Taylor sat down at her desk, frustrated by the events of the past hour. She had met with her director a week ago. They had talked about the project he was assigning to her and what he wanted her to create. Now, he seemed to have a completely different set of expectations. The goals were different. The presentation was going to be for a different audience. She was no longer certain where to begin. This was not the first time that her boss had confused her and her colleagues. There seemed to be different rules for different people who reported to him. Some individuals appeared to be treated with more leeway than others. Rules changed from week to week, and expectations were only moderately consistent.
Unfortunately, Taylor is not alone in her frustration. Healthcare is an ever-evolving industry, and without careful consideration for the people who work on our teams, it can be easy for leaders like Taylor’s director to bend to the needs of their own leaders and leave their direct reports confused and frustrated.
People want to know the boundaries of their roles. They want to meet or exceed expectations, which is one reason we have policies and procedures. Written guidelines help employees and leaders throughout the organization know where the limits are, which limits can be pushed, what the laws require, and how the norms for the system or practice are applied.
Without policies and procedures, employees become unclear about how their jobs should be performed, and the practice risks violating federal, state, and local regulations. The following 5 primary areas are issues that practice managers and other healthcare leaders can focus on as they create new policies and procedures or validate that existing policies and procedures cover foundational needs.
1. Human Resources Policies
Most policies are created to ensure that our employees experience consistency and repetition. Leaders need to be able to replicate what is done for one individual with others.
Consistency eliminates the likelihood, and reduces the perception, that there is discrimination or preference in the treatment of individuals. Human brains pick up on a lack of fairness quickly.
Some of the human resources processes to include are:
- Hiring processes: Where do you post new positions? How long does someone need to stay in 1 position before they can apply for another? Can positions be designated for a single individual or do you always ensure there are multiple applicants? Does the posting get published somewhere or does an employee need to have inside knowledge?
- Entering time on the clock: What is required? How late is late? Is clocking out required for meals and/or breaks?
- Corrective action: What does the escalation of corrective action look like? Can individuals be fired for a first offense? When is a performance improvement plan warranted?
- Financial compensation: How often are wages reviewed? How are raises calculated? How are bonuses determined? How is personal time off or vacation time distributed?
2. Front Office Policies
Front office policies allow organizations to be consistent with employees and with patients. Having clear expectations regarding how much demographic and insurance information is collected from each patient and what needs to be collected prior to the visit is important because it allows us to be clear with our patients and their families. The policy should include what action the front office will take if the patient does not have their complete information and whether the patient can be seen for their visit.
Other policies related to the front office include how to handle last minute cancellations and patients who do not show up for their appointments.
If the practice site collects cash or processes payments, it is critical to have clear policies about cash counting and reconciliation, storing the cash, and depositing it at the bank. Unfortunately, some individuals may be tempted to “borrow” money from a cash drawer if processes to deter these actions are not in place.
3. Revenue Cycle Policies
Because the revenue cycle is critical to the ongoing operations of a healthcare organization, it is essential to ensure that the policies and procedures related to the revenue cycle are captured in writing and understood by all employees. It is important to make certain that expected timelines are documented: How quickly are charges entered? How are missing charges identified? What is the escalation process when charges are missing? What is the follow-up process to ensure that all claims are paid?
In addition to timely capture of charges to keep the revenue cycle moving, it is important that all payer and government guidelines are followed. Document who can add missing charges or change diagnosis or procedure codes and under what circumstances.
4. Clinical Policies
As with revenue cycle policies, clinical policies often describe how the practice upholds federal, state, and local laws. In the clinical realm, policies designate how team members and providers can and cannot interact with patients. Most states have specific regulations for individuals who have received clinical licenses or certifications. Although each professional category is likely to have a scope of practice, this is not always the case. Know what is required in your state and ensure that your physicians, advanced practitioners, and clinical staff are aware of what each individual can and cannot do.
Areas in which your practice may consider creating clinical policies include medication refills and renewals; storage and dispensing of sample medications; medication administration; and infection control and prevention.
5. Health Information Management Policies
Another category of policies that is dependent on legislation is Health Information Management (HIM). Medical organizations handle a lot of sensitive information, and whereas electronic health records provide significant benefits, they also make information more accessible. It is important to ensure that HIM policies are well understood by your staff, including how the Health Insurance Portability and Accountability Act and the Health Information Technology for Economic and Clinical Health Act of 2009 apply to their workflows.
When it comes to HIM, a good frame of reference is “just because you can, doesn’t mean that you should.” Very little in electronic health records prohibit an employee from accessing information that they should not access. It is necessary to have policies and procedures to audit compliance and initiate corrective action when necessary.
We also have to be aware of external threats. Bad players are looking to steal identities and submit false claims, and these can slow healthcare operations. Freezing an organization’s electronic operations while it is being held for ransom is no longer just a myth or something that happens in the movies.
Some of the specific HIM policies to include define where data is stored, how it is accessed, what to do during downtime, how to come back up from downtime, and how often systems are updated.
Managing Policies
It can be daunting to think about all of the policies that are necessary when managing a healthcare organization. Working through each category of policies can guide a new practice in its endeavor. It is important to remember that not every policy captures every situation, so policies will need to be managed throughout the life of a healthcare organization. An overarching “policy on policies” is a useful reference that outlines where policies are stored, how often each policy is reviewed and what the review process looks like, and how changes are communicated throughout the organization.
Employees want to know what is expected of them. They want to understand the rules and guidelines. When every employee understands how they are supposed to carry out their daily routines, that builds a more unified, trusting culture. Through strong, trusting cultures, healthcare organizations are able to take better care of patients—which is what it’s all about.
