December 16, 2022
Community Care of the Lower Cape Fear (CCLCF) provides community-based care management services, population health management, and practice transformation support for patients and providers across southeastern North Carolina. With a history of “meeting patients where they are at” to address personal, structural, and socio-economic barriers to healthier outcomes, CCLCF was selected as one of three Network Leads to oversee the administration of North Carolina’s innovative Healthy Opportunities Pilot.
The Opportunity
We can’t overstress the importance of information when it comes to providing the right care, for the right patient, at the right time and place. But ensuring that an organization has the right (and interoperable) technology tools and platforms is only the first part of the problem. Next, you must make sure that there is a system to ensure that those tools and processes are securely used in the correct, secure manner, ensuring their confidentiality. That is the role of an organization’s compliance operations and compliance officer.
Goals
As CCLCF adapted to growth with Medicaid Practice Transformation on the horizon, CCLCF tasked Atrómitos with evaluating its privacy and security policies and procedures, identifying areas for expanded investment or updates, and then serve as a resource for the newly recruited Compliance Officer.
Approach
Gap Analysis
The first step in any compliance operation is to conduct a complete inventory of assets, threats, and vulnerabilities. Next, we reviewed all information security, administrative, and privacy policies and provided leadership with a gap analysis for updated policies and controls. We cross-walked this against the OIG’s 7 elements of an effective compliance plan. We developed a work plan for updating policies to ensure conformity with stringent privacy and information security requirements for managed care organizations.
The Gap Analysis and subsequent work plan allowed a visual presentation of activities by category (types of resources or action required), timeline, and comparative prioritization.
Capacity Development and Compliance Investigations
Results
With the support of Atrómitos, CCLCF successfully:
Recruited and trained a new compliance officer
- Created onboarding training for the new compliance officer and held touch-ins every two weeks to field and troubleshoot operational questions as the officer grew into the role
- Completed readiness review approval with all contracted Prepaid Health Plans
- Resolved complex questions around patient communication protocols, enabling expanded use of texting with patient authorization workflows
Conclusion
A year after the institution of CCLCF’s new compliance officer, CCLCF’s compliance program and its compliance officer served as the foundation for the data privacy and security protocols for CCLCF’s Healthy Opportunities Pilot.
