In addition to my healthcare-related job, I serve on a supervisory committee for a company outside the industry. The Chief Executive Officer of the non-healthcare organization has been wrestling with a new compliance policy.
He presented a first draft to the Board of Directors. I did not have a problem with the technical aspects of the draft. However, I felt that the tone of his document characterized the compliance program as a burden; and it implied that compliance gets in the way of customer service.
I countered that a compliant organization definitely serves the customer, since our consumer wants the institution to be trustworthy, less vulnerable to conflicts of interest or monetary fines, and protective of his/her privacy.
The CEO continued to surprise me with his proposed compromise: he suggested “no stated policy at all.” I explained that the lack of communication from the top is a recipe for disaster. We know that the absence of a written policy introduces risks not only in an external audit, but more importantly, in the corporate culture.
The boss remained hesitant. I probed his reasons, and learned that he feared the “red tape” would distract management from focusing on service operations. I suggested that he could promote compliance and simultaneously express his concern, with a policy that includes the statement, “Compliance should not become a bureaucratic hurdle to good customer service. Our compliance program is not intended to be a foot-high stack of guidelines; rather, it is a commitment to ethical processes and an attitude of doing the right thing at all times.”
Fortunately, the Board of Directors shared my opinion, and came to my defense. Afterward, some directors thanked me for “saying what had to be said.”
The following week, the CEO wrote to me, “Thank you for speaking up in the meeting. Had you not voiced your concern, I don’t believe there would have been any discussion of the policy. And clearly discussion was warranted… As the regulatory environment becomes more and more challenging, I think it is imperative that the Board provide managers direction in this area… I’m confident we’ll get there!”
HCCA members probably recognize that many of my points came from Compliance 101. Clearly, the principles transcend the healthcare industry.
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