“I’m a compliance officer, of course I...”

7 minute read

Over the past year, I have had the opportunity to teach two graduate-level courses to individuals from varying backgrounds who are interested in healthcare compliance. Like many of you, I sometimes become overwhelmed by the day-to-day requirements of those in the field of compliance and privacy. However, having the honor to teach people how we review matters and the laws surrounding compliance and privacy has given me a refreshed perspective. In thinking of this during a recent long run, I wanted to convey my sense of optimism for our profession in present-day terms.

  • I’m a compliance officer, of course, I . . . work hard to send the message to the right address and ask for what I need. This means I must sometimes have crucial conversations to investigate matters with individuals inside and outside the organization. This involves understanding that it matters not what you say but how you say it. Additionally, this means learning specific tools to use to decrease the potential for defensiveness and developing your own authentic style to communicate honestly and openly. Most of all, this involves knowing when it is appropriate to escalate an issue and using that escalation sparingly so that when you heighten an issue, it is taken seriously.

  • I’m a compliance officer, of course, I . . . have learned that control is an illusion. Meaning I cannot control the actions of others. I can collaborate, communicate, and educate others, but at the end of the day, I cannot control them. I need to meet people where they are on a matter and understand perspectives—theirs and mine—to come to a consensus. There will be times that consensus is not reached and depending on the issue, it may need to be documented, communicated, and escalated appropriately.

  • I’m a compliance officer, of course, I . . . find that being initiative-taking and energetic influences the education process. People gravitate to positive people who have positive energy. If you demonstrate that you believe in the “education” and the concepts you are training, others will follow. It is like salespeople who demonstrate they believe in their product having higher sales than those who do not demonstrate product confidence.

  • I’m a compliance officer, of course, I . . . am curious, sincere, and strive to understand that everyone has different perspectives so I may need to adjust my approach to encourage dialogue. Seeing the good in others until proven wrong is key to maintaining this philosophy.

  • I’m a compliance officer, of course, I . . . firmly believe at my core that doing the right thing is never the wrong idea. Encouraging reporting and transparency is vital to the success of the compliance program, and, frankly, the compliance profession. I strive to ensure that understanding the right thing to do in each situation is part of the analysis, as each situation is nuanced with different variables.

  • I’m a compliance officer, of course, I . . . am teachable. I must be, as new and changes to regulations are coming out on an ad hoc basis. I also need to adjust to new ways of communicating information. Simply sending a memo with a change is no longer a means of communicating. It differs by organization, but emails, voicemails, podcasts, town halls, virtual town halls, virtual meetings, and social media platforms are all possibilities, depending on the environment.

  • I’m a compliance officer, of course, I . . . think culture is at the core of success. This means that negating the image of “compliance as the police” and promoting the image of “compliance as the confidential, knowledgeable resource” is imperative. To do this, I strive to share our department mantra with others. We use a mantra instead of a mission or vision because, as a marathon runner, I know how powerful they can be. In running, a mantra is defined as “a specific set of words that you repeat during tough moments to help you find that inner strength to go on. Once you have found the right mantra, you will repeat it over and over during that tough time.” The same is true of a compliance mantra. As we face tough times, I always remind the team of our mantra: “We communicate, we collaborate, and we educate.” When faced with a significant privacy compromise or billing concern, it is easy to lose sight of that mantra. That is the time to double down and focus on how to help the business and be the resource to mitigate the risk and promote positive change.

  • I’m a compliance officer, of course, I . . . never give up. In his 2014 University of Texas at Austin commencement address, the ninth commander of the U.S. Special Operations, Naval Admiral William H. McRaven, highlighted 10 Life Lessons for Life that can be applied to our roles.[1] Compliance officers must frequently meet with multiple people to unravel a situation or learn the source of information. Sometimes, investigations can take weeks or even months. It can be daunting and discouraging, but we never give up. Why? Because we have a job to do, and we need to do it. People—and more importantly, our stakeholders—whether our patients, colleagues, leadership, employees, or business operational leaders, depend on us to get the job done.

  • I’m a compliance officer, of course, I . . . am interested in communication from all levels of the organization. This involves establishing check-ins with senior leadership and compliance ambassadors, ensuring there is an annual virtual town hall focusing on compliance, deploying compliance and privacy staff to the business units on a routine cadence, and responding to all emails and voicemails within 24 business hours. Communication and rapport are the keys to establishing trust. Once there is trust, there is the ability to understand issues more clearly, mitigate them, if need be, and educate the business unit.

  • I’m a compliance officer, of course I . . . am not always right. There may be times when I provide guidance and later find out it was incorrect or without enough detail to be understood. In those times, I seek to immediately correct the communication and apologize in person and in writing. We are all human, and in this role, it is critical to show our humanity by expressing our humility when we have made an error and need to revisit the matter with our stakeholders.

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