Bridging the Compliance & HR Gap: Drive Operational Efficiency in a Shifting Regulatory World

Hello, and welcome, everyone, to today’s webinar, Bridging the Compliance and HR Gap, How to Drive Operational Efficiency in a Shifting Regulatory World. On behalf of Becker’s Healthcare, I’m Erica Carbajal and thank you so much for joining us today. So before we get into it, I’m going to walk through just a few quick housekeeping notes here. So first, we will start today’s webinar with a presentation panel and you can go ahead and submit any questions you have throughout by typing them into the Q and A box that you should see on the right side of your screen. Today’s session is also being recorded, so it will be available after the event. You can go ahead and use the same link and login information for today’s webinar to access that recording if you’d like to see it once it’s available. And if at any time you don’t see your slides moving or if you’re having any audio issues, just refresh your browser. You can also submit any technical questions into that same Q and A box. We’re here to help on the back end with those. So with that, I’m pleased to welcome today’s esteemed presenters. First, we have Donna Fiel, Chief Compliance Officer at ProviderTrust Michael Rosen, Co Founder at ProviderTrust and David Servedidio, Director of Marketing at ProviderTrust. Thank you all so much again for being here, and I’ll now go ahead and hand it off to you all. Hey, friends. Happy afternoon or good morning depending on where you’re you’re at. We’re thrilled to be able to come to you live today. We we have a really cool session, planned planned today. We we’ve, we had a lot to share, a lot to cover. Couple of things that I would I would ask, of y’all attending and listening live is let’s make this as interactive as possible. Right? We’re gonna do our best to get you the information that you need, in an impactful way. We’ve got a ton of stuff to send after as well in terms of resources and things like that. But if y’all have questions, please, we can see them coming in in the chat. Just go ahead and ask. We’ll do our best to address them kinda as we go. And if not, we’ve got some space carved out at the end for questions. And and so please make it interactive. We’d love to hear from y’all, and and just bring as much relevancy as we can to y’all’s world. Today, I am thrilled. We had a little bit of a a little bit of an intro already. But if if you if you haven’t heard of ProviderTrust, I’m gonna give you just a couple minutes of background about who we are and what we do in the world and why it makes sense for us to talk about connecting HR and compliance, and how to bridge that gap in a changing regulatory environment, especially in a world impacted by COVID nineteen and an ongoing pandemic. Today’s presenters, we are, we are just thrilled to be able to have, Donna Thiel, who is has been a chief compliance officer, for one of the largest post acute systems, in the country, and has been our chief compliance officer at ProviderTrust, for, several years now, is a subject matter expert and an industry trusted voice in the compliance world, certainly for providers, but has also spoken to payers quite a bit, in just the last few years. Donna has, just recently been HITRUST certified, high five, Donna, on the phone. And so even from a security perspective, the intersection of data security, HITRUST, high trust, and how that intersects with traditional compliance as well has been a massive part of her world. So we’ll we’ll intersect interject some of that today. Michael Rosen is a cofounder of ProviderTrust is, as he will describe, a recovering attorney, and a lawyer by background, but that has has brought his, his legal expertise and the way we think about the regulatory environment, both from a compliance and from a human resources perspective, had it’s just it’s been a critical, again, another industry trusted voice that, both Mike and Donna speak at conferences really frequently, about the intersection of these two. It’s a topic that we we talk quite a bit about, we’re really passionate about, and both Mike and Donna are trusted experts on bringing that information to you. Myself, I’m gonna be mostly the the interviewer today. This this is gonna be a little bit of a podcast style. We were debating internally what’s the best way to bring the most relevant information to you. We’ve got a couple of slides. But for the most part, we’re just we’re gonna be, I’m gonna ask our panelists, Mike and Donna, questions, about their experience based on questions we got from several of y’all in the audience and, what we are asked pretty continuously as it relates to the intersection between compliance and HR. So that’s my role on the phone today. Here is what we are gonna cover. A quick agenda. We just covered introductions. I’m gonna include a quick introduction about provider trust and who we are. Connecting HR and compliance in twenty twenty two. What does this look like? What are some of the keys to that? What are the things that we think about? And it’s changing. Connecting HR and compliance is far different now than what it was certainly pre COVID nineteen, but even just in the last five, six years beyond, it’s this is a changing, evolving connection point between compliance and HR. So we’re gonna talk a little bit about that. The COVID nineteen impact and growing trends, what are we seeing? We, provider trust, live at the intersection between compliance and HR. And so we see how these two things work together and collide, in, in different ways, and we’re gonna tell you a little bit about growing trends. That’s gonna lead us into a conversation around good, better, best. What does success look like? Again, just alongside of trends, what was good, better, and best five, six years ago is not what’s good, better, and best today, and it’s certainly not where the industry is evolving. So we’re gonna bring you case studies of what we see in the world. And then we we we, we’re talking internally, and we figured the best way to do that to explain good, better, best in theory is to actually put it into practice. And so we’re gonna talk what does good, better, best look like as it relates to licensing credential monitoring, a very specific shared process in which we see the good, better, best theme, either either help or hurt if it’s if we’re misaligned in in some of the ways that can impact, not just your organizational risk, but, ultimately, your patients downstream. Not just your organizational risk, but ultimately your patients downstream. It’s a little bit about what we’re gonna cover, and then I’m almost done with my part of the program. We’ll get into the good stuff. Who we are at ProviderTrust. We are a compliance monitoring company. We monitor more than five million individuals, providers, and vendors on an ongoing basis for compliance against all sorts of regulations, whether that’s monitoring for credentials and licensure status, whether that’s monitoring for exclusions, either state or federal, or sort of anything in between. Monitoring primary source, state licensing boards for disciplinary actions or state actions, state abuse registries. We live in the world of aggregating primary sources that matter for compliance and HR reasons, And that’s sort of why we’re here today. We’re made with love in Nashville, Tennessee. We’re privately held since our founding in twenty ten with over a decade of experience. We focus and live solely in health care. We serve providers, payers, and vendors. We are really proud to be consistently recognized as the best place to work. We are very proud of our culture. You can’t tell on the screen, but all three of us are actually in the same physical location. We even just right before we jumped on this webinar, we did a little bit of return a relationship at provider trust and and reconnecting with some of our colleagues in person for what felt like the first time in quite a while. So, we we value our culture. We value the relationships we get to build, and that includes the folks we get to work with. You’ll see NCQA and SOC too, on the logos on the screen. We’re also pursuing HITRUST certification as well. We care tremendously about data integrity, data security, and privacy along the way. Serving health care’s finest, I’m I’ve mentioned our return to relationship. Well, these are just a few of the brands that we’re proud to call friends, partners, clients, and colleagues, on an ongoing basis. Some of them are new, to the provider trust family. Some of them have been with the provider trust family for a decade or more. We serve the continuum of health care from post acute to acute to academic medical centers to telehealth, virtual care to payers, to and pharmacy networks and basically anywhere in between. So we’re really proud of who we get to work with every day, and it’s those insights that fuel the content that you’re about to hear that we’ll walk through you with you today as we learn good, better, and best in connecting HR and compliance because of the brands that we get to work with. And some of them that you see on the screen today will actually get a chance to reference, and say, here’s what best looks like because we sought this organization do it. And here’s some of the and and have jointly presented that in other spaces across the health care ecosystem. So super excited to bring you some of the insights from from very specifically some of the brands that you see on your screen today. The last slide of provider trust, and then we are getting into it, it, is just essentially what we do. We believe pretty deeply in provider trust that a smarter health care makes it safer health care. We believe that if we can make health care just a little bit smarter, we can make it a lot safer for everyone and make it a lot more equitable regardless of who you are, what you look like, or what your income level is. We can deliver a safer health care experience for you across the entire continuum. That’s what we do, and that’s what we believe. What that means very tactically is that anything from health care license verifications and monitoring to OIG exclusion checks to the entirety of compliance and eligibility. We deliver it all in a platform that, is inclusive and aggregates primary source documentation from, the OIG, and state Medicaid exclusion lists, primary source license verification and going to state boards, disciplinary sanction screening, talking through enabling sources like a Medicare opt out or an OFAC, and vendor compliance and onboarding as as well is all in one platform. That’s the world in which we live, which gives us the unique perspective and insight that you’ll hear from for the rest of the presentation today. So with that, we are gonna get started connecting HR and compliance. And so I really wanna start off, with a question to, to Mike and to Donna. Donna, Donna, you can go first, which is just, let’s talk about the relationship between connect with compliance and HR and some of the content that we were I had just talked I had I just shared earlier is how is this relationship changing over time? Thanks, Dave, and thanks everyone for joining us today. And thank you for those of you that are responding in the chat that, that you can hear. Hopefully, Lisa, Lauren will help you resolve your microphone issues or your issues. So how is it changing? What’s important, in the relationship between HR and compliance? It’s it really is a natural relationship and one that, in most health care organizations, does have to be fostered to a certain extent. Right? We, I think in compliance, we certainly have our accountabilities. HR has their accountabilities. But but when you think about all of the things, most issues in an organization, right, ultimately boil down to people. And compliance has to help us, navigate the landscape, navigate the regulatory requirements, all those things that are swirling around us. But in partnership with HR to say, hey. How can we communicate differently? How can we communicate in a way that’s understandable and is is valuable to, all of our team members in the organization? So I think leveraging those relationships and really reaching across the table and saying, I’m here. I wanna be your partner. How can we, solve these problems together? How do we communicate good together and and define, processes that work within our organization, work within the compliance and regulatory world, but but really make it, a comfortable place to work and come to and care for your patients each and every day. Right? Patients are our number one accountability where we wanna spend most of our time, but our people are the ones that are caring for those patients. And and I think we have the opportunity, speaking from a compliance hat, right, to reach across the the aisle and say, hey. I wanna be a better partner. I wanna help, support you so that we have the right folks, caring for our patients each and every day. Yeah. Donna, I think you laid that out nicely. I think if if I could add just from a recovering lawyer’s perspective that is, I I started out litigating, and, really didn’t find much satisfaction in it and ultimately found my way in entrepreneurially to the compliance world, which I I really love. It’s actually helping people. But, on a different note, I will say that, you know, one of the things that’s really, what a lawyer looks for when things go bad is when, you know, policy and procedure is a good thing to have. You need to have them, and they need to be reflective and current of of the kinds of things that your organization does. The problem with the policy procedure is when you don’t follow it. And so there’s so many intertwining things that occur between HR and compliance that really when when the when the, when the crap hits the fan, if you will, is is is easy hunting for what went wrong. And there’s so many things that could naturally with the partnership front end. So, not to scare you, but to let you know that, really, between h you know, a lot of times, I think in today’s world, compliance, compliance, and, we’re not going to be able to do that. Between h you know, a lot of times, I think in today’s world, compliance has moved from that that group that’s gonna come point their finger and shake their head and is always gonna say no and make life difficult to really being proactive and being able to help the organization meet its goals and objectives. Nobody wants to see an organization in trouble with the Department of Justice. They don’t want to see a bad brand, with their name out in the marketplace. And, and that’s why HR and compliance. And when you think about really the evolution or ecosystem, if you will, you know, the the patient experience, which is what we’re all on, even here at ProviderTrust, we wanna make patients’ experience safer, with better data. That’s our little way of contributing. And you as a provider hire what are supposed to be the best skilled and trained and licensed and credentialed individuals so that they can do what they’ve been trained to do, which is take care of patients. When that goes, wrong and someone either isn’t licensed, we can discuss that later, or, doesn’t believe in the quality and and value of quality care, it drags HR and compliance because HR is going to have to deal with that issue, now that it’s a people per issue. And compliance is gonna have to determine, is this reportable? Do I have to report it to the board? Is this something that we’re gonna need to, to resolve? So it really is where we see it best, and we’re gonna highlight Ochsner in a minute who does does it so well, and and pass on kinda how they’ve chosen to work together proactively, it becomes seamless, and then HR and compliance are really one. Thanks, Mike. Donna, I wanna kick it back to you to just talk through the the ideal relationship and the overlap between some of these. So, you know, again, just setting the framework a little bit for some of the stuff that we’re gonna get into over the next thirty, forty minutes is where are the intersection points and how do these things tie in from HR to compliance and the the intersection of clinical along the way. What’s the what’s the ideal, working relationship between those three variables? Thanks, Dave. And I think when, you know, when we put this slide together, right, we purposefully put clinical in the middle. Right? Again, trying to put the the patient in the center of of everything that we’re doing. And when you think about HR and and especially in the the world that we’ve lived in for the last two years, right, the rules are changing on a daily basis. We’re having challenges finding staff. We’re having challenges keeping staff. We’re having agency staff in our facilities on a much more frequent basis. And and what does that mean? That’s this huge burden on our our partners on the HR side. Right? They are constantly recruiting. They’re coordinating with any of these agency staff that are they’re coming into their organization. They’re they’re trying to make sure that they’re properly credentialed. And we also know that during this past, couple of years, right, there’s been all of these emergency orders that allowed licensure restrictions to to kinda go out the window at at certain times. So they’re just trying to make sure that the person has the right credential, that they’re coming in the door, that they’re onboarding them. Right? Trying to, hopefully, get some sort of orientation and onboarding the protocols that are appropriate in in the organization. And clinical sitting in the middle just saying help help help. I don’t care. Like, I need people. Right? I need people in to care for these patients. And And compliance is all the way over here on the other side saying, woah. Woah. Woah. I understand that all of these things need to happen. Let me help you. Like Mike said, I think, feeling, again, from a compliance perspective. Right? Compliance is your partner, is your friend. Right? We’re not here to say no. We’re here to say, here are the rules. Let’s figure out a way to to fit within those boundaries and get you what you need. And so I think the compliance side is saying, I’m gonna help you with those regulations. I’m gonna, you know, keep us up to date, make sure that we’re all on the same page, making sure that we’re pivoting as quickly as we can to to meet the requirements and also meet patient needs, which ultimately means meeting HR and staffing needs. And there are like, that last bullet talks about the the ethical decision. Right? There is a point in time where the pressure from the clinical team and the the pressure that HR is feeling to get folks into, into the your health care setting, it just mounts and mounts and mounts. And you you have to think about what your risk tolerance is. What are the good ethical decisions that, that we have to make to to, again, care for our patients? So I think the intersect is the patient in the middle, but it’s it’s how do we interpret the changing and evolving world around us so that we can support the very quick and fast paced changes that the HR team is having to do in this really, especially in this current time. Mhmm. Yeah. Don, I only have one more thing I think what’s, will resonate certainly with with both HR and compliance. There was a recent case that came out that I found fascinating, and and really takes it to a different level. Unfortunately, courts are now holding senior executives personally liable. If you’re under a corporate integrity agreement, your organization, you, the compliance officer, are certifying that the things that you said the organization is doing and they’re documenting and showing the OIG, it actually occurs. And you can be personally liable if if in fact that’s not happening. There was a case called Martino versus, South Bay Mental Health Clinics. It just came out. And, in essence, it involved, a private equity firm that had purchased or had bought into existing, seventeen, social mental health facilities, if you will. During due diligence, their lawyers told the buyer and the PE firm, private equity firm, that the way they were billing and the way they were accounting for, they basically had unlicensed providers a licensed provider and then submitting that as a claim. That’s a false claim. And the Department of Justice was coming down on this organization. Ultimately, what happened was and so this is an HR and compliance area that could have been better collaborated. Ultimately, the the system ended up paying, almost twenty million dollars in fines, but two of the boards of directors who were from their private equity were personally held liable because once they were informed by their lawyers during diligence prior to purchase that this was going on, they did nothing to stop it. It. And that’s where you have to stand up and come to the board and represent as HR or compliance or combined, but we can’t continue to do this. What and in this case, Martina was a relator. She was an actual former employee who blew the whistle. So from an HR perspective, you do a good job bringing in people. They also could become qui tam relators if they see fraud and you aren’t taking it seriously. So, really, I think that case is is designed to really kinda show you that had those organizations work better together and have certainly the leadership taking it seriously, they could have avoided over twenty five million dollars in fines. That’s a great share, Mike. I as follow-up for everybody that’s listening, we’ll make sure to send out that case to so y’all y’all can get the primary source and get the the, directly from, you know, directly from the primary source, following the webinar. I wanna ask one more question while this slide is on the screen too, to both of you as, you know, you all have been living in the intersection of compliance and HR for the last two years. We’ve all been continuously navigating COVID nineteen. I’m curious how you’ve seen that the relationship between compliance and HR evolve over the last two years, and know, in what specific ways have you seen this really get stress tested and force some evolution in the connection between both of these, compliance and HR? I can start if you’d like. I think it’s just the reality that we all need a partner. And and I think the the challenges that we’ve been presented is there there aren’t enough people no matter where you look, no matter what role you’re playing. And each one of us, we all whether it’s compliance, whether it’s HR, whether it’s clinical, whether it’s operations, finance, it doesn’t matter. Right? You need a partner. You need someone that is by your side, that is helping make decisions in a very fast paced environment. And when you look at a lot of of our enterprise clients and myself and, you know, my past life, like, the leadership teams have to come together. There has to be continuity and consistency in our messaging, and we have to make fast, difficult decisions. And and so I think what I’ve seen is perhaps a little bit of, knocking down those walls and knocking down those silos and just saying, we we have to be a team in order to to survive. I mean, quite honestly, to survive and for our organization to continue, to be able to to meet the needs of our of our patients, our clients. And so I think as difficult as it has been, there will not be, you know, kind of a, going looking backwards or going backwards to that very siloed organizational model. It I just don’t think it works anymore. I I think there has to be collaboration, and and I think maybe I’m not sure the good of of this, but, you know, one of the the things you can look at is how did we iterate? Like, how did we change when there there was no script. Right? There were no scripts for us to figure it out. And and so to me, that’s that’s what I’ve seen mostly is I’m I’m not wearing the same hat I wore yesterday. I’m wearing, you know, ten of ten different ones and ones I never thought I would wear. And, I think that’s gonna continue in the future. And I think it helps, you know, it helps all of us realize that we are partners as we’re trying to, make these difficult decisions. Yeah. Dave, I know in a minute, we’re gonna talk about the seven elements of a compliance program and and remind you that you you already should be doing some of these, which is another way to to bridge that gap between HR compliance. Douglas actually asked about how do you connect risk quality and patient safety with HR compliance. I love that because he’s thinking, you know, as a team thing. Donna, you actually were a client of ours. You were with one of the largest long term care providers in the country, and we were a solution for you. I would love if you could tackle that question because I think your team did a really good job, and your board actually embraced the value of compliance. So how do you connect not just HR compliance, but risk, quality, and patient safety? It’s a great question. You know, honestly, it starts at the top. You know, I obviously reported to the board and to the the CEO, and I spent I had the opportunity to meet with the CEO all the time. But, like, every board presentation, every board report, I sat with him, and we always put patients first. Everything in our board reports were quality first. That’s what drove our organization. And I think he was was absolutely the proponent of of patients. Our our our number one, reason that we’re here, quality first is the most important. And and so having compliance sit with this you know, sit in that space and and really be able to to say, you know, a quality outcome is a measure of compliance. Right? If our quality outcomes are going down, like, the compliance committee, we, you know, we measured all sorts of quality metrics and risk metrics within the compliance committee framework. So it it really it starts at the top in my humble opinion, and you really have to have the board and and your senior leadership, in concert and sitting next to you at the table each and and every day. And, you know, whether it’s these seven elements that are on the screen right now, those are just tactical things. I think that that from a compliance perspective, we know are always kinda looming in the background. But they’re a framework that we can all kind of use as our guide. And and some of the presentations that that our team has done and we talk about these seven elements, we link them to HR specifically and show how there’s there’s marriage and partnership. But I think if you went through all of this and and layered on top of it quality or clinical, you would see that that same synergy exists. Right? It might look and feel different when you talk about monitoring and auditing. You’re monitoring quality outcomes, patient outcomes as opposed to monitoring metrics as it relates to to claims and outlying claims and that sort of thing or monitoring a metric in HR relative to turnover. They they all come together. They there’s all similarities, and I do absolutely believe it starts at the top. Yeah. Donna, I I I think you nailed it. And I would say a takeaway and a win for each of you on this call, whatever your role or involvement is, is is I would challenge your your, senior leadership to allow you to be present and or present, at a board meeting. Donna herself comes in and presents at each of our quarterly board meetings, as she should on, you know, what are the risks? What are we doing about them? How are we categorizing them? Are there, things we’ve learned? What are we doing? How are we approaching HITRUST? Those kinds of things. Our board deserves to know, and I don’t want them to be in the dark of not knowing what we’re doing or taking something seriously. To that to that same extent, I think if you could collaborate HRN compliance and say, we’d like a a a five or ten minute section at the board meeting, and we want to show you what we’re doing from beginning when we recruit to onboarding, hiring, background checking, monitoring, all the way through so So we don’t have relators, and we don’t have unhappy, people. Here at ProviderTrust, we do a weekly pulse. Every Friday, our people operations team called Pops sends out a survey to all of our one hundred and five employees. And we want to know they don’t have to say who they are. What’s the pulse? How are you doing today? And certain questions are asked, and it gives us a really good idea. I won’t wake up on Monday and be surprised if I’ve got someone unhappy because they’re telling me, hopefully, in advance what their concern is or what they’d like to see and learn. So there’s things you can do all along the way through the HR process, to to gain more insight in how your staff the temperature of your staff. We touched on seven elements of it of an effective compliance program, which is, you know, an an acceptor standard thing that you’ll hear a lot about, not just from us, but other folks, across the compliance continuum. I think one thing that we have observed from the provider trustee has been the in each of these continued collaboration from HR and compliance over the last couple of years. And so specific to we’re gonna get into one of them at the end just as a to go a little bit deeper. And when we say more connected, what does it mean? In monitoring and auditing, in monitoring and auditing, and what does that look like in a good, better, best scenario? So I wanna take us actually there. I think it’s a good time to talk good, better, best best of, you know, where and I think for those listening, you know, we have several hundred folks listening into this live. When we consider a good, better, best evaluation criteria, I think pay special attention to what Donna and Mike are saying. And where do y’all stack up, right, on the good, better, best continuum, and what does it look like to move from good to better or from better to best? And and I would really challenge y’all, to to consider that. And so, Donna, let’s start with you is, let’s talk good, better, best. What does good look like? What does better look like? What does best look like? And do you have specific examples of where you’ve seen that? Absolutely. And and, David, if it’s appropriate, it might even be great for people to put in the chat, like, what how they define good, better, best, or what they feel, like, examples of good, better, and best look like in their world. So I think good when you start with good, good is that you have a relationship with HR. Right? And and really focusing on, do we have, you know, ad hoc conversations? Are we sitting at the table on a any sort of cadence? You know? Do we have a relationship? Are we partnering, you know, at provider trust? We focus on exclusion monitoring and license monitoring and and people and all of those sorts of things. And and so using that just as an example, in a good environment, right, if if we find an excluded person, what’s my relationship with HR? Like, how how do they help do the investigation? Are they part of the investigation? Is it clear that that we’re working together in in making that decision? I think just knowing, like, hey. We’re in this together. I think that’s good. Right? We we’re good. We kinda have a sense of of which one of us owns kinda what area. I think better is that next step of routine routine legitimate, you know, is it a monthly cadence where you and your your colleague, on the HR side and compliance side have a a routine meeting where you’re actually looking at things together. Are you, do you have metrics that you’re sharing across the, the aisle? Are there metrics as it relates to to turnover or onboarding or orientation and making sure that the internal controls that you may have surrounding, you know, in my life, in my past life, right, no employee could work the floor without going through orientation. And orientation had to be done within the first, you know, three days. Right? There’s just those were metrics that we monitored to make sure that, we are meeting them. HR drove orientation. HR drove the hiring process. But on the compliance side, we were monitoring the metric to make sure that we stayed in compliance with our own, you know, own policy, which, again, ultimately relates to patient safety because you wanna make sure your folks are trained before they get in. So so better to me is is really that great relationship where you have a routine cadence. Cadence. I think best, Mike, alluded to Ochsner, and we have just a great partnership with them. And we we spend a lot of time with our friends at Ochsner and do some some co presenting and had a really opportune a great opportunity to get to know them well. And they’ve actually combined their HR and compliance functions under one umbrella in their organization. Now I think I was when we were kinda prepping for this, I’m not even sure that that’s best. I feel like that might even be a step past best. I mean, I feel like that that isn’t the norm yet. I think it’s it’s amazing. I love the synergies that have been created with, with that collaboration and and kind of changing the org structure. In my world, in today’s, I think, real, like, best just feels like an absolute comfort in partnership. HR and compliance are, you know, at the table together. They’re investigating together. They’re making decisions together when, you know, so and so person needs to be, is is leaving the organization. What does an exit interview look like? What compliance questions are being asked in the exit interview such that, you know, Mike was alluding to whistleblowers, you know, so that so that we’re making sure that our our folks that are transitioning out of our organization that that we know how they’re feeling and that we know that any compliance issues have been reported or that they’re saying that they aren’t aware of, you know, any, you know, inappropriate behaviors or any, you know, false claims sort of thing. That to me is best in today’s world. Ochsner is the gold standard, and I, you know, we couldn’t have done a whole webinar about that transition. And and I I love that, and I love the consistent, clear accountabilities, clear partnership, between HR and compliance. Yeah. Let me add to that and and not in any way self serving because I wanna talk about this broadly. You know, good is focus on what you do well. Right? There are certain things that HR does really well. If that is because you are good at recruiting, do it in house. If you’re not good at recruiting, recognize that you’re not and work with the staffing partner or whatever pressures that are coming your way and you’re not able to keep up with. You’re drinking from a fire hose right now. You know, it’s a it’s a market where people are leaving for a dollar or more an hour or, you know, even better benefits. It’s it’s the great migration. It’s affecting everyone. And that puts more pressure on you. And as some of the questions were coming in, they were asking about, you know, like, what are the metrics to truck to to track? Well, certainly staffing ratios is how you’re being judged by the regulators and the state licensing boards and and the auditors. And so if if you can’t keep up and that’s not what you’re good at, then outsource that. And that’s where we find and that’s the genesis of actually how provider trust was started. I came from the background screening industry, and we were really good, my previous company, at getting, background checks completed timely so you could hire, staff. And then no one was monitoring that person the day after they started. Well, that’s when your liability begins, not ends. And there was no solution really out there, and I saw that and thought we should focus, but that’s all we wanna do. We just want to focus on one thing and do really, intentional work. And there are people whatever the whether it’s a hotline or whether it’s a monitoring service, or all the different things you could consider outsourcing, find what is better. Because, a lot of times people will think, this is public record. I can just download the OIG list. Sure, it is. But it comes in in poor data format. And data coming in, data coming out, being poor both ways is not reliable for you. And so when companies, whomever they may be, are really proficient at trying to solve something so that you can focus on providing care actually, that’s really where you should be focused is the the measurements of and the delivery of quality care. Let others help you do things. We always say if we can help our compliance and HR, colleagues sleep better at night, they shouldn’t have to worry is is their staff licensed, is their staff able to bill Medicare, are they excluded. That’s just not something you should have to worry about. You got much bigger fish to fry. And so I think finding so that’s moving from good to better to best is some things are are done well in house, some things are not, and, finding that trusted provider. Donna is in the midst right now of assessing our vendors and having to determine, the risk assessment associated, making sure we don’t handle PHI, but we handle PII. And that’s very, that’s a very valuable asset to bad actors, and we have to be very careful about not exposing your, employees’ data out there. And so we’re we’re that’s where we rely on the best of breed software programs and other, consulting firms that help us make our systems, you know, locked down in tight. And likewise, you’re doing the same where it might be better to to partner with somebody else. I I love that perspective. Thanks, Mike and Donna. The other thing I think William asked a great question. I I wanna make sure we touch on here because I think it relates to the good, better, best, is what’s the what’s the relationship between overall health system trust and successful compliance? It’s a great question. And I and I think, you know, I’m actually a marketer on the phone, and I think the you know, something that I pay attention to a lot is brand reputation, and how people perceive you. And when you think brand reputation, that is not logos, colors, and a great website. Right? That is what people perceive of you in in in the market and the, the considerations that go into that. And we’ve seen this go really, really well. So today, we’re talking about HR and compliance. I think best a component of best is when those outcomes and the highest standards are actually, one, connected with the the vision and the mission of your health system, and you can actually put some teeth behind that. And then secondly, I think it’s absolutely, a growing trend that we’ve seen especially during, the pandemic of partnering with your communications team and making that part of your overall story that you’re telling of patient safety and quality and the the the measures that are put in place to ensure that when a patient walks through the front door, that they can trust that their provider is licensed, not excluded, safe, fraud free. So I think the connection there is a really important one. I think it’s integral. I don’t think it’s, we’ve seen brand erosion with, health systems that we’ve seen in the industry that when they have so many, they have a critical licensure issue, they’ve had a nurse on staff that, you know, had a did not have a license, wasn’t appropriately licensed, how quickly that can hit, the news and and erode health system trust. The other piece that I think is really critical to this as well that I would I would add in is health system. Today, we’re talking about compliance and HR, but the the health system trust extends far beyond just your employees. And so Mike alluded to this before of part of your health system are your vendor partners physicians that are referring to your health system and ordering services with your health your health system, the home health provider that you’re working with to outsource, outsource services. So all of that becomes part of the the the trust metric of your health system too and going all the way back to seven elements of a compliance program is the better we are at that, the more it actually, I think, directly impacts impacts health system trust. And you can actually leverage that, in a in in in a way that directly contributes to your mission health system. And it’s just critical it’s a critical piece, and I we I see a lot of organizations do this well. I also think it’s it’s it’s rare to find best, to that degree. And I think it’s a good challenge for all of us. William, it’s a great question. I wanna we’ve got a ton of questions too. I’m gonna keep them rolling as we go. The next piece that I wanna get into is actually going a little bit deeper into a specific process to say when when HR and compliance are connected, in this changing regulatory environment, what does good look like? Very specifically, we’re gonna anchor, to the process of ongoing continuous license verification and monitoring for your licensed staff. This is a process that we have seen maybe three or four years ago. Don or Mike can help me out on this. We’ve seen was probably either housed in one place or the other or nowhere at all. As we’re seeing this today, what best looks like is where your HR and compliance functions are both both have a seat at the table of how do we do this really, really well, both from an an initial background check to credentialing, to continuous license verification and monitoring and making sure compliance and HR are both tied to that. It’s a people process, but there’s certainly compliance risk associated with not doing this well. And so I’m gonna take us really quickly through, the challenges and the questions for HR to consider. And then I’ll open it to Mike and Donna to explain sort of how we’ve seen this go well and what they see work well or not well from their perspective. The challenges associated with this process I’m gonna go quickly here. There’s about eighty eighty disciplines in health care that require a license or certification, respiratory therapists, registered nurse, and sort of everything in between. There’s over four thousand possible primary sources across the license and certification board. There’s variability that the primary source data and format require that makes this really challenging. Sometimes licenses are lumped together, sometimes they’re not. How they’re displayed very tactically primary sources of consideration. There’s latency in reporting disciplinary actions between individual, state licensing boards. Provider delays renewal means these things can expire. And there’s also nursing contacts as well, when we think about how that plays into the world. So there’s all of these variables that make this really challenging. And then the questions that we have here for HR to consider, are a few that I think are great prompts. And so if you’re at home following along and you’re in either HR compliance or this process is near and dear of something to check-in on, this is the screenshot slide that are that are are are, questions to answer, which are, do you have a centralized system, or could or could each license be stored in multiple places? What happens when an auger needs to verify a provider’s license? Where do you go? How is the status to play with regards to eligibility for scheduling? What happens when a name changes or a license is obtained? What other departments might also need to know the status of each license? And so there’s a couple of prompt questions to think and anchor you to some of the challenges, some of the next steps that I think are probably good takeaways. But for Donna and Mike, going back to the good, better, best scenario, can we apply good, better, best to this process? What does good look like for ongoing license verification? What does best in class look like for ongoing license monitoring and verification? And y’all’s thoughts. Donna, if you could kick us off, it’d be awesome. Yeah. Happy to. I I think, certainly, I mean, we all know. Right? We’re we’re always, validating a license upon hire. Right? That’s a foregone conclusion before someone comes to work in in our workforce. We have to make sure that they have a proper license to operate in this in the, state in which, you know, they’re performing their work in with whatever sorts of requirements that go with that, based on their specialty. Right? So, certainly, that I believe all of us would agree is a foregone conclusion. I think, it’s hard for me now to think about what good, better, best is because to me, of course, it it needs to be a certain way. But I think, good in my mind, it’s so hard because I I I feel like we should be looking at people’s licenses all the time, right, in order to make sure that they’re that they’re doing the right thing. So I think you could argue good is, gosh, if I just looked at it once a month to make sure it was still in good standing, nothing had changed, that would feel comfortable. Lots of organizations still today only look at their licenses upon renewal. They say my license expires one, you know, once one every year, every two years, typically. So thirty, sixty, ninety days before the expiration, I’m gonna take a peek at it, make sure it’s still in good standing, that everything’s still valid. I wouldn’t consider that good anymore. I I would say that the risk in that space is that any of those things, that that Dave talked about could have happened. Right? Something bad could have happened. The license could have gone from good standing to being, on probation, or there may have been a sanction against that license for some behavior that happened way in the past. Right? We know licensing boards take a very long time to complete their investigation as they should. Right? Due diligence is very appropriate. But that puts puts the provider at risk of of having someone, you know, on their floor that now has a probationary license that they don’t know anything about. We certainly all have policies and procedures that say, gosh. If something happens to your license, you have to notify us and tell us in HR. Tell us that my you know, your license has changed. But that doesn’t necessarily mean that people are gonna do that. So, I I again, I I’m not sure how to say what good, better, best is. To me, good is really routinely looking at your licenses and and making sure that, your folks are are properly credentialed in the role that they’re in at the time, right, to, to do the job that you’ve hired them to do. So I kinda went around about sorry, Dave. I don’t know how to how to put, variance into that. Yeah. Let me add to that, Donna, because I think you you you set it up really nicely. I mean, obviously, there’s different types of organization representatives on this call. I won’t even get into if you’re in the telehealth space, the newest addition to health care expansion, post COVID, I mean, it depends where the patient who’s calling in is calling from and whether the physician or practitioner or provider that’s responding is licensed in that state. So it can get really granular depending on what your business model is. But I think a couple of things I would give you as a check Number one, the job description that HR is responsible for, Donna mentioned, needs to be checked, monitored, updated to make sure things haven’t changed. So for example, if somebody is licensed as an RM and they have an, ACLS, but they don’t have, the certificate for PALS for, for pediatric, you can’t just grab them when staffing gets short and say, well, you’re on our end. Go go into the pediatric unit. They don’t they’re they’re not certified to work with kids. That’s a lawsuit waiting to happen. In the moment, God forbid, poor care is provided or something goes problematic, you’re not in a good place if you don’t have any centralized system to say, well, we should have never put nurse Judy there because she doesn’t have a POW certificate. So this thing gets real, real fast. One thing you so make sure job descriptions are updated. Make sure compliance is is aware of what the job description are when it comes to how staffing, is put in place. I would also suggest taking a look at your vendor contracts. If you use a staffing agency to supplement your work or CNRA or traveling nurses, make sure that you’ve bulked up your vendor contract that that puts the liability on them to tell you that person is licensed, that they should be monitoring them, that they’re assuring you that person is not excluded or they’re not gonna send them your way. Though, if you don’t have those contractual provisions, the the nurse, him or herself, is gonna just flee the coop once the when once the problem hits. And now it’s between you, a regulator, and your vendor as to who should be really responsible. So there’s some things you can do in your contracts to to shore up your liability. And and who’s tracking the law changes? Look what’s happened with COVID where there’s been this expansion of an emergency order. There were several states that, said, look. If your license is due to expire, we’re gonna extend it for six more months because we we, the licensing board, don’t have time to get through all these applications. If you don’t know that, are you terminating somebody unlawfully because their license didn’t renew and they literally have applied on time but are waiting for the state? Or, or what laws that require a different type of certification have taken place is compliance telling HR you need to update your job description because something changed in Alabama. What do you do at a name change? If HR is is if the HRIS system is aware that Donna Thiele was Donna Smith or got married this weekend and changed to Donna Smith, but compliance doesn’t know and your systems aren’t talking to each other, you’re monitoring the old name. Out you’re monitoring the wrong license. And there it is of record. It’s in your HRIS, but two systems are not talking to each other. And then as Donna mentioned, you know, what we find for the the few bad actors that are in health care, and and thankfully it is few, percentage wise, they’re not stupid. They they they run into issues. Mostly, it’s drug addiction or other problems of that nature. They’re feeding their habit, their theft or otherwise. They get in trouble in Iowa. They know it’s gonna take nine months for Iowa to go through the disciplinary action. Action. I think we have a timeline to show you an example. So they hop over to Tennessee. Tennessee says, oh, great. You’re a nurse in Iowa. You’re currently in good standing. Come on. We’ve got a shortage here. And now you’re working at a new employer here. You’re not going to tell the new employer when Iowa sanctions you. And now the new employer is liable because they didn’t know what happened potentially in another state. So this is where HR and noncompliance, when it comes to license, have got to work together to be better. And, we we wanna show a very specific example of something real that we saw in our universe as well. So, Donna, I’d love if you could take us through you know, as we think about interstate licensure and monitoring a mobile workforce, this is this is a real problem that we interact with and see in our world all the time. It’s a perfect example of how when this process is connected, between a really healthy HR and compliance, joint effort, how you can answer yes to the question at bottom. But, Donna, I’d love if you could I’d love if you could walk us through this. Yeah. Happy to. And as Dave said, this this is not fictitious. This is, a real example of a practitioner. So they’re with provider x. There’s an allegation of theft of money from a patient that happens. That organization terminates that person and reports them to the licensing board. In this, example, it takes the licensing board a year, to initiate, an initial administrative action against that person. And as part of their process, the practitioner has thirty days to, refute or rebut, make, a a case, for that. And in this particular situation, the practitioner did not, have a defense. And so at that point in time, the board concluded their investigation and revoked their license. Something we really haven’t talked about is that the OIG, the office of inspector general, has the authority, the premise of authority, to exclude someone based upon a license revocation. Permissive authority and made permissive authority and made the decision to exclude the person. Now you’ll notice that took seven months, right, for that to happen. So for seven months, I didn’t have a license, but I was still not excluded. And, if you know very much about, you know, the OIG and exclusions, you know that Sam, generally speaking, has a reciprocal exclusion that comes about right after, the OIG excludes you. And in this scenario, during this course of time, after the person got excluded, they changed their name. They might have gotten married. They might have gotten divorced. They may have chosen to change their name. Who knows? Right? But they changed their name. They moved to a different state. And in this time period, they were issued a new license in the new state just like what Mike was referring to. And fortunately or unfortunately, the the last bullet of this slide, the next part of the story is and then the new employer that, hired this practitioner with the new name and the new license, when they were, you know, brought into the system and started monitoring them, found out that there you know, this particular person was actually excluded under a different name and had a license that was revoked in another state. And so this, unfortunately, is a story that we see in, in the movement of of bad actors, as Mike would say, in a really great place where HR and compliance are absolutely collaborating to make sure that as folks are coming into their organization and the journey of their, employment with you, that you’re continuously making sure the information that you have tied to a person is accurate and up to date and that you are consistently looking at a license and making sure that everything’s in good standing. Same with the, exclusion monitoring as well. That’s well that’s well said. And what I would say is over over time as this process is maturing license monitoring and that the ongoing continuous daily license verification so that you know every day when you come to work that your practitioners have a valid up to date license in whatever state is is an emerging and growing trend in health care that we see. That frequency of monitoring is a big deal. And I think the question in the bottom you know, this is a slide from a year or so ago, but the when you catch it is for sure a couple years ago, it was a would you ever know? And now I think it’s it’s emerging into this and how long would it actually take you before you caught it too? And what we’re seeing is that best in this scenario is you catch it almost immediately if you have a really good monitoring solution and a connected HR company. You know? And and, you know, not good enough. On the other end of the spectrum is if it takes six months to catch, and then, you know, all of the the risks to patient safety, to quality, certainly, there’s a financial and a risk component in there as well, is if you have a license monitoring process right now that is not good enough and it takes you three, six, nine, twelve months to catch this potential issue, that represents a real risk to trust of your health system and trust of your process, and certainly all the way back to trust between HR and compliance. I think it’s a really good example of it’s a good time to reevaluate something like this as a foundational element of the seven elements of of building an effective compliance program. It’s a good time to to think through just just how good are we at this, because I think it’s it’s it it will it will speak volumes to how connected HR and compliance really truly are. Dave, one other thing. Go ahead. Yeah. One other, if I could. Just from this timeline, from January two thousand eighteen forward, any, reimbursement that you receive by federal health care dollars, CMS, Medicaid, Medicare, CHIPS, TRICARE, or even under your contracts with any of the, payers. Right? Blue Cross, United Cigna. You’ve got a contract provision that says you wouldn’t put that person out in the workforce. They’re going the OIG will fine you, but you also potentially have false claims. So where this really comes to matter are when you have billable people such as therapists, people that bill by the day, by the patient, and it’s trackable. These fines add up tremendously fast and, is not where you wanna have certainly HR and compliance that have never coordinated before are faced with a real problem, potentially a regulator bringing it to the company. And now you have two dual departments that are trying to jockey or figure out what happened and let alone determine who should respond. That is not where you that’s not when you wanna be in that situation. So we always like to set up kind of what’s out there with keys to success. Right, Dave? And I hope we can leave you with some positive, things to go out, check, and do, because we don’t wanna leave you with with with a problem without answers. Donna, what what would you say some of the keys to success for the people that are listening today that are trying to coordinate these two or these two departments? Certainly, I think taking all the things that we’ve just been talking about. Right? It’s it’s absolutely looking at your current processes. Like, how do I reach across the the table? How are HR and compliance, you know, partnering? Are we partnering? First, ask yourself, like, what is a good cadence? I’ve I’ve seen a couple of really great questions down here about, like, you know, what should HR do or what, should compliance do? And that’s the most important thing. Right? As you’re looking at how are we gonna be successful, take a pause. Sit down and ask yourself, in my organization, what hat do I have and what hat do you have? Where should we be collaborating versus being in silos? Where can we work together? What should we be communicating on a routine basis back and forth? Right? Do we have risk? We’ve just talked about licenses and exclusion monitoring. And it’s just one example. We’ve talked about onboarding new employees. Someone asked a question about what should compliance and HR do as it relates to temporary agency nursing and certified nursing aids coming on board. Sit down and ask yourself those questions. Like, what are the regulations, and does HR understand the the why? I had the opportunity of sitting with, a whole group of HR professionals of one of our clients a while back. And and my job when I went to meet with them was to teach them what compliance meant and why license monitoring mattered and what it meant on the HR side and why compliance cared so much. So just sit down and and take some time and evaluate how you wanna partner together. I really believe that’s the way to start. Thanks, Donna. We are so there’s a couple of things left in our last two minutes, as we close out here is, one, we’re gonna leave you you will get a copy of these slides, as a as a thank you for joining on today. There are three slides here that are essentially check lists. One is what you see on the screen, evaluate your current process for license monitoring and a checklist on how to do so. The second, which, we’ll go through right now, is is a really quick plan for collaboration, which echoes what Donna said. And the last piece is as you’re thinking through collaboration as well, considering what needs to happen initial versus ongoing, what needs to happen today versus what needs to happen on an ongoing continuous basis as well. So we’re leaving you with all three of these things as essentially a playbook to say, here’s a here’s a couple of things you can do to connect HR and compliance. We did not get a chance to hit every single question. There was a ton of good questions that came in. We were gonna make sure that those get, followed up on and get the answers, or at least we get them routed to Mike and Donna, after the webinar today. We touched on as many as we could, but, frankly, the engagement was amazing. So we’ve got we’ve got more than we could possibly answer in the last hour. The last thing I would say, as we close this out here is, would encourage you all to browse the library on provider trips dot dot com. Click on resources at the top. We have ready to go checklists on how to evaluate these processes. We are we are considered thought leaders in this space as it relates to not just connecting HR and compliance in the theoretical, but in the practical on how this can how you can really connect data, processes, and eliminate your risk in doing so. And so, we’d love to learn a little bit more from each of you. And if you’re interested in learning more from us, that’s a great place to start is the library on provider trust dot com. And with that, we are all done. I am grateful y’all chose to spend an hour with us today. Again, you’ll get the recording and some follow ups from us, following the session. But a special thank you to Mike and Madonna for their time today and sharing their expertise on on what we believe is a critical piece of health care moving forward.