By Frank Ruelas
Facility Compliance Professional, St. Joseph’s Hospital and Medical Center/Dignity Health
Whenever I hear someone offer, let’s get back to basics it gives me pause to wonder. Of course I am not saying this applies to all situations, but when I do encounter this phrase I have noticed a distinct trend or theme, especially when it comes to assessing a compliance plan and then deciding on next steps to make the compliance plan more effective.
First of all, “go back to basics” seems to be a phrase somewhere or somehow applied or used similarly to the phrase “best practice” as if though uttering this phrase automagically (one of my favorite terms which is just as applicable today as it was when it surfaced back in the 1940s) makes whatever is being associated with that phrase more acceptable. My point here is that I think when people “go back to basics” there is the assumption on some level that the “basics” were there to begin with. What is interesting is that this may not be the case.
For example, of the seven elements that make up an effective compliance program as described by such sources as the Federal Sentencing Guidelines or the Office of Inspector General’s compliance guidance documents, auditing and monitoring is often one of the elements which is very weak, if it exists at all. To say we are “going back to basics” may mean we are heading back to a state where one of the basics didn’t exist to begin with. How is this a good move?
Secondly, “going back to basics” in my view should not discount the work that has already been done in the current state of affairs. Too often I see people make the “back to basics” move and overlook or ignore that which has worked to date as if though going back to basics means also distancing oneself from that which has been completed to date. Just as many people may agree that most compliance programs are ripe with opportunities for improvement, I think these same people will agree that in these same compliance programs, there has been good work done that is worth promoting and building upon. Let’s make sure that going back to basics doesn’t result in recognizing and promoting that which is working.
So do I think “going back to basics” is an inherently bad move? Not at all. However, I do think before doing so, it is important to acknowledge that whatever basics we are returning to may in and of themselves need repair. In addition, going back to basics doesn’t mean that we shouldn’t at least consider taking with us that which we have successfully implemented or accomplished since these continuing practices may also provide useful in whatever evolution of the compliance program may result.
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