Medicare and Medicaid compliance can be a tricky area to adhere to. As such, Senior Consultant, Dick Menard provides the following tips on navigating compliance issues:
Focus on creating process for understanding the requirements as best you can using the proposed rule. The tricky part is predicting what will change in the final rule, so someone has to monitor the CMS (Centers for Medicare and Medicaid Services) website constantly for updates. A Google alert works well for this, and there are many special interest blogs that are helpful in interpreting what CMS really intends. Once the final rule is announced, there is not much time to modify systems. Also, CMS will issue technical clarifications in publications such as MLN Matters after the final rule has been published.
I suggest making a business requirements document (BRD) using the proposed rule and passing that around to senior hospital management for review. Sometimes a requirement is so vague that you will have to take a stance and let someone challenge you. Once you get consensus on what the business requirements are, then you can assess the revenue impact and begin to scope out detail project plans and functional requirements.
To facilitate moving from business requirements to functional requirements, I recommend creating a business vocabulary. Make the vocabulary consistent and even color-coded. This avoids misunderstanding of what a concept means as more members become part of the team and details stop to emerge.