The Compliance Checklist Nobody Actually Completes

Every practice has a compliance checklist. Somewhere. In a binder. On the shared drive. An email from the consultant. Everything they’re supposed to be doing regularly to stay in check with HIPAA, OSHA, state licensing, infection control, everything is in one spot to have it all checked off.

But no one ever gets it done.

Not because they don’t want compliance and want to cut corners. Not because they don’t see the value in getting it done. But because for far too many small practice operations, there isn’t any time or effort to go about doing it the right way.

The Checklist That Expands

Healthcare regulations do not diminish. They multiply.

Every couple of years something new comes out. New electronic health record documentation requirements. New privacy regulations. New infection control mandates. New substance use regulations for controlled substances. New staff training regulations.

What was a checklist that could be conquered five years ago is now doubled in size. Something that was once done annually is now required quarterly. Once signed off now has another box that needs checking that the staff had a chance to review it plus employee satisfactory competency and annual training audit needed.

For large systems this means more compliance staff are brought on board; for small practices this means the office manager has yet another bullet on an already impossible checklist.

The Time That Doesn’t Exist

Here’s what it actually takes to get a standardized medical practice compliance checklist done:

Ongoing annual training for staff for HIPAA, infection control, emergency protocols, safe workplace procedures. Monthly routine reviews of access logs to assess whether patients had their notes accessed/reviewed for any other reason than expected access needs. Quarterly procedures with equipment inspections and audit signature requirements. Annual risk assessments with consistently revised policies with routinely managed background checks of all staff and credentialing requests of all staff as needed.

Each take time. Not a lot of time individually but cumulatively? Hours must come from nowhere each week.

For too many practices “nowhere” translates into the office manager squeezing it in between angry patients, confused schedules and disgruntled insurance companies. The front desk needs coverage when someone calls out sick so where does the time come from?

Or the owner of the practice – the physician – squeezes it into their off-hours – which goes against all professional recommendations since the medical provider is not trained in this workload endeavor.

What Gets Done Instead

What gets done is what’s needed so the practice doesn’t get fined for not performing due diligence expectations of what’s required to remain compliant from a perception perspective at least – staff get HIPAA training that takes too long and requires extensive documentation but they avoid minor renewals that lapse into expired statuses.

Licenses are up for renewal so they’re renewed before expiration; equipment gets assessed if it’s blatantly going to present a safety concern down the line because after time invested in getting an auditor in to look at what someone thought would but never actually obtained proper attention over the years means it’s flagged if photos exist showing years worth of deterioration without comments meaning trouble in an ideally theoretical risk scenario.

But longitudinal awareness over time, audits that determine whether documentation really warrants universal priority with additional suggestions? That’s what falls through the cracks not intentionally but because there’s no one available with time and energy to take ownership over time. Which is why external virtual assistants for healthcare growth make sense – and bringing in a specialized compliance team allows someone else to manage this small detail without full day fires pulling them in multiple directions.

No one wants partial compliance because that’s not compliance at all; when auditors walk in or something happens, saying we meant to get it all done but got too busy isn’t a legitimate excuse when urgent need overtakes educated guessing instead.

The Things That Fall Off The Radar Completely

There are compliance issues that fall so innocuously into place that they become invisible until they’re required – all new employee handbooks as labor laws change; equipment maintenance requires documentation; consent forms require review/updates; staff require current certifications to perform otherwise mandated procedures before any can be conducted; labs require updated emergency equipment – and what’s the review date that’s never assessed?

These are not glamorous tasks but they’re so benign interspersed between daily efforts that they get pushed back until next week, next month, whenever we can…until an auditor shows up or a staff member raises a flag or something goes wrong and suddenly everyone realizes this should have documentation or a process or training that never happened because it got lost in the shuffle.

The Training That Didn’t Occur

Staff training requirements are extensive: Initial training for systems and procedures upon hiring then continued education about compliance topics related to their roles thereafter; new policies require new training (with some exceptions); specialized training for each occupied role by administrative employees means time taken for all employees.

The reality of many small practices? New hires are shadowed for about three days by long-tenured employees who might know the policy before they’re thrown into the fray themselves without much step-wise guidance (other than what’s in their heads). Then annual required training happens because it’s required – and everything else happens if there’s time – which there typically isn’t because no one wants to stay after-hours when people are available.

This creates loopholes where people do things as they’ve always done them, rather than as policy dictates. Procedures are not followed because people are unaware of the correct procedures. Workarounds become the status quo simply because no one is there to direct what’s right and wrong.

The Documentation No One Reviewed

Documentation is key in healthcare – but regarding everything from incidents to potential failings to justification attempts, documentation only serves its value if someone checks back afterward for validity and comprehensiveness.

Most documentation exists because a practice must provide it but no one ever checks back with accuracy or usefulness aside from “Yeah I’ve got documentation” when documentation shouldn’t exist if it’s inaccurate.

Consents haven’t been redone over time but red flags don’t emerge until recertification months later when caveat consents have been poorly informed and competencies presumed checked off long before haven’t met muster.

Training logs indicate employees completed their modules when they absolutely didn’t – and maintenance certificates suggest consistent checkups that likely haven’t occurred – the people who document without checks back create paperwork – or reports – hoping no one looks too closely at everything needing more eyeball scrutiny than reality allows.

Why This Happens                        

The reason gaps exist too often with compliance is because small practice operations provide limited operational support – there’s rarely an office compliance officer (if any) and more likely than not there’s barely an office manager with sufficient staffing dedicated to operational musts let alone systematic compliance review functionality.

Practices know they should be doing better – they feel bad about it – but instead of blaming themselves into failing over whatever falls through the cracks, recognizing what should be accomplished versus what’s realistically achievable gets accomplished is an entirely different ball game altogether.

In large healthcare organizations, dedicated departments serve such purposes – in small practices, working harder helps work smarter – and that’s not true without fair compensation of professional acumen offered accessibly and affordably.

The Real Risk

While fines exist over possible failed audits – or at least subsequent penalty options – the real risk is failure of compliance presents safety and quality failings that shouldn’t happen, Infection control fails due to poor longitudinal stocking; equipment maintenance falls by the wayside presenting risk; privacy fails because those allowed to assess files observed patients will never be able to come forward.

Mandatory failures are not bureaucratic red tape – they exist because every line that fails represents an additional risk against everything that shouldn’t happen – but does if steps haven’t been taken toward fulfillment.

What Works Instead

What practices do to champion successful compliance is simply easier when more dedicated administrative support beckons appropriately, where healthcare compliance management exists from comprehensive oversight to random audits, regulatory hosting solution, outside professionals who’ve dedicated their careers specifically toward such efforts spell bliss.

But for small practices, it’s about compartmentalizing what’s required against volumes which would overwhelm them at face value – therefore practices must value timely efforts, while increased staffing hours for such efforts adds value as well as significance.

Practices need change to make changes effective – but unless they’re willing to implement radical changes nothing will ever happen other than intentionally adding extra hours worked (and supported systems through supervisors making rationalizations based upon critical thinking – small systems have no time).

Practices who’ve figured out compliance solutions are operating under considerations championed by dedicated resources who’ve viewed compliance as a necessary operational component rather than relegated an afterthought simply because they mean well.