A Lens Switch for Improved Compliance Effectiveness

A phoropter is a medical device that you likely have seen or used but may not recognize by name. It could also be called the lots-of-lenses-machine-your-optometrist-uses, and that may make it more recognizable.

The phoropter’s purpose is to allow an eye care professional to test many vision correction lenses quickly and easily, each option getting closer to a patient’s specific prescription.

In healthcare, leaders should consider a similar concept as they seek to have an effective regulatory compliance program.

There are many lenses we can use to determine whether we are effective at identifying and mitigating regulatory risks. Each of these may be valuable to monitor as a critical performance indicator.

We can review financial performance, including the number of denied claims or the results of government audits.

We can measure the completion of compliance education or — even better — include quizzes to measure whether employees really understand the information.

We may survey our workforce to understand things like whether people know about our nonretaliation policy and whether they believe we follow it. If there is a gap between those numbers, we may have more work to do.

We may look at the number of complaints or reports we receive for various compliance risks, such as privacy, conflict of interest, or harassment.

Just like the phoropter, many lenses may be necessary to create a clear and accurate vision of how our program is really operating in practice.

One lens we should never fail to use, though, is that of what compliance means to an individual. Are we helping each of our employees be successful in their role? Are our policies and processes seen as protective, or are they seen as requirements that have a purpose but hinder efficient healthcare?

A recent statement by Christi Grimm, Inspector General for the U.S. Department of Health and Human Services, emphasizes this what’s-it-mean-in-practice lens.

“Think about an individual employee,” she said. “That employee faces an ethical dilemma that forces them to make a choice. Has your company informed, trained, and empowered that employee to make the right choice? Are they empowered to make the choice that is consistent with your mission? And in times when that employee makes the wrong choice, does your company have the right capabilities to detect it, to fix it, and to ensure others don’t do the same?”

Clinical care requires a constant focus on what is needed for each patient’s care. As healthcare leaders, we must make sure we view compliance through the lens of a particular employee. Otherwise, we may miss out on some of the most effective ways to remain compliant.