Both the Centers for Medicare & Medicaid Services (CMS) and the Joint Commission have ramped up their scrutiny of contract management at hospitals—and with good reason. Data breach and communication breakdown are very real risks given that multiple hospitals departments are regularly accessing the contracts of many varied parties, from vendors and employees to payers. But the feds’ chief concern is that you—and your external contractors—are providing quality patient care that aligns with regulations.
That’s easier said than done if you don’t have a solid contract services evaluation process in place. And you can expect the feds to question everything. For instance, hospitals are frequently asked why they have contracted with certain entities, according to medical legal consultant Sue Dill Calloway. In her ProfEdOnDemand presentation, “Contracted Services: Comply with CMS, Joint Commission & DNV,” Calloway explains how to evaluate your contracted services to be sure they will measure up to regulatory scrutiny—and patient satisfaction.
Yes, you: Everyone responsible for a hospital’s contracted services is on the hook for evaluating those services and complying with standards. That list includes, but is not limited to, safety officers, hospital directors, accreditation and regulation representatives, risk managers, chief nursing officers, and legal counsel.
According to the Joint Commission, your evaluation duties involve not just observing the care provided but also collecting data on contracted services, reviewing performance reports, and conducting staff/patient surveys.
Knowledge Is Power
CMS recently issued a memo pointing out deficiencies in hospitals—with many failings related to contract management. And CMS has added a section to the final worksheets for surveyors to address contract management issues specifically. Clearly, your contracted services are under the microscope!
So get proactive and conduct your own self-survey. Reflect on these important questions:
- If your hospital is accredited by the Joint Commission, do you and your staff currently understand all the contract requirements?
- How knowledgeable are you and your staff about the CMS hospital Conditions of Participation (CoPs) contract requirements (which every hospital that accepts Medicare or Medicaid reimbursement must follow)?
- Do you understand the standards for hospitals accredited by DNV-GL (which are closely cross-walked to the CMS CoPs)?
- If you want to survive the current increased scrutiny of contract management, you must address any knowledge and practice gaps—now.
Better Contracts, Better Care
The bottom line is that you must ensure that the same level of care is provided for patients, regardless of whether your hospital provides the services directly or through contracted services. But doing so doesn’t just make smart compliance sense—it’s also good business.
Global Health Exchange recently conducted a survey of top healthcare providers, asking what factors are most critical to solving cost and quality issues in the healthcare industry, reported Becker’s Hospital Review. Forty-seven percent of respondents believe that contract optimization is a key component—that by having good data, providers can better manage the contracts they do have as well as decrease “off-contract spend.”
Get In Compliance Now!
If you find your facility doesn’t have a full understanding of contract management regulations, there’s still time to get up to speed on whatever regs apply to your hospital—whether Joint Commission (leadership chapter) requirements, DNV standards, and/or CMS hospital CoP rules.
Start your compliance-upgrade right away—and know that it is possible to train your staff to avoid the contract management errors that will earn the feds’ ire, Calloway assures.
