Compliance Control

By Jeri Melinkovich
jmelinkovich@winhealthplans.com

As an attorney, I often hear my colleagues in private practice talk about “client control.” Oh how they regret not exercising a little client control when they get that client who refuses to settle, that client who calls on a daily basis, or that client who insists on micro-managing every filing. Without proper client control, expectations get out of hand, the ability to adequately represent is compromised, and negative financial impacts may result.  Client control really boils down to managing expectations.

Perhaps this concept of managing expectations may also be applied to the world of compliance. Let’s call it “Compliance Control.”  Have you ever been in a staff meeting where an issue is being discussed, and then someone says, “That seems like a compliance issue.”  That procedure that needs to be re-vamped, the problem with the third party vendor, those forms that need to be updated…if no one quite knows what to do with it, it is easy to throw an issue at Compliance to handle.

Enter “Compliance Control,” managing colleagues’ expectations of what the Compliance Department can and will handle.

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Compliance staff and resources are often limited, and it is imperative that resources are utilized efficiently on the most pressing compliance issues.  So how to keep the compliance officer’s desk from turning into a dumping ground for the miscellaneous?  Here are a few suggestions:

First, educate.   The term “compliance” may not be completely understood by staff, especially if your company’s compliance program is relatively new.  Take every opportunity you can to educate staff on the purpose and roles of compliance.  At regular staff meetings emphasize the importance of compliance remaining independent. Getting loaded down with side projects compromises that independence.  As our Chief Compliance Officer always says, “We can’t take the test and grade it too.”

Second, establish clear processes for vetting compliance issues.  This is a great way to put your compliance committee to work.  The compliance committee can serve as support as you gently inform your co-workers that working on operational projects may not be an appropriate issue for Compliance to handle.

Third, follow your own processes on how issues reach your desk.  Don’t let that conversation in the hallway turn into a commitment to take on a new project.  While those side-discussions at the watercooler may bring to light compliance issues, make sure that all issues are eventually vetted through your formalized process.  This way all issues are dealt with consistently, and only true compliance issues make their way through.

What constitutes a “true” compliance issue may not always be black and white, but exercising a little “Compliance Control” will increase your ability to work efficiently and on the most pressing compliance issues.