Catherine Boerner (cboerner@boernerconsultingllc.com) is President of Boerner Consulting LLC in New Berlin, WI.
I am not sure how you measure or interview to find out how well you or someone else can see the big picture. I have been told by professional recruiters that very few people are really good at it. A compliance team working together, with a variety of strengths and weaknesses, can be amazing if they are able to lean on each other and at least one team member is good at seeing the big picture.
In the compliance department, when working compliance events/investigations, it can be important to be able to connect the dots and see the grand scheme of how what may appear to be an isolated compliance issue may actually affect many other areas in the organization.
With compliance risks, one benefits from being a detail-oriented thinker. You need to look at the rules and regulations and policies and procedures, narrow down the compliance risk areas, understand what is the right way to do something, and investigate and/or audit to find out how things are being done when someone raises a compliance concern. The detail is important, but so is the understanding of how and why a compliance risk area may affect other departments and the organization as a whole.
I like to have compliance team members think about a compliance investigation in terms of steps that allow for the detailed investigation but also provide a broader perspective when it comes to approaching compliance risk, especially in the area of coding and billing. Examples of steps to consider are:
Step 1: Fix the problem:
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What is the problem?
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What is needed to fix it (research)? What is the correct way?
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Once fixed, what did we change?
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Date fixed?
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Train on correct way.
Step 2: Look back to when the problem started and consider auditing:
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Do we have a systemic problem, or was this an isolated situation?
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How long has this been wrong?
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Write up an audit plan and conduct an audit.
Step 3: Return overpayments.
Step 4: Expand focus:
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Does this apply to other/similar areas?
Step 5: Reaudit in six months to ensure it’s still fixed.
I guess this is a way to “see the forest through the trees,” stay on track, and know what is next.