Written By: Andrew Morgan PT, DPT, MBA, COS-C
Imagine this scenario: you have just finished working with a patient. You go to check your email. You see an unread email with the subject line, “compliance investigation”. What are your initial thoughts? Regardless of your level of experience, your seniority, or what you have or have not done, that subject line will likely cause some degree of anxiety. But, should it? If your company has done a proper orientation, then you should know that a compliance investigation is just what it says it is: an investigation.
Patients, family members, and even co-workers can report things to compliance. In fact, most organizations require a compliance report before all of the facts are available. I work in home health, an area ripe for compliance complaints. I remember a situation where a patient called alleging that her clinician, who just left her home, took her 2 roles of quarters that she needed to do her laundry. I sighed to myself, but my position required that I file a compliance report. I initiated the process, which began with documenting the patient’s allegation and obtaining a statement from the clinician. He denied the allegation. He even offered to go buy 2 roles of quarters to avoid the investigation; unfortunately, that was not an option. As I completed the paperwork and was about to send the report, the patient called again. She found her quarters.
What do should you learn from this situation? Hopefully, you learn that you rarely have anything to fear from a compliance investigation. Anecdotally, and in my experience, most compliance investigations end with an unfounded or unconfirmed status. A complaint that is unconfirmed means that there was simply not enough evidence to verify an allegation. When an investigation is unfounded, it means that the investigation has concluded that the claim is false or not supported by facts.
Hopefully you never receive an email from compliance; however, if you practice long enough, chances are you will. So, when and if you do get this dreaded email, what should you do?
- Do not panic. There is a possibility the investigation does not even involve you. Sometimes your name be mentioned as a potential witness who can verify a complaint.
- Cooperate. Reply to the email or accept the meeting. Avoiding the compliance investigation will not make it go away. It only frustrates all involved.
- Be honest. Answer all of the questions truthfully. If you do not know an answer, say so. If you are unsure of something, state that. If you know something, provide that information when asked.
- Do not try to be evasive. Answer questions truthfully. A compliance investigator is not trying to trick you or trap you. They are simply looking for the facts of what happened. Do not offer your opinion or hearsay unless asked directly to do so. A compliance investigation is not the time to place motives on others.
My first focus is always on providing quality care. If you focus on quality, you will rarely have to deal with compliance. While my first hope is that you will never deal with a compliance investigation, my experience suggests that many of you will. Knowing what to do can save you a lot of grief.
Andrew’s Upcoming Free Lunch and Learn:
March 5th: 12:00am-1:00PM EST
Andrew’s Upcoming Live Webinar CE Courses:
March 1st: 11:00am-1:00PM EST
Clinical Documentation in Occupational, Physical, and Speech Rehabilitation
April 12th: 11:00am-1:00PM EST
Evidence-Based Rehabilitation of the Total Knee Arthroplasty
CLICK HERE to view Andrew Morgan’s Instructor Page & OnDemand CE Courses
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