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Healthcare Compliance Faces a Complicated Future

As the healthcare landscape continues to shift and evolve, the role of its compliance professionals will be adapting and changing as well. For instance, as healthcare moves away from being entirely hospital based, care types and payment structures will take up more and more of their time.

That’s the perspective of Sheryl Vacca, Senior Vice President and Chief Risk Officer at Providence St. Joseph Health, a $24-billion company with 130,000 caregivers in seven states. Vacca, who began her healthcare career as a nurse at the bedside, now handles oversight for compliance, audit, risk management, and information security.

“What used to be hospital-based services are [going] to lose some of the payment,” Vacca says “Our payers are saying, ‘Enough! Hospitals are costing us too much money. We need to focus on how to deliver care differently.’ Even CMS is changing what will be paid for in the hospital vs. outpatient. They’re setting incentives for providers to go outpatient, and some contracts right now are really draconian. From a perspective of going forward in compliance, it’s going be critical to understand that we are really going to be driven in a different way than what we have in the past.”

“Our revenue streams are not necessarily coming from our hospital-based services anymore,” she continues. “Everyone views those as costly. Look at the ambulatory setting and the growth in ambulatory surgeries and the growth in urgent cares. There are standalone ERs that are able to say because of the kind of facility they are: ‘We will take no Medicare or Medicaid patients.’ And so, it’s profit only. I think there will be more and more of that as we go forward. There’s this balance of needing to care for our communities, and then needing to be able to pay our way so that we will be here to be able to provide services.”

Maintaining compliance as rules and regulations change

The compliance professional will be challenged in all settings because the risks are changing, Vacca notes. Organizations are being forced to innovate faster than they’d like, especially in the often-slow-moving healthcare world, and that means compliance also is moving at a speed that will seem overwhelming at times.

“You have to keep in mind that even though we are moving to outpatient services, some of those are still based on the hospital license,” Vacca explains. “We still have requirements that are applicable that we need to make sure apply—The old-school, hospital JCAHO and all the other surveys that relate to our hospital orientation. Most people who have been in hospitals understand that. We know why it’s happening. We know what we need to do in our culture. But when you move further away from that setting the odds of compliance can go down because a different group of compliance requirements that might apply.”

There will also be compliance situations where the regulatory aspects haven’t caught up to the physical situation. When that happens, Vacca says, the need will be to create consistent standards based on what’s already in place so that proper patient care continues unchanged.

“Do we really have to partner with all of our different risk aspects? The patient care provider, the legal team, audit, compliance? We’re not going be able to be siloed anymore and say, ‘Well, I understand this particular regulation. This is what you must do.’ It really will be us coming together as a team in identifying what the risk is. Is it compliance? Is it legal? Is it reputational? Is it patient care? Then we have to work toward a solution.”

This blog post is taken from a HealthStream Second Opinions Podcast that was recorded recently. To hear Vacca’s full discussion, click here.

About Sheryl Vacca:

Healthcare compliance expert Sheryl Vacca is Senior Vice President and Chief Risk Officer at Providence St. Joseph Health, a $24-billion company with 130,000 caregivers in seven states. Her responsibilities include oversight for compliance, audit, risk management, and information security. Most recently, she served as the system-wide senior vice president for chief compliance and audit officer at the University of California. Vacca has received awards from the Society of Corporate Compliance and Ethics (SCCE) and the Health Care Compliance Association (HCCA).

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