the new era of transparency - national pace association...issues of non-compliance. •describe the...

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The New Era of Transparency PACE Audit Process and Data Request

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Page 1: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

The New Era of Transparency

PACE Audit Process and Data Request

Page 2: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance
Page 3: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

Learning Objectives

• Describe the role transparency plays in the PACE Audit Process and Data Request.

• Increase knowledge and application of the Pre-Audit Disclosed Issues of Non-Compliance.

• Describe the role transparency plays in Compliance Programs and Quality Assessment Performance Improvement.

• How to use Strategic Thinking in the identification of issues regarding transparency and disclosure.

• Define the Seven Steps of Problem Solving and its use during the PACE Audit Process and Data Request.

Page 4: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

Historical PerspectiveMitch Leupp Executive Director Northland PACE

• Transparency Organizational Cultural Beliefs in Healthcare

• Institute of Medicine reports

• To Err is Human – 1999

• Crossing the Quality Chasm – 2001

• SHINING A LIGHT Safer Health Care Through Transparency-The National Patient Safety Foundation’s Lucian Leape Institute - 2015

• Role of Transparency in PAST CMS Audit Protocols

• Clear changes with audit process in 2017 for PACE programs in regard to transparency as we provide CMS with much more information pre-audit.

• Self disclosure

• Inducement for PACE programs to provide high quality care

“Take the long way. Do the hard work, consistently and with generosity and transparency. And then you won’t waste time doing it over.” ~ Seth Godin, Author

Page 5: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

Defining Transparency

Lack of hidden agendas and conditions, accompanied by the availability of full information required for:

• Collaboration

• Cooperation

• Collective Decision Making

trans· par· en· cy

Page 6: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

Defining Transparency: Breaking It Down

Lack of hidden agendas and conditions, accompanied by the availability of full information….

PACE Audit and Data Request• Audit Purpose and General Guidelines

• Universes

• Tables: SDR, AR, GR, LOP, LOPMR, QAIR and OCU

• Supplemental Data

• Supplemental Questions; Pre-Audit Disclosed Issues of Non-Compliance, QAPI Plan and PAC Minutes

• Audit Elements

• Sampling, Sampling Review, Application of Compliance Standard

trans· par· en· cy

Page 7: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

Defining Transparency: Breaking It Down

….collaboration, cooperation, and collective decision making.

• PACE Audit and Data Request

• Audit Purpose and General Guidelines

• Universes

• Tables: SDR, AR, GR, LOP, LOPMR, QAIR and OCU

• Supplemental Data

• Supplemental Questions; Pre-Audit Disclosed Issues of Non-Compliance, QAPI Plan and PAC Minutes

• Audit Elements

• Sampling, Sampling Review, Application of Compliance Standard

trans· par· en· cy

Page 8: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

Pre-Audit Disclosed Issues of Non-Compliance

• Table Contents

• Key Elements to Consider

• PACE Organizational Use

Page 9: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

Strategic Thinking

Expanding Capacity to Think and Act Strategically

“The significant problems we face cannot be solved at the same level of thinking we were at when we created them.” ~Albert Einstein

Problem Solving and Decision Making Process

The Seven Steps of Problem Solving

Page 10: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

Defining Strategic Thinking

Strategic Thinking

What seems to be happening?

What range of possibilities do we face?

What are we going to do?

Good managers have a good sense ofwhere they are going…or at least ofwhere they are trying to go. They areconstantly looking for ideas about howto get there. They know that theyhave no monopoly on good ideas abouthow to accomplish their purposes.Thus, given their bias for action, theyspend less time analyzing these ideasthan experimenting with them.

Robert D. Behn

Leadership Counts.

Page 11: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

Defining Problem Solving

• Problem Solving-A process of eliminating or reducing the causes or potential causes of performance deficiencies that interfere with productive functioning of an organization.

• Decision Making-The process of selecting between alternative courses of action. Decisions are the logical outcome of problem solving.

Page 12: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

Problem Solving

Page 13: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

Problem Solving: Finding the Problem

• Define the Problem• Why

• How

• Tips

• Analyze Potential Causes• Why

• How

• Tips “A problem well defined is a problem half-solved.” ~John Dewey, American Philosopher and Educator

Page 14: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

Problem Solving: Decision Making

• Identify Alternative Solutions

• Why

• How

• Tips

• Select the Best Solution

• Why

• How

• Tips

“There are few things as useless---if not as dangerous---as the right answer to the wrong question”

Peter F. Drucker, Father of Modern Management

Page 15: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

Decision Making: Solution Matrix

Criteria Solution One Solution Two Solution Three

Cost

Time

Ease of Implementation

Degree of Risk

Degree of Resistance or Acceptance

Probability of Success

Page 16: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

Decision Making: Solution Matrix

Criteria Solution One: Revise policy to be inclusive of regulatory and table requirements creating a work around within the confines of our EMR capabilities.

Cost Human Resource Costs

Time In person assessment; Documentation; IDT Review; Monitoring/Auditing

Ease of Implementation

Complicated Process Steps; Multiple Regulatory Domains Impacted

Degree of Risk High

Degree of Resistance or Acceptance

Moderate

Probability of Success

Moderate

Page 17: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

Problem Solving: Taking Action

• Develop Action and Contingency Plans

• Why

• How

• Tips

• Implement the Solution

• Why

• How

• Tips

Page 18: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance
Page 19: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

The Hangover Cast 2009

Page 20: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

Problem Solving: Taking Action

• Evaluate Progress

• Why?

• How?

• Tips

“They always saytime changes things,but you actually haveto change them yourself.”

~Andy Warhol

Page 21: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance
Page 22: The New Era of Transparency - National PACE Association...Issues of Non-Compliance. •Describe the role transparency plays in Compliance Programs and Quality Assessment Performance

Questions?

Comments?

Amy Ruff, QA [email protected]

Mitch Leupp, Executive [email protected]