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Using the seven elements as a common framework for effective compliance and quality programs

Mary Findley (mfindley@alvarezandmarsal.com) is a Senior Director in Alvarez & Marsal’s Healthcare Industry Group located in Dallas, TX. Jennifer Rabaglia (jennifer.rabaglia@phhs.org) is Chief Quality and Safety Officer; Associate CMO/SVP at Parkland Health and Hospital System in Dallas, TX. Kathleen Murphy (kmurphy@alvarezandmarsal.com) is a Managing Director and the Chief Operating Officer in Alvarez & Marsal’s Healthcare Industry Group located in New York, NY.

Anyone who has been engaged over time in the healthcare quality and safety (quality) debate has probably come to the same epiphany: If you have seen one quality program, you have seen just that—one quality program. Quality, by its very nature, is somewhat subjective. Fundamentally, quality is defined as an assurance that the care provided meets or exceeds best practices or nationally recognized professional standards. Countless medical professionals have spent much of their careers trying to appropriately define those professional standards, or identify those best practices, so that they can be objectively measured. But quality is not just a set of mandated metrics to track or a department that manages them. Quality is a way of being; a culture that, when done well, is woven into the very fabric of an organization. Quality metrics may measure performance, but that performance is generated by people and their actions, which are in turn guided by the cultural and behavioral norms of the organization in which they serve. Quality is everyone’s responsibility.

To date, that “special sauce” that forms the underpinning of an effective quality program has not been fully elucidated. Few organizations have managed to build highly successful quality programs, and success has been born out of a wide variety of programmatic shapes, sizes, and approaches. Consistency, however, is somewhat elusive. As consideration is given to the nature of quality as defined above, the mind wanders to other organizational oversight functions that have similar dependencies; compliance and ethics (compliance) programs immediately come into mind.

Compliance is woven from a similar fabric. An effective compliance program promotes an organizational culture that supports integrity, accountability, and ethical behavior. Compliance is not just a set of policies and procedures in a binder but is dependent on the behavioral norms of the organization in much the same manner as quality. However, compliance is not entirely subjective; it is bound by clearly defined regulatory and corporate integrity standards. This clarity with respect to the end result lends itself to structure, and with this structure, compliance has something that quality, as of yet, does not.

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