Margaret C. Scavotto, JD, CHC
President, Management Performance Associates
At the risk of getting some Billboard top ten 1980’s Janet Jackson lyrics stuck in your head for the rest of the day, I’d like to ask you an important question:
What has compliance done for you lately?
Phrased another way:
How has your compliance program helped your organization this year?
Did your hotline encourage employees to report potential false claims internally, so they could be self-reported? Did this hotline call possibly avoid a whistleblower situation?
Did routine compliance audits find a documentation issue – so you could correct it before it became a widespread problem?
Maybe the compliance department collaborated with the HIPAA Security Officer to run a ransomware and phishing campaign, educating employees about potentially hazardous emails and links. As a result, the Compliance Officer and Security Officer received dozens of calls from employees reporting suspicious emails and links that potentially contained ransomware or malware. Can you put a price tag on potentially avoiding a costly ransomware attack?
Did your quality assurance program reduce adverse events? Lower the amount of pressure ulcers? Improve patient care? Did that lead to an increase in census? Higher patient satisfaction? Positive perception in the community?
Perhaps your annual employee compliance survey shows a more supportive workplace due to the compliance education effort the compliance department put in place, and that employee turnover has also decreased.
What else did compliance do? Did compliance boost the bottom line? Make it easier for employees to do their jobs? What processes did compliance improve? How did the compliance department contribute to your organization’s culture? Make your company a better place to work? A better place to receive care?
Once you have taken a moment to tally up everything your compliance program has done for your organization this year, ask a second question:
Who did you tell?
Did you tell your board? (Or the president, or CEO, or whomever else is at the helm of your organization?)
Did you tell your managers, so they can see how the compliance department is working for them?
Does the marketing department use compliance data showing improvement in quality assurance scores?
Who is in charge of the budget? Do they know about the compliance team’s accomplishments? Do they know that investments in compliance could yield greater advances in quality care, patient satisfaction, employee satisfaction, billing accuracy, occupancy, and more?
I hear so often from compliance officers who have trouble getting money in the budget for compliance, or getting compliance projects treated as a priority. So I ask them: What has compliance done for you lately? A lot, I bet. Who have you told? Because if you don’t tell anyone, your organization might not know how powerful your compliance effort really is. And as Janet would say, ain’t that a shame?
Margaret, these are questions that we should ask ourselves throughout the year but especially during this time. As we quickly approach fourth quarter, many organizations are conducting performance evaluations and refining 2020 strategic plans. What better time than now to answer these questions?
Walter, great point about fourth quarter! Too often, compliance is left out of strategic planning, when it should be at the forefront. I couldn’t agree more.
These are great questions to ask. Compliance is always working in the background which makes it seem unimportant and easily forgotten. It is up to us as compliance professionals to put ourselves in the forefront and make the board and leadership aware of all the efforts.
Tammy, I agree. As if compliance professionals don’t have enough to do! But, it might be one of the most important things we do.
Tammy, I agree that this might be one of the most important things that compliance professionals do (if only we had more time to do it)! Thank you for taking the time to weigh in.
Margaret, The first year after creating our agency’s Corporate Compliance and Ethics program in 2011, I provide semi-annual “State of the Agency” presentations to our board (similar to the Presidential State of the Union address) to highlight answers to many of your questions you raised in your posting. I include stoplight graphics to indicate full compliance (green), compliance issues (yellow), and non-compliance (red).
Kent, I love the red, yellow and green approach – I’m always in favor of using a visual overview. Great idea!
A lot ! to my surprise and beyond my expectation considering the lot more of goodies that is in store for me and my company after successful implementation of our various compliance programs. . I will therefore like to express my sincere appreciation and gratitude to my investors , partners , stakeholders and all who have contributed to my success thus far as a compliance officer and request for more support and guidance for the journey ahead to finally hit my main target as a business leader or compliance officer. both in the near . immediate and in the long term..
I have learned that compliance is indeed a team work and success could only be achieved through collaboration and therefore strives always to collaborate as much as possible with my team made up of investors , regulators, partners etc. to achieve a total and perfect success.
Jean, I love this!! What a good (and inspiring!) point. So often we hear about the compliance struggles – struggles to get time with the board, to get compliance in the budget, to get time committed to compliance tasks – but just as often there are stories of success and that success always involves collaboration and support. Thank you for sharing and brightening my day!
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