Staff Structure Support HCCA Special Interest Group 1-28-03 New Regulations: A Strategy for...
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Transcript of Staff Structure Support HCCA Special Interest Group 1-28-03 New Regulations: A Strategy for...
Staff
Structure
Support
HCCA Special Interest Group
1-28-03
New Regulations: A Strategy for
Implementation
Sharon SchmidVice President, Compliance and
PrivacyMedica
Multiple Levels of Obligations Multiple States’ Regulations Overlapping State and Federal Regulation
DOL ERISA Regulations Privacy (GLB, HIPAA, Federal Privacy Act, State Law,
NCQA) Accreditation Requirements
Type of Regulation Governs the Core of What We Do
Volume and Complexity of Obligations
Governing Standards Framework:
Challenges for Implementation
– Develop Method to Help Ensure Obligations Come to Life in the Business
– Risk Based Approach to Implementation and Ongoing Compliance• Assess• Prioritize• Resource
– Compliance Project Management (“CPM”)• Manage the Complexity• Builds it into the Core of What We Do
Implementation Process
– Builds on Traditional Project Management Practices - Adapted to Manage and Minimize Compliance Risk
– Defined Analytical and Implementation Processes that Support: Identify Implement
Assess Monitoring
Plan Audit
What is Project Management For
Compliance?
Document
– Central Oversight With Identified Compliance Staff in All Business Units - Departments
• Shared Accountability for Compliance and Business Ensures Compliance Expertise and Strong Understanding of Business
– Process and Structure to Support Consistent, Documented, Completed Implementation
– Tools and Training
– Ongoing Support and Training
What Makes CPM Successful
What are the Elements of Compliance Project
Management?• Understand the Legal/Regulatory/Governance Requirements
• Identify and Assess Current Business Practices
• Identify Operational Gaps
• Develop a Documented Action Plan
• Implement the Plan and Document the Implementation Activities
• Monitor the Results of the Implementation
• Document “How We Know” We Are in Compliance
How Will Compliance Project Management Help Us Reach
Our Goal?• Compliance Project Management Helps to
Identify and Minimize Legal Risk
• Develops Consistency In Approach and Implementation
• Documents Work To Support Compliance
• Builds on Expertise of All Staff from all business areas
• Enhances Communication
• Creates Institutional Memory
The Higher the Level of Risk, As Determined by the “As-is” Assessment, the Greater the Need for
Compliance Project Management
Greater need for CPM
Why Might You Want to Use The Project Management
Approach?
Compliance Operations Project Management Phases
Intake
Assessment
Implementation Planning
Implementation
Post Implementation Management
How Does Compliance Project Management Help
Manage Risk?
Intake
Assessment
Planning
Implementation
PostImplementationManagement
RiskProject Phases
A Key Step in Any Compliance Effort - Whether It Is a
Relatively Simple or Complex Obligation - Is
Understanding, Defining, and Documenting the
Issue.
Key Tasks for Intake Identify the “Obligation”
Initial Legal Analysis
Intake Information Completed - Including Obligation Summary
Intake Phase
Compliance Project Life Cycle - Compliance Project Life Cycle - Intake in DetailIntake in Detail
Com
pete
ncy
Com
pete
ncy E
xit
Exit
C
rite
ria
Cri
teri
aT
ask
sT
ask
s
IntakeIntake
Identify obligation Conduct initial legal analysis Notify compliance operations of new obligation Review legal analysis, enter obligation information in CPM, link relevant documentation Conduct initial triage assessment and notify CO leads to conduct operational assessment
Required information completed in CPM and Compliance Operations notified CO staff complete Archive Summary, if applicable
Compliance OperationsCompliance Operations
LegLegalal
Business Business OperationsOperationsSteering CouncilSteering Council
Deli
vera
ble
sD
eli
vera
ble
s
Documented legal analysis Completed Intake information in CPM including Obligation Summary Linked documentation in System An Archive Report, if no further action is necessary
Ph
ase
Ph
ase
The Operational Assessment Is a Review of Business Operations Against the Requirements of the Obligation
Compliance Ops Leads Conduct Operational Assessment online:
Products Processes Departments Vendors Background/History Connections Current Business Practices Recommendations
Assessment Phase
Assessment Summary Report
The Assessment Summary Report Is a Compilation of All of the Information Entered As Part of the Operational Assessment
•This Report Can Be Invaluable for Focusing Resources and Expertise
•Helps to Identify Specific Action Steps or Tasks for Implementation.
•In Some Instances, the Assessment Summary Report Will Reflect That the Organization Is Already in Compliance With the Obligation’s Requirements and Will Provide the Necessary Information for Documenting Our Compliance.
Planning
In the Planning Phase, the Project Manager Develops a Detailed Action Plan To:
•Create the Right Solution for Compliance and Business
•Establish Communication About Implementation
•Foster Involvement of Team and Key Stakeholders
Review the Assessment Summary Report
Develop the Action Plan
Identify Team Members and Key Stakeholders
Schedule and Hold the Kickoff Meeting With the Project Team
Document Additional Tasks Based on Team Members Participation
Obtain Stakeholder Input for Plan
Define the Communication Protocols
Planning Phase Key Tasks
The Purpose of the Implementation Phase Is to Perform, Monitor, and Control Project Work So That You Can Complete the Project on Schedule and Within Defined Quality Standards.
In This Phase, Staff Implement and Manage Against the Action Plan, Making Enhancements and Changes to the Action Plan As Necessary to Accomplish the Project Goal(s).
Implementation Phase
Implement Project Plan
Communicate Status to Team Members and
Stakeholders
Status Updates in Application
Training As Needed
Manage Project Changes as Needed
Escalate Barriers for Resolution
Summarize Compliance
Implementation Phase Key Tasks
The Purpose of the Post Implementation Management Phase Is to Complete Commitments, Check the Success of the Implementation, Plan for Transitions, Conduct Evaluations, and Identify Lessons Learned That Can Be Carried Forward to Future Projects
Post Implementation Management Phase
Project Manager Ensures Project Documentation is
Completed and Linked to Obligation in Application
-Action Plan and Supporting Documentation
-Policies and Procedures, training, process
documentation, etc.
Post Implementation Evaluation
Monitoring Activities Completed According to
Action Plan and Ongoing As Necessary
Post Implementation Management Key Tasks
Compliance Project Management Supports Effective Compliance
Identify and Minimize Legal Risk
Develops Consistency In Effective Approach For Implementation
Documents Work To Support Compliance
Builds on Expertise of All Staff
Enhances Communication
Creates Institutional Memory