How to Take a Big Picture Approach to Compliance Work

Something I have picked up over the years is that the way a compliance officer interprets the initial report of a concern says a lot about how he or she will solve the problem. What I mean by that is that very quickly, you will find out whether the person is guided by the big picture or whether they’re detail oriented.

In order to navigate the politics of healthcare successfully, you’ll be better positioned if you approach the problem as a big picture thinker. That does not mean details are not important. It’s just a matter of timing. That means knowing when to focus on the big picture, and when to focus on the details.

The Importance of a Big Picture Approach

Taking a big picture approach is important to the work of a compliance officer for a couple reasons. First, it positions you to maintain a calming presence in your communications. For example, consider conducting an investigation. Allegations involving high-risk issues like drug diversion, coordinating a response to a regulatory change or responding to a government investigation all get people’s hearts pumping fast. When healthcare leaders come to you with a high-risk issue to resolve, they are often anxious because they’re functioning in a state of uncertainty. To counteract this anxiousness, avoid making your focus on past (i.e., the conduct that occurred). Instead, focus on the present and the future—the steps you’re going to take to resolve the issue. Taking this approach will help you maintain a calming presence and demonstrate to your leaders that you’re capable of big picture thinking.

Separate from helping you maintain a calming presence, operating with a big picture mindset also helps you build stronger relationships with your healthcare leaders.

Why?

Because healthcare leaders are predominantly big picture thinkers. They operate in a world of mission and vision statements, strategic plans, and business agendas, all of which are focused on the big picture. That means a leader is not only focusing on the launch of a project, but what the exit strategy is going to be if it doesn’t work out. Big picture thinking means you’re able to see what is in the past, the present, and the future. If you take a big picture approach to your work as the compliance officer, it becomes a form of tailoring your communication to your audience. Over time, this approach will help establish rapport and develop stronger relationships with your healthcare leaders.

A Big Picture Approach to Compliance

When it comes to compliance work, a big picture approach can be carried out with many—if not all—of the Seven Elements of an effective compliance program. Let me give you three examples to illustrate how this works.

First, building off the discussion above, let’s revisit the topic of investigations. If you are investigating an issue, what does the end of the investigation look like before you get started? If the allegation is substantiated, how will that affect you, your supervisor, and the compliance program? What impact will it have on the organization and any of the individuals involved? If the allegation is unsubstantiated, could the reporter file a complaint with a government agency (e.g, state agency, CMS, OCR)—and if that happens, can you defend your investigation?

Second, consider conducting an audit. A big picture approach to conducting an audit means you’re looking at the beginning, middle, and the end of an audit before you get started. What potential outcomes will exist for you and the organization as a result of the audit. If an issue arises outside the scope of the audit, do you need to consider adding a new audit to your audit plan? Is the topic you are auditing, one that you need to conduct a follow-up audit in a year or two years?

Finally, think about conducting education & training. If you are developing content for educating your workforce members on a new regulatory change, what specific information do you want your audience to walk away knowing (i.e., the learning objectives)? How will you approach the training to ensure they will retain the information? Do you need to conduct monitoring to determine if they have retained the information? Do you foresee needing to conduct repeat training in six months or a year, or will this training be a one time thing?

These are just a few examples to demonstrate how a big picture approach can be applied to the work for a compliance officer.

Pulling it All Together

Having a big picture perspective identifies what is most important, which helps you determine what is a true priority. As I said earlier, details are important; it’s just a matter of timing. When a compliance matter gets presented to you for resolution, your initial interactions should be focused on the big picture. What questions do you need to resolve? How are you going to resolve them (if this is possible to predict)? Who do you need to talk to in order to resolve? What are the likely end scenarios going to be?

That’s a big picture line of thinking.

Over time, your professional judgment is going to be shaped by how well you can maintain a big picture view while carrying out detail-oriented work. If your goal is building strong relationships with leaders, adopting a big picture mindset will help you achieve that goal and ultimately improve your ability to navigate the politics of healthcare.

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