S. Leah Yoder (sleahyoder@gmail.com) is Owner-Consultant at Leah Yoder Consulting, LLC in Moncks Corner, SC.
“Remember, life is so uncertain, eat your dessert first.” This is the voicemail message on my 90-year-old mother’s answering machine. What a profound and current message for life and business. Our world is often described as volatile, uncertain, complex, and ambiguous (or VUCA for short) — a perfect description of the compliance manager’s world. Regulatory bodies consistently produce ambiguous wording to describe complex layers of guidance upon which organizations are then audited. Often, regulators have a different ambiguous understanding than you do.
What management skills will best serve current and future compliance managers in this ever-changing business world? The dessert skills — the skills that are continually labeled “soft skills” to differentiate them from technical skills. These behavioral skills are often tacked on as an afterthought to competencies like dessert after a meal. Instead, let’s acknowledge them for being foundational skills, as they deserve, and start with them. Eating your dessert first will help compliance managers meet and exceed the seven elements of an effective compliance program described in Chapter 21, Section 50 of the MedicareManaged Care Manual.[1] Paraphrasing, the elements include:
-
Standards, Policies, and Procedures
-
Effective Oversight and Communication
-
Effective Education and Training
-
Risk Identification, Monitoring, Auditing and Reporting
-
Enforcement and Discipline
-
Response and Prevention
These elements focus on people doing the right thing, doing it well, and doing it at the right time. Arguably, compliance programs depend on three components to be effective — people, processes, and technology. You may have the best processes imaginable, but without enabling technology and competent people, those processes won’t be implemented correctly. Each of the elements identified by regulators can be correlated to the behavior of an organization’s people.
