Hospices seeking to grow should consider building a culture of compliance driven by data, effective system design and accountability, including for its sales force.

Compliance and sales should walk hand-in-hand, according to a recent report from the Transcend Strategy Group. This can help prevent sales staff from running afoul of regulations inadvertently as well as support sustainable growth, according to Tony Kudner, chief strategy officer for Transcend.

“The strategies that we’ve seen hospices take to grow their organizations responsibly do require a deepened, nuanced understanding of compliance. You should not have a sales function without a strong compliance partner, and at least annual compliance training that’s specific to your sales staff,” Kudner told Hospice News. “Because if you don’t have that, then what you get are things that start to run afoul of the anti-kickback statute and Stark Law.”

For example, a sales rep may think that sending a gift card as a “thank you” for a referral is an innocuous act but could be seen as a kickback by regulators, Kudner indicated.

“Without that understanding of what the rules of the road are, you’re going to run into trouble,” he said. “Though no one-size-fits-all approach exists, providers can adapt three overarching strategies to support this kind of culture.”

Data

Data are necessary to track and manage sales team performance, according to the Transcend report. To be most effective, these data must be relevant to the tasks at hand and available in real-time.

A key first step is to identify the key performance indicators that a hospice should track. These can range from census, length of stay and admission conversions to referral source mix and sales visit productivity, among others.

The hospice sales force can also leverage data in their daily work. In communication with potential referral sources, they can cite information such as their organization’s number of clinical visits, the breakdown of those visits by discipline, total patient care days or hours and discharge numbers, the Transcend report noted.

“At a fundamental level, you’ve got to have data to drive your decisions. You have to sell outcomes,” Kudner said. “Otherwise, you’re doing a spray-and-pray strategy where we’ve got a rep who’s running around everywhere dropping off pens and everything, and we have no idea if it’s successful or not. So you’ve got to have the data.”

Design

A robust suite of data can help inform systems design, including the ways that your sales team, clinical staff, compliance and other personnel collaborate and interact, Transcend indicated.

With solid design, an entire organization can come to work with a “growth mindset” and recognize their place in fostering the company’s success on KPIs. One key element of this is strong alignment between the sales force and the admissions team.

“If you start with a thesis that there are people who need us out there, and it’s our job to go find them and to position ourselves as the hospice that can best serve those needs, it would follow that you also have to have the admissions architecture to admit those patients in a timely way and get them that care,” Kudner said. “Where sales sits and the closer it can be integrated with clinical operations, the better off hospices are.”

Some operators can benefit from having sales and admissions as an integrated department. Recurring meetings, effective scoping of each employee’s specific role, compliance training and hiring new staff commensurate with the company’s rate of growth can also help foster greater collaboration among different areas of the business, according to the Transcend report.

“You’ve got to have the right design, and we think about that sort of holistically: Where does sales sit within the design of your organization?” Kudner said. “Is it a bolt-on that doesn’t really have any meetings, for example, with the director of clinical operations, or the director of admissions, and they’re just out in the field, and nobody on the [interdisciplinary team] knows them? That’s a recipe for ineffective and ineffective design, and it will not lead to sustainable and durable long term growth.”

Accountability

A culture of accountability is also essential, Transcend reported.

Sales teams need to be held accountable in a fair and equitable way. Data factors into this as well, as a means of assessing performance. Strategies for achieving this can include a requirement of sales teams to provide a quarterly sales plan to organization leaders, with input from clinician and admissions managers, the report said.

Hospice employers should also set clear expectations as far as how many referral relationships they are responsible for developing and leaders should be able to determine where sales people are and what they are doing on any given day.

Providers also can arm employees with Customer Relations Management (CRM) software in which sales staff can document who they visited, include notes on the conversations and outcomes, as well as items for follow-up, Transcend indicated in the report.

Sales leaders can also do “ride-alongs” with frontline staff to offer coaching and support, according to Transcend.

“An organization has to think about what outcomes they want their sales reps to drive and to celebrate the successes when they meet those outcomes, but also to have honest conversations,” Kudner said. “If the expectation is a set number of hours with high-value referral source accounts, and a rep is consistently not doing that or consistently not documenting the quality of those visits, then it’s very easy in a distributed labor force to lose sight of these things.”