A Holistic Approach to Healthcare Compliance

Amy Mallery Rhone is the VP of Corporate Compliance at Bassett Healthcare Network. She has been in the healthcare industry for 25 years and is experienced in the compliance field for 20 years. With her extensive operational experience, she has successfully carried out a variety operational roles. In an exclusive interview Healthcare Compliance 2023, Amy Mallery Rhone shares her valuable insights on healthcare compliance and the operational aspect of healthcare.

COULD YOU EXPLAIN YOUR KEY ROLES AND RESPONSIBILITIES IN BASSETT HEALTHCARE NETWORK AS THE VP OF CORPORATE COMPLIANCE?

Throughout my healthcare journey, as I have taken time to understand the business and operations aspects of healthcare and my approach to topics associated with compliance is different. While I do focus on the rules and regulations, I also focus on the operational impact and examine how compliance affects patients. This is a holistic approach to addressing an issue, which is the approach I take towards my work.

I am experienced in not-for-profit and for-profit facets of healthcare. I was also the vice president for a compliance program with the Aspen Group, a business support organization in the industry. I spent some time in the for-profit, private equity backed industry. Currently, I am at Bassett Healthcare Network and I am a Chief Compliance Officer and am the vice president for corporate compliance.

I also have my own compliance services consulting business. I am the owner and operator of that establishment. I have been with Bassett with almost a year now, where I leverage my 25 years of experience from other industries.

CAN YOU TALK ABOUT SOME OF THE CHALLENGES THAT YOU HAVE COME ACROSS IN HEALTHCARE COMPLIANCE?

When I started working in healthcare compliance, the concept of a compliance program was unclear. We adhered to OIG compliance program guidelines and eventually, also to the federal sentencing guidelines.

Recently, we started looking specifically into regulators’ expectations in a compliance program, and that has been a journey for the compliance industry. We started with guidance, moved on to corporate integrity agreement, and then looked at different recommendations from advisors in the industry.

In New York State, compliance programs are mandatory for certain types of providers in the healthcare industry and hence, the state saw specificity around it. There are clear expectations from a regulatory perspective, on what effective compliance programs look like.

In the compliance professional, you should always remember which organization you’re trying to service and who the supporting people in your community are, and ultimately, you end up dedicating yourself to the industry.

People in the industry either love the compliance field and are passionate about their job or they leave because it’s not for them. People in the compliance field who are familiar with compliance programs have a different appreciation for what individuals within the healthcare industry are going through. As a compliance professional myself, at times I find it hard to navigate through the landscape because every year, just like the healthcare industry, we are asked to do more with less.

For example, we are facing significant staffing shortages. Through staffing issues were prominent before the pandemic, COVID added another layer to staffing shortages. Balancing this can be a struggle. As compliance officers, we have to build relationships to help solve this problem. We build relationships internally through our organization, but we also build relationships within the industry and find the right partners to help us focus on specific issues and problem solve them. Building additional resources outside of the organization is crucial to thrive in the industry. 

In the context of staffing shortages, declining revenue, and sick patients, compliance officers have to focus on the particular risk profiles for each organization, and how they are going to prioritize that effort. 

A compliance officer is responsible for the day-today operations of a compliance program, but at the same time, you need to be able to educate and hold leaders accountable for understanding their role, as compliance is a shared responsibility. You have to dedicate yourself and your data finding time to find time to do things that you really need to be going on day-to-day bases to ensure you have a compliance program that is effective.

When you’re building compliance programs, you’re gaining contacts from patients, staff members, regulators, who ask questions, need assistance, and report their concerns. In such scenarios, you have to shift your attention between problem solving, root cause analysis, enhancing workflows, drafting policies, which is why the industry is complicated, as it’s hard for one person to know all rules and regulations. For these reasons, it’s important to have effective training programs and we’re holding individual counseling throughout the organization, as the compliance officer alone cannot do everything.

As a compliance officer, I spend time listening, researching, and understanding the healthcare industry to realize its view after May 11th, and how it relates to billing services compliantly, at the state and federal level. Right now, we are faced with the shifting evolution of healthcare, but it’s more agile and innovative now than it has ever been and we can now get more access to care for patients.

Are there any recent projects that you have been working on to create remarkable patient experience? If yes, what are some of the process elements that you have been leveraging to make that project successful?

At Bassett, I have had the privilege to be a participant in our innovation committee. It observes variety of upcoming or established technologies in different innovations within the healthcare industry. We take a methodical approach to evaluating innovation strategies that helps enhance patient care, while simultaneously, easing the process of practicing for practitioners.

It’s a role I have been encouraged to take by my colleagues at Bassett and I’m grateful that the value in compliance is prominent. The innovation committee and I work collaboratively and approach healthcare compliance differently, with a shared commitment to getting it right the first time.

We undertake a comprehensive assessment of potential compliance risks before progressing too far into any project. We recognize that such an approach is vital in ensuring that our innovative ideas successfully contribute to the healthcare industry, without being encumbered by unforeseen compliance concerns.

We are evaluating innovative solutions in the market that enhance patient care and the way our practitioners practice, and we are looking at it through the lens of compliance, analyzing potential risks and looking for ways to mitigate them. This is an efficient approach and it is a testament to our chief innovation officer, who is committed to ensuring these methods are implemented.

WHAT WOULD BE YOUR ADVICE TO THE FELLOW PEERS IN THE INDUSTRY?

When you are in the compliance field, you have to get back to basics periodically and prioritize what is important. Compliance officers are challenged on a day-to-day basis with an influx of information coming in daily. Some data is little and some are big, and in such scenarios when we get back to the basics, it’s easy for compliance programs to be effective.

My strategy always, whether it’s an organization I’m familiar with or uncharted territories, is to understand the basics and holding methods that are tried and true. Else, we can get caught up in a variety of topics and the implementation of compliance programs is neglected.