In November 2018, Baylor St. Luke’s Medical Center in Houston made two medical errors, the second of which lead to the death of a 75-year-old patient. After an investigation by the Houston Chronicle and ProPublica, the Centers for Medicare and Medicaid Services issued a report in early 2019 that outlined a pattern of blood labeling errors at the hospital. A ProPublica article on the report states:
Dr. Ashish Jha, an expert in hospital quality, reviewed the government’s findings and said it appeared St. Luke’s was struggling to meet basic care standards. The labeling mistakes, he said, seemed indicative of ‘a broader systemic problem.’… St. Luke’s appeared to miss warning signs in the months prior to the deadly mistake, according to the government report.
The “broader systemic problem” Dr. Jha mentions is, unfortunately, not unique to St. Luke’s. Many hospitals and healthcare systems face organization-wide, process-related issues, especially in a modern healthcare landscape that’s rife with change. Mergers, multiple technology platforms, and changing healthcare policies, to name just a few, contribute to widespread miscommunication and a lack of transparency. This, in turn, jeopardizes the overall quality of care within these organizations.
Hospitals can stem the scope of these issues by implementing a healthcare enterprise risk management (ERM) program. Healthcare ERM establishes a standardized framework for identifying risk across an organization, encourages cross-departmental collaboration, and shifts hospitals from a reactive clinical risk program to a proactive holistic risk management program. A straightforward process, along with the right technology the leverages healthcare analytics, can help to make this shift effective.
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Complying with Bank Secrecy Act/Anti-Money Laundering (BSA/AML) regulations is a major challenge for financial institutions. Those found with deficient practices are subject to receive a Matter Requiring Attention (MRA) notification. The Office of the Comptroller of the Currency (OCC) states, “MRAs communicate specific supervisory concerns identified during examinations in writing to boards and management teams of regulated institutions. MRAs must receive timely and effective corrective action by bank management and follow-up by OCC examiners.”
This combined requirement of timeliness and proof of effectiveness makes delivering an acceptable response particularly challenging. Unfortunately, MRAs are not uncommon. The article Get to Know the “5 Cs” — BSA Matters Requiring Attention notes, “Most banks receive some sort of finding or ‘Matter Requiring Attention’ (MRA) or ‘Matter Requiring Immediate Attention’ (MRIA) regarding their BSA Program during a BSA exam.” Given the likelihood of receiving an MRA, and the burden associated with the response, developing a robust process to handle them is essential.
This post will examine how the right Enterprise Risk Management (ERM) system is uniquely suited to not only help efficiently and effectively respond to the challenges associated with MRAs, but also (when properly configured) help minimize them.
To understand how this is possible it is useful to “learn from the mistakes of others.”
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Implementing an enterprise risk management (ERM) program can be a daunting, intimidating project. Trying to introduce new frameworks and controls across the organization, roll up risk reporting from the unit to enterprise level, and initiate discussions with the board that lead to action can be overwhelming. Using techniques proven to work with startups, however, can make the process far more manageable and increase the odds for success.
Startup incubators often promote a few common themes:
- Let customers/market dictate the product
- Scale it down – start small and go live fast
- Do the research and learn about the market
- Get feedback as quickly as possible
- Fail silently – incorporate lessons learned without dragging the whole effort down
These techniques suggest that the traditional high-profile, enterprise-wide rollout of a new ERM program may not always be the best way to launch. Instead, focusing on the smallest scale project—one with the potential to yield meaningful results—and relying on a customer-driven approach may be the key to creating a sustainable, effective ERM program.
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