should be to:

  • Establish your compliance plan, including periodic reviews and revisions as regulations are updated
  • Developing your written policies and procedures
  • Monitoring your agency’s compliance performance
  • Monitoring the effectiveness of your compliance program
  • Enforcing disciplinary standards and ensuring consistency
  • Implementing risk assessments
  • Developing an audit work plan
  • Conducting regularly scheduled compliance training and education

Your agency’s compliance committee should also meet regularly to discuss any compliance activities, as well as any issues investigated, identified, and resolved by your compliance initiative.

3. How Can You Tell if Your Compliance Program Is Working?

Sometimes, it can be hard to tell if something is really working. That’s why your compliance program should have internal monitors and safeguards in place, much like any other system. Otherwise, it’s bound to fall apart from the inside.

Without the appropriate monitoring methods, your EMS agency may be unable to detect and identify any compliance problems — let alone reduce the likelihood of future ones. Be it quality assurance reviews or independent audits, these are valuable tools for you to determine whether your compliance program is performing as intended. Any results you obtain from these should be shared transparently across your organization, and then utilized in identifying key problem areas in the compliance of your agency operations.

To mitigate any remaining risk areas, it’s also recommended that you prepare risk assessments for your agency, with your focus prioritized around the top compliance high-risk areas as cited by the DOJ and OIG.

What's Next?

An effective compliance plan is more than just a ‘one-and-done’ initiative — establishing one and continuing to keep it up to date is a necessary and strategic business investment. How else will you be able to prevent, detect, and correct issues that could otherwise lead to catastrophic consequences?

With the right procedures and precautions in place, your compliance program won’t just safeguard your agency, patients, and the communities you serve from fraudulent claims and abusive conduct. It’ll also ensure an increase in the quality of your patient care, and make sure that none of your revenue slips through your fingers like sand.

Want to learn more about EMS compliance and determine whether your compliance plan is on the right track? Download our eBook on compliance here for our step-by-step guide on establishing a robust compliance plan.

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