AT: You have a remarkably diverse career in healthcare. You have worked in compliance, internal audit, nursing, and quality management, and have spent time working with a host of other functions. Is there any one of them you think every compliance officer should spend six months working on to gain insight into how to make compliance more valuable to the organization?
KN: A broad range of experience is always beneficial because you gain the ability to see how various departments connect to serve the patient. Ideally, I would love to see every compliance professional deliver patient care, but that is not realistic, so my suggestion is to find an opportunity to get as close to patient care as possible. There are many opportunities; be creative!
I believe a compliance professional needs to recognize and appreciate that patient care involves complex technologies that do not always work well together. There are days when patient care needs are incredibly high, which means documentation happens later, and electronic medical records do not always capture a situation’s complexity. A compliance professional who recognizes that every day can bring challenges that require real-time troubleshooting is invaluable.
AT: Even though most of your work is consulting in other areas, you continue to work as a nurse. What keeps you committed to nursing?
KN: Even though I moved to internal audit after nine years of nursing, I continued to work on-call for several years. I think deep down I always knew I would return to nursing at some point.
The reason I pursued my bachelor’s degree in business rather than nursing initially is because I did not see many leaders in the early ‘90s with patient care experience except for the chief nursing officer. I saw so many inefficiencies in how we delivered patient care (systems, processes, communication, and wasted expenses) and did not have much of a voice as a young nurse. I felt a degree in business was an avenue to be heard. My commitment to patient care never changed over the years; I just found a different path to be influential.
After 25 years in management and consulting roles, I accomplished my goals and felt the next logical move for me was to go back to bedside nursing while continuing to consult. Today, I have the pleasure of being a consultant and working part-time as a nurse. It has been a wonderful combination, and I feel like I have become a better consultant since returning to nursing.
AT: You had the mixed blessing of working under a corporate integrity agreement (CIA). Obviously, no organization wants one, but it does focus management on the importance of a properly functioning compliance department. Two questions. First, how should compliance teams use a CIA most effectively for their organization and compliance program?
KN:I would say this a little differently; I think a CIA helps management recognize that compliance needs to be everyone’s responsibility and integrated into operations to be successful and effective. I was fortunate to work for an organization that viewed their two CIAs as an opportunity to improve revenue cycle workflows and develop new processes to stay on top of regulatory changes. The consulting team I have worked with for the past 14 years advises organizations entering a CIA to view it as an opportunity rather than a burden.
The compliance team can help facilitate change by learning more about healthcare operations and using the opportunity to educate all involved in the process on regulatory requirements. In an organization with limited compliance resources, it provides an opportunity to address structural (compliance officer, committees, code of conduct, policies and procedures, education materials, etc.) and process (risk assessment, monitoring, auditing, exclusion checks, corrective action plans, etc.) needs. What drives operational and regulatory compliance improvement is risk assessment, monitoring, auditing, and corrective action plans. The focus should be on these elements for a CIA to add value.
