Take Your Work Seriously, But Don't Take Yourself Too Seriously

Without question, compliance work is serious business. The work we do is important to patient care. It is important to the organizations we work for. And it is important to tax-payer-funded healthcare programs. Simply put, the work requires that it be taken seriously. But that does not mean a compliance officer needs to be a serious person...well... not all the time, at least.

If you want to effectively navigate the politics of healthcare, take your work seriously, but don’t take yourself too seriously. Now, you may be thinking, “Hey, man. I like a good joke as much as the next person. Are you saying I need to be a comedian?” Not exactly, but let’s break this down a little more.

Take Your Work Seriously

Taking your work seriously means you are passionate about your work. That is true, no matter what line of work you are in—accounting, painting, medicine, plumbing, etc.

In the compliance officer profession, there isn’t a more accurate indicator of taking your work seriously than passion. Whether it’s reviewing regulations or conducting an audit, the work is tedious and labor intensive. As I covered in a separate article a couple weeks ago, you have to unconditionally love the struggle of compliance work—and that takes a special person to voluntarily endure that kind of pain.

Don’t Take Yourself Too Seriously

So what do I mean by “Don’t take yourself too seriously”? A few thoughts come to mind.

First, it means not beating yourself up when you make a mistake. When you are passionate and thorough in the approach to your work, you have the capital to lighten up on yourself. You’re human, and all humans make mistakes. As it relates to how you externally process mistakes, of course, you need to take that seriously. That is your work. Genuinely apologize and follow through on your steps to correct so that trust is not lost.

As it relates to how you internally process the mistake, this is where some people vary in how they respond. You need to be able to laugh at yourself. People who take themselves too seriously become too afraid to fail, and when they do fail, it becomes too much for them to accept. People who are self-confident because they worked hard have no problem admitting their mistakes. They may even bounce back by throwing in a little self-deprecating humor. When you can laugh at yourself in front of others, you are not taking yourself too seriously.

Not taking yourself too seriously also means you have a healthy dose of humility. Now, humility can mean different things, but for me, humility looks like a person who is grateful for what they have. It looks like listening to others and enabling them to be heard. And it looks like asking for help when you need it. These are traits that one should possess, no matter one’s socioeconomic background. Let me give you an interesting example of humility that I experienced in my life.

In 1997, I was working as a bartender in Sun Valley, Idaho. Yes, it is true. I was “finding myself ” after college. It was a time that my father had really hoped wouldn’t last long.

If you’re not familiar with Sun Valley, think Beverly Hills but in the mountains. It’s filled with celebrities and the uber-wealthy either living or vacationing there. Every day was an out-of-body experience that resulted in me calling my folks to tell them whom I saw. It’s a ridiculous fantasyland. A perfect place for someone finding themselves.

One night I was working at an annual event put on by a major investment company out of New York. It was a who’s who of multimillionaires and multibillionaires. While I was serving drinks before dinner, a gentleman tapped me on the shoulder. He asked me if he could have a glass of wine sitting on the tray I was holding. As I turned around, my twenty-two-year-old male brain mumbled, “Yeah” to this person—but he didn’t quite hear me. He said, “Oh. No, I can’t have it?” in an almost apologetic tone. As I fully turned around to give him the glass of wine, I immediately recognized who it was. It was Bill Gates.

At the time, he was the second wealthiest person in the world, with a net worth of $36 billion. Though I politely replied, “Oh, yes, you can have it,” I will tell you inside I was actually thinking, “Holy crap!!! You’re Bill Gates! I believe you can have this free glass of house wine!”

I mention this story because I have never forgotten how impressed I was with how he carried himself. It was as if he were no better than I was, though Forbes would certainly feel otherwise. Humility is about understanding that we’re all equally valuable, and that is demonstrating that you are not taking yourself too seriously.

Pulling it All Together

The takeaway here is that if you want to be effective at navigating the politics of healthcare, take your work seriously but don’t take yourself too seriously. This approach can help you in building relationships and communicating with others. Since some healthcare leaders perceive us to be about as impersonal as a computer, this approach can help change the perception of compliance. It adds a human element to your work.

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An Unconditional Love for the Struggle of Compliance

I will be the first one to admit that compliance-related work is not for everyone. You really have to have a love for this type of work, which means an unconditional love for the struggle that goes along with the work.

Personally, I think this true in life, no matter what you seek to do.

In this article we’ll take a look at an unconditional love for the struggle of compliance work and how it affects your ability to navigate the politics of healthcare.

An Unconditional Love for the Struggle

As some can attest, I absolutely love to ski. If you were to ask my wife, she would say that I probably love it more than life itself. It’s my happy place. It’s where I feel like a kid again, out on an adventure. It’s where I feel the most alive.

Inherent to that love, though, is an unconditional love for the struggle that goes along with skiing. Skiing means being outside in the cold, so you have to be OK with that. Being outside in the cold also means you’re going to have a runny nose. Are you OK with that? And skiing means shoving your feet into ski boots. Now as much as I love to ski, I will be the first to admit that ski boots are not exactly comfortable. They’re also an awkward pain in the a** to walk around in.

These are all examples of the struggles that go along with skiing. These are also things I don’t think about because I don’t think of them as struggles. I appreciate them for what they represent to me: the opportunity to ski.

For me, compliance work is very similar.

A Love for the Struggle of Compliance Work

Deep down, you have to have an unconditional love for struggle that is part of the job, or you’ll never make it. If you can happily sift through endless pages of a final rule published in the Federal Register, you have an unconditional love for the struggle of compliance work. That means you can see past the fact that the content is dry and the font is mind-numbingly minuscule.

If a new investigation is exciting to you because it seems like an interesting adventure, you have an unconditional love for the struggle of compliance work. That means the tedious steps needed to document your work doesn’t bother you.

If resolving a complex issue seems like an opportunity to learn and grow, then you have an unconditional love for the struggle of compliance work. That means you’re at peace with the amount of time and work it will take to resolve the matter.

If these are examples that resonate with you, then I’d say you have an unconditional love for the struggle of compliance work.

Navigating the Politics of Healthcare

So how does an unconditional love for the struggle of compliance work relate to navigating the politics of healthcare?

If you have such a love, then it’s a sign you are passionate about your work. When you are passionate about your work, others in the organization will see it come out in your interactions with them. (Even if they don’t understand or agree with it.)

They will see you as a trusted resource when it comes to advising them on compliance-related matters, and that gives you capital. The kindof capital that positions you to establish rapport with your leaders and build strong relationships with them as you work through a question or issue. Over time, your ability to find solutions during times of conflict will improve, as well as increase your chances of gaining buy-in to your compliance program.

Pulling it All Together

An unconditional love for the struggle of compliance work is an excellent benchmark as to whether the career choice you have made is a good fit for you long term. It also is an asset that can help you in navigating your compliance program through the politics of healthcare.

In my experience, an unconditional love for the struggle is something that must occur naturally. It can’t be forced. With that said, figuring out whether you have an unconditional love for the struggle of compliance work can only be identified over time. So how do you know?

The litmus test I’ve used professionally is money. If there were no such things as money and bills to pay, would you still perform this job? Put another way, if you won the lottery tomorrow, would you still want to do this work?

Going through this exercise will always provide you with your answer.

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The Importance of Executive Presence in Compliance

As healthcare compliance officers, we are tasked with ensuring that our organizations adhere to a complex web of laws and regulations tied to patient care and reimbursement. An often overlooked— but vital asset to the effectiveness of your compliance program—is the ability to demonstrate executive presence. In this article, we’ll take a look some of key characteristics that define this important skillset, and how executive presence can help you in navigating the politics of healthcare.

What is Executive Presence?

Executive presence is a combination of qualities, both tangible and intangible, that convey leadership, credibility, and confidence. It’s more than physically how present yourself in a corporate setting, it encompasses how you communicate with others and inspire them to act—compliantly, of course.

Individuals with a strong executive presence can be characterized by the following traits:

• Effective Communication—They speak clearly, concisely, and with conviction, as well as actively engage in meaningful conversations.

•  Authentic—Their personality is genuine in nature, whether they are on stage or off-stage.

• Emotionally Intelligent—They navigate complex interpersonal situations effectively because they can identify the emotions of others and know how to manage their own.

• Confident—The believe in their abilities and commit to them.

• Handle Stress Gracefully—They maintain their composure in high-pressure situations.

• Decisive—They make timely decisions and take responsibility for them regardless of outcome.

• Big Picture Thinker—They have the ability to see the end of a project before starting on it by considering various options and potential outcomes.

For a compliance officer, these traits can make a significant difference in how you resolve an issue and build credibility as a trusted business partner to those in operations.

Executive Presence Tips

If you seek to achieve the above-noted traits, here are five tips to help you improve your ability to demonstrate executive presence as you interact with others in the organization.  

1. Mentally prep for your discussions ahead of time. (Think about what information you need to convey to your audience, anticipate questions you may get asked, and what actions you need them to take.)

2. Develop and refine your critical thinking skills. (For tips on critical thinking, click here.)

3. Build confidence by identifying weaknesses and practicing the skills needed to overcome them.

4. Focus on maintain a calming presence as you address and resolve a compliance issue. (For strategies on maintaining a calming presence, click here.)

5. Improve your emotional intelligence by developing tools for emotional self-awareness, self-care, and empathy.  

Executive Presence and The Politics of Healthcare 

Executive presence is a critical asset to help you in navigating the politics of healthcare. For example, when you are able to confidently communicate with others and maintain a calming presence while resolving an issue, you will position yourself as a credible resource. Over time, this helps you build trust and develop stronger relationships with those in operations.

Executive presence also helps you positively influence the behavior of others in the organization. When you critically think through a compliance matter by challenging your assumptions, considering various outcomes, and factoring in the feedback of others, you are better equipped to find solutions that work. Finally, executive presence aids your ability to resolve conflict by taking into account the point-of-view—and emotions—of other interested parties.

When factored together, this skillset improves how you interact with others in the organization and your ability to obtain buy-in to the compliance program.

Pulling it All Together

Executive presence skills are a must for any compliance officer. They help you communicate more effectively and project confidence as you resolve an issue. They also improve your chances of building credibility as a trusted business partner to those in operations. In the context of navigating the politics of healthcare, executive presence helps you to build stronger relationships with others in the organization, as well as positively influence behavior, and resolve conflict. In order to be effective, executive presence should be authentic to you. These traits aren’t about being someone you're not—rather becoming the best version of yourself.

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The Importance of Critical Thinking in Compliance

From scheduling patients to delivering care to reimbursement, healthcare is an industry functioning under a mountain of regulations in the United States. To help navigate this mountain, healthcare organizations have us—the compliance officer—to identify and respond to issues.  

While knowledge of the applicable healthcare regulations is undoubtedly essential to our role, there is one skill that I think that stands out as indispensable—critical thinking. In this article, I will explore the importance of critical thinking skills, and how it helps the compliance officer in navigating the politics of healthcare.

What is Critical Thinking?

Critical thinking is a cognitive process that involves analyzing, evaluating, and synthesizing information to make informed decisions and solve problems. It's a skill that allows an individual to assess information, identify flaws, and make reasoned judgments. Critical thinkers can be characterized by the following traits:

• Curiosity—They ask questions and strive to understand the world around them.

• Skepticism—They approach gathering information by questioning the quality, validity and reliability of sources and statements.

• Objectivity—Critical thinkers seek to remain impartial and objective by aiming to separate personal biases and emotions from their analysis and decision-making processes.

• Evidence-Based—They rely on evidence and facts to support their claims and arguments.

• Logical Reasoning—They draw conclusions by making connections between different pieces of information.

• Open-Mindedness—While maintaining skepticism, critical thinkers remain open to new ideas and perspectives by being willing to consider alternative viewpoints.

• Creative—They are driven to think outside the box by generating new ideas and solutions to problems.  

• Foresight—Critical thinkers plan ahead by considering various options and potential outcomes. 

• Self-Reflective—They continually assess their own thought processes and decision-making in order to remain open to the idea of self-improvement and learning from their experiences.

Tips for Critical Thinking

If you seek to achieve the above-noted traits, here are six tips to help you improve your ability to think critically about your compliance work.  

1. Ask more questions (and be curious and not judgmental in your approach).

2. Identify your assumptions and question them.

3. Seek out the feedback, insights, and opinions of others, especially those with a differing view.

4. Develop foresight by thinking 1-2 steps ahead of the move you’re about to make.

5. Weigh the consequences of different actions/outcomes before you act.

6. Develop big picture thinking by identifying the end result before you begin your work.

Critical Thinking and The Politics of Healthcare

Developing and refining your critical thinking skills will help you in navigating the politics of healthcare as you approach your compliance work. For example, consider the part of your job that is that of a problem solver. Whether you are consulting to operations, or conducting an audit or investigation, you will encounter ethical or non-compliance dilemmas. These are the moments that will require careful consideration and resolution. Critical thinking enables you analyze these situations, evaluate potential solutions, and make informed decisions that align the organization’s compliance and business agendas.

Let me give you another example. Assume there is a new regulatory change affecting a department’s operations in your organization. As part of implementing a new and compliant process change, you’ll need to figure out how to articulate complex regulatory requirements in a way that ensures that everyone understands what will be expected of them. Critical thinking helps you organize your thoughts, consider others’ perspective, and anticipate counterarguments. This allows you to develop a solution that is tailor fit to your audience.

Pulling it all Together

Critical thinking skills are a must for any compliance officer. They enable us to navigate complex regulations, interpret requirements and resolve intricate problems. They also allow us to proactively identify and respond to compliance risk, as well as assess information and make reasoned judgments. When you think about it, critical thinking skills permeate just about every aspect of our work on a daily basis.

In the context of navigating the politics of healthcare, critical thinking positions us to communicate effectively with others and build stronger relationships within the organization—which not only helps obtain buy-in, but can unlock your potential to shaping a brighter future.

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Vetting the Accuracy of Your Compliance Communications

Earlier this year, I published a couple articles detailing how compliance officers can effectively communicate with physicians and healthcare leaders about compliance matters. If you happened to miss those, you can find those articles here.

Another component of effective compliance communication is vetting the accuracy of what you are saying to your audience. To be clear, I’m not suggesting that all your communications need to be vetted. For example, if a coworker asks you for the date of the upcoming holiday party and you get it wrong—that’s probably not going to end your career.

What I’m talking about are the communications that involve a higher level of risk. In this article, we’ll take a look at what types of communications need to be vetted, I’ll share some tips for vetting them, and why doing so is important to navigating the politics of healthcare.

The Types of Communications that Need to be Vetted

Let me give you three common examples to help illustrate the types of communications that need to be vetted for accuracy:

1. Any communications with an external party, such as a patient/family member, government agency, organizational business partner, or the media.

2. Any discussion with others inside the organization where you are analyzing or making a conclusion about a potential compliance concern.

3. Any communications where you are providing an opinion that is interpreting a regulation, internal policy, or other formal guidance.

With these specific examples, there are some common denominators that signal a need to vet your communication. First, you could be discussing a matter of high risk to the organization. Second, you could be discussing a matter that is sensitive in nature (e.g., confidential, controversial, potential for conflict). Finally, you are communicating to an audience who is relying upon what you are saying, for purposes of making a significant business decision affecting the organization.

Tips for Vetting Your Communications

Regardless of the type of communication that I described above, there will be times when it is critical to double or even triple check your facts. For example, if you find yourself in a meeting, or another situation where you are having to verbally communicate about facts and you’re not 100 percent sure, then let your audience know. Be transparent that you are not 100 percent certain of the facts and that you will verify and follow up. Taking such an approach will help you in maintaining trust with your audience vs. relying on inference and professional judgment.

Some additional tips for vetting your compliance communications include:

1. (Fairly obvious), check with your point-of-contact who is closest to the facts that you’re relying upon to validate the accuracy of what you are communicating to others.

2. During times when you are drafting a written communication, reach out to someone you trust so you can get a “2nd set of eyes” to look at what you’ve written. Having this fresh perspective can help you spot typos or identify any gaps in the communication or analysis that may raise a question.

3. Run the scenario by a trusted colleague who has no knowledge or background of the matter being discussed. This can also help provide a fresh perspective and identify any questions that need to be answered.

With these tips, you should’ve noticed a trend—checking in with someone else. We often get so close to our work that we can’t see what’s right in front of us—which is to say, words we think are there, information that’s not accurate, or a gap in logic that needs to be filled.

(Note: For Tips #2 and #3, your supervisor may be the best option available to you.)

Vetting Communications and The Politics of Healthcare

Vetting your communication is critical to navigating the politics of healthcare for three reasons. First, it’s a hallmark of communicating diplomatically because your communication is rooted in fact and not opinion. This creates a more defensible position as you communicate with others, especially those who may have a competing self-interest. Second, it helps you establish credibility with others in the organization as a trusted resource. Finally, taking this approach helps establish rapport with others in the organization, which leads to gaining buy-in to the compliance program.

Pulling it All Together

While vetting your communications does involve extra work, the time and energy spent will be less than the time it will take you to explain why your communication was originally inaccurate. Yes, we’re all human, easily capable of mistakes. You just don’t want to make it a practice. Taking the time to vet your communications will help guard against making inaccurate communications a practice.

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Challenge Your Compliance Assumptions

As compliance officers, challenging your assumptions is a critical skill for things like conducting investigations and audits. It also comes in handy when advising healthcare leaders as to whether or not their business decisions are compliant. Below are ten tips to help you in challenging your assumptions when working on any compliance-related matter:

1. Maintain Awareness. The first step towards challenging an assumption is recognizing when you have made one. Here, you want to start by identifying the thought processes that are leading you to make an assumption.

2. Question Your Assumptions/Examine the Evidence. When you do identify an assumption, ask yourself why you believe it? What evidence has led you to this assumption? Is it based on fact or opinion?

3. Seek Out Contradictory Evidence. When I was in law school, our professors made us advocate for both sides of a case in class. You can apply that thought process to assumptions, by actively searching for evidence that contradicts your assumption. The takeaway here is don’t get so blinded your own argument that you can’t see the other side.

4. Consider Different Perspectives. Piggybacking off of the last tip, try seeing the situation from various viewpoints. How might someone with a different background interpret the same information? If available, discuss the matter with others who may have an opposing viewpoint.

5. Practice Intentional Empathy. Put yourself in the shoes of others to understand their feelings, motivations, and perspectives about the situation. Doing so can help open up a perspective you might otherwise have not considered.

6. Evaluate Your Sources. Consider the credibility, (and biases), of the sources that have contributed to your assumption. Are they reliable? Are they objective?

7. Test Your Assumption. As you are gathering your information, try testing your assumption. There are a number of different ways that one can test an assumption—for example, you could discuss it a trusted colleague and see if that person has come to the same conclusion. Another would be to seek out additional information to validate your assumption.

8. Practice Open-Mindedness. Be willing to revise an assumption when new information becomes available or when you gain a deeper understanding of the situation.

9. Self-Reflect. Set aside time to consider whether your assumption has evolved or if new information has surfaced that is challenging it?

10. Learn from Your Mistakes. When an assumption has led to a mistake or misunderstanding, view it as an opportunity for learning and growth.

Assumptions and The Politics of Healthcare

Challenging an assumption is critical to navigating the politics of healthcare for a couple reasons. First, your own credibility as an independent and objective gatherer-of-facts will be strengthened. Your healthcare leaders will be able to see that your work product is unbiased and trustworthy, which helps develop rapport with them. Additionally, you will have developed a more comprehensive view of the matter, which can aid in developing potential solutions. As a result, your healthcare leaders will feel understood and that their point-of-view was considered. Over time, this will help you in developing a stronger business relationship with them.

Pulling it All Together

Challenging assumptions is an ongoing process that requires self-awareness and an open-minded approach. By practicing these tips, you can develop a more informed perspective on the various compliance-matters you are working on. Over time, this approach helps you achieve results that are compliant—and business friendly, allowing you to effectively navigate the politics of healthcare.

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When Communicating About Compliance—“Find Out Before You Flip Out”

If you’ve been paying attention to social media lately, you know much has been said about the intersection of compliance and the Apple TV series, “Ted Lasso”.

If you’re not familiar with the show, I’ll give you a brief thumbnail.

Jason Sudeikis, plays Ted Lasso, a midwest college football coach who is hired to lead an English soccer team (“AFC Richmond”). As the series begins, “Rebecca”, the new team owner via a recent divorce, attempts to sabotage her ex-husband’s soccer team by hiring Ted because of his inexperience. As the series goes on, you come to find out that Ted’s folksy-optimism proves to be an unexpectedly successful leadership style.

Going back to my comment about the show intersecting with compliance…for me, there was a moment in the third and final season very familiar to a conversation I recently had with a colleague.

In the eighth episode of that season, Ted, who was confronted with his own divorce, has an encounter with his ex-wife and her new partner and he learns of an upcoming trip they’re taking to Paris. Upon hearing this news, Ted reveals to his closest confidants on the team, (affectionately called the “Diamond Dogs”), that his ex-wife is getting married. When pressed by the Diamond Dogs to explain how he came to this conclusion, Ted tells them that she and her partner are going to Paris. Collectively, the Diamond Dogs become concerned with his conclusion and challenge Ted’s assumption. The discussion ends with one of them saying to Ted…

“You should find out before you flip out.”

When it comes to the daily work of a compliance officer, we should also follow that advice, but stated a little more gracefully…you should avoid jumping to conclusions. That is true whether you are conducting an investigation or audit, advising leadership on a compliance-related risk, or anything in between that involves gathering information to make a decision.

Jumping to Conclusions

Jumping to conclusions is a common form of cognitive distortion, or a faulty way of thinking. For example, if you meet another person for the first time and the other person doesn’t smile at you, you might conclude that the person doesn’t like you, though there are alternative explanations for that behavior (e.g., moments before your encounter, the other person just learned a family member’s car was broken into).

Jumping to conclusions can take on many forms, such as:

• Mind-Reading (i.e., someone believes they understand how somone is thinking without supporting evidence).

• Overgeneralization (i.e., someone assumes that because they experienced a negative result from an action once, he or she will always experience the negative result from that action).

• Labeling (i.e., someone makes an assumption of others based on opinions or behaviors of others sterotypically associated with a group they are not a part of).

• Fortune Telling (i.e., someone assumes they know what will happen in the future).

In the context of compliance work, jumping to conclusions means making assumptions based on incomplete facts. For example, let’s assume you have oversight for HIPAA in your organization. A department director reports that an employee has snooped into the medical record of a coworker. At this particular point in time, you don’t have all the facts to reasonably conclude whether or not a violation occurred. For that reason, until you have gathered all your facts it’s best to label such behavior as “an alleged HIPAA violation” or a “potential breach” . Something that signals to others that an official conclusion has not been made.

Those who jump to conclusions often do so because they fail to realize they’re missing pieces of information—or they are overly confident in their ability to analyze facts. In either event, jumping to conclusions leaves gaps in logic which has the potential to lead to fallout.

The Fallout from Jumping to Conclusions

If you jump to conclusions, there are a couple of ramifications that can arise.

First, there is potential you were led to a wrong conclusion. This can create confusion if you have to circle back and communicate a different conclusion to your audience. While everyone makes mistakes from time to time, you don’t want this to become a pattern. If this becomes a pattern, your leaders may begin to lose trust and confidence in your ability to perform your job.

Additionally, jumping to conclusions can create conflict or confusion with others who may have drawn a different conclusion. While the conflict or confusion can eventually work itself out, doing so will require everyone to expend additional time and effort that otherwise could’ve been avoided.

Finally, another ramification can arise if you jump to a conclusion by labeling conduct as a violation prematurely. It can create an environment of unnecessary heightened risk, akin to shouting “Fire!” in a crowded theater. When it comes to compliance work, you’ll be better positioned to gain the buy-in from your healthcare leaders if you can maintain a calming presence as you are responding to a compliance issue.

The takeaway?

Make sure that before any official conclusions are made, your opinion is based on a thorough and comprehensive review of the facts.

Tips to Avoid Jumping to Conclusions

To reduce instances of jumping to conclusions, here are a few suggestions:

• Slow Down and Consider your Facts. There is no prize for being the fastest to complete an investigation. Slow down and ask yourself whether you have the facts to support your conclusion?

• Challenge your Assumptions. Ask yourself…is this conclusion based on fact or personal opinion?

• Reflect Upon a Time You Were Wrong. Think back to a time when you jumped to the wrong conclusion. Could the current situation you are facing be similar?

• Take the “Diamond Dogs” Approach. Run your scenario by a trusted resource and see if he or she is coming to the same conclusion that you are—or challenging your assumption? We often get so close to what we’re working on that we can start to see things that don’t exist. A fresh perspective can be a great reality check to ensure you have the facts to support your conclusion. Your supervisor often will be the best resource to help you in this situation.

Pulling it All Together

Navigating the politics of healthcare successfully requires a diplomatic approach to your communications. Part of that diplomatic approach means ensuring your conclusions are based on verifiable facts. In today’s fast-paced working environment, there can be pressure to act quickly rather than spend the time needed to analyze the facts and requirements. Being able to make inferences based on available information is a key skill for any compliance officer, but you have to be careful not to make your conclusions based solely on inferences.

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How to Effectively Communicate with Healthcare Leaders About Compliance Issues

A few weeks ago, I wrote about some strategies for effectively communicating with physicians about compliance issues. If you missed it, you can find that article here.

Piggybacking off of that discussion, the focus of this article is another specific audience that compliance officers have to interact with on a daily basis—the healthcare leader.

For purposes of discussion, I am broadly defining a healthcare leader to be anyone that is making administrative business decisions for the organization, who is also in a leadership role (e.g., C-Suite, department director, manager, or a supervisor). Since these folks possess the ability to make business decisions—and influence the actions of others—it is in your best interest to know how to effectively communicate with them. Possessing this skillset better positions you to gain their buy-in which can help you in navigating the politics of healthcare.

So let’s take a look at this particular audience and dive into some strategies for effectively communicating with them about compliance issues.

Healthcare Leaders as an Audience

When it comes to healthcare leaders, there are a couple of considerations to keep in mind that impact how they communicate with you.

The first is their education. Many leaders possess advanced degrees, such as MBAs, MPHs, JDs, or PhDs. That means they have been trained to be analytical in how they approach their decisions. In their professional lives, most healthcare leaders function through a groupthink model. For example, before a CEO will make a decision, he or she will have asked for input from various members of his or her leadership team. From the CEO’s perspective, each stakeholder is responsible for providing input from their respective POV. The CEO will then take this input under advisement to help shape his or her decision. When you are communicating with healthcare leaders, you’ll be more effective if you are mindful of this approach and apply it to how you approach your own work.

The second consideration is the fact that healthcare leaders are driven to be career oriented, which impacts how they make decisions politically. They view the business decisions they make as the steps along the way in a marathon, not a sprint. They put in long hours, often sacrificing their work-life balance in order to navigate political issues with physicians and other healthcare leaders. This is how they advance up the corporate ladder. As a result, healthcare leaders are savvy at operating with the big picture in mind—which is to say that they have a self-interest not to make political mistakes costing them their careers. For that reason, analyzing any compliance issue should take into account any political self-interests of those healthcare leaders involved.

Now that we’ve put some context around this particular audience, let’s take a look at some strategies that can help you when communicating with healthcare leaders about a compliance issue.

Know How Decisions Are Made in the Organization

One approach for effectively communicating with your healthcare leaders about a compliance issue is to demonstrate to them that you know how decisions are made in the organization. For example, if you are working on an issue that has a financial component to it, be mindful that a CEO will not make a decision unless the issue has been vetted by the CFO. So that means if you are meeting with the CEO to discuss the matter, you need to either invite the CFO to participate or, alternatively, let the CEO know you have already vetted the matter with the CFO. If taking the latter approach, you need to also be prepared to communicate what the CFO’s response was and why.

Taking this approach demonstrates to the CEO that you understand he or she won’t make a deci- sion without the CFO’s input, and that you were prepared to address that concern. Knowing how decisions are made in the organization will help reduce any frustrations your leaders may have with you in operating inefficiently.

Be Mindful of the Knowledge Gap

This one I can’t stress enough…as you are communicating with a healthcare leader about a compliance issue, always—and I mean always—be mindful of the knowledge gap that may exist between you and the healthcare leader about a compliance requirement.

Keep in mind these folks likely will not be as knowledgeable about compliance programs and the rules and regulations as you are. For that reason, you may need to take a step back and explain terminology you might not otherwise have to think about. It’s kind of like trying to explain to a four-year-old what the word “anyway” means. There are some words we get so close to because we use them all the time that we never even think about actually defining them.

The point here is to assume your healthcare leaders know nothing about the rules. It will help ensure that your communication logically flows from one point to the next, and everyone is on the same page with what is expected. It also cuts down on the time you have to spend responding to questions and provides for a smoother discussion to get their buy-in.

When You Bring a Problem, Bring a Solution Too

This approach relates to when you have identified a compliance matter that needs to be addressed. When you’re faced with this scenario, make sure you are communicating the identified issue—and the proposed solution to the leader. For example, let’s assume you have identified that an employee has snooped into the medical record of another employee. When you first alert your appropriate leader, explain what occurred but also the proposed steps to resolve the matter and prevent a future occurrence.

Healthcare leaders do not like surprises, especially ones putting them and the organization at risk. When you take this approach, you will be reducing their anxiety by communicating a clear path for mitigating risk and restoring the organization back to a state of certainty.

Mirror Their Communication Style

Finally, an overall approach to communicate effectively with your healthcare leaders is to mirror their communication styles. Everyone has a preferred communication style. For example, do they prefer phone calls or email? Are there certain times of the day you can reach them in person, by phone, or by email?

The point here is that if you don’t know your leader’s preferred style, then either ask them, or be observant of it and then mirror it. When you mirror their communication style, leaders will see you more like a business partner and less like an obstacle, which can help you gain their buy-in.

Pulling It All Together

Due to the nature of our role in the organization, we are in a position to influence the behavior of others on a daily basis, including the healthcare leaders in our organization. In order to positively influence their behavior, you need to communicate your compliance message in a way that results in gaining their buy-in. By focusing on the above strategies, you will significantly increase your chances of obtaining their buy-in, and be in a far better position for navigating the politics of healthcare.

One final note is that if you missed the article on communicating effectively with physicians about compliance issues, I would encourage you to check it out. There are some concepts in that article that transfer over to times when healthcare leaders are your audience.

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If You Want Buy-in to the Compliance Program—Make it a Safe Place to Ask Questions

When I think of a culture of compliance, I tend to define it as a commitment throughout all levels of the organization to do the right thing and do things right. In my experience, what I have found is that it takes a village of truly committed folks throughout the organization in order to pull that off.

It’s not an insurmountable task, but it is one that I feel requires some self-awareness about how the compliance staff are interacting with others in the orgnization. For example, are they creating an environment where others feel psychologically safe to ask compliance questions?

According to Megan Martin, writing for Forbes, “Psychological safety is the ability to show and employ one’s self without fear of negative consequences of self-image, status, or career. In the workplace, it is a shared belief held by members of a company, department, or team that the team is safe for interpersonal risk-taking.”

Now apply this concept to our world. I think the most significant way to promote a culture of compliance, and navigate the politics of healthcare, is to ensure your compliance program is a psychologically safe place for your workforce members to ask questions. (Here, I would define “workforce members” as not only employees, but also contract labor, students, and volunteers.)

So how do you make your compliance program a psychologically safe place to ask questions?

 Below are some strategies that may help.

Give Others Permission to Ask Questions

One way to make your compliance program a psychologically safe place is to give your workforce members permission upfront to ask questions. Some examples include:

• Before I proceed with the training, please know this is a safe place to ask questions.

• For purposes of our conversation today, I want you to know I subscribe to the concept of there are no stupid questions.

• As we go forward, if you have any questions, please feel comfortable in asking them.

Everyone comes from different backgrounds, personally and professionally. In my experience, it’s best not to assume your workforce members will feel safe in asking questions. I once worked in an environment where leaders would become super frustrated when people asked questions, or worse, they limited staff in time or the number of questions they could ask.

Now, I know what you may be thinking.

“Huh?”

I was thinking the same thing too.

When I changed roles, I felt a sense of culture shock when I was actually encouraged to ask questions. It was a significant indicator of safety that I was given to process information in my own way, including by asking lots of questions. So don’t assume your staff know it’s a safe place to ask questions. They could be a little traumatized from their prior working environment.

Even if you do make a disclaimer, you should reinforce the concept of safety in asking questions when staff are reluctant. You can do this by giving them an opportunity to ask questions offline, (If there are no more questions, you can always reach out to me at xxx-xxx-xxxx or via email.)

Show Others that “I don’t know” is an acceptable answer

Another way to make your compliance program a psychologically safe place to ask questions is to be vulnerable yourself. Simply say “I don’t know” when you don’t know the answer to a question.

I think there is an unwritten expectation of newer compliance officers to know the answer to every question. I know I was guilty of it when I started. In my experience, that’s just not a realistic or practical. When it comes to analyzing a compliance-related question, the regulations change frequently. Often you have to consult them to validate your answer is still correct.

Over the years I had to get comfortable in saying “I don’t know” when a question was asked that I didn’t know the answer. What I figured out is that the way to get comfortable, is making sure those asking me the question felt comfortable in my answer. The way I did that was saying...

I don’t know the answer, but I will look into this and get back to you.

The key in maintaining trust in that answer though is to make sure you do follow-up with the actual answer.

If you lead by example in saying “I don’t know,” you will create a ripple effect through the organization. Others will see that it is okay to say “I don’t know” to a question. This will leave staff feeling your compliance program is a psychologically safe place to ask questions when they have them.

Encourage and Reward Questions

Finally, another way to make your compliance program a psychologically safe place to ask questions is to encourage questions and reward those who ask them. 

If you think about questions, they are critical to the work we do. In the context of a compliance investigation or an audit, we can’t determine a solution until we define the problem. Questions are important tools for defining the problem. They help you determine if there is any difference between the facts you have (i.e., compliant or non-compliant), and the ones you want (i.e., compliant). In the context of delivering education or discussing a potential issue, questions from employees signal curiosity, which demonstrates engagement with your compliance program.

If you want to encourage questions, don’t use closed ended ones that can be answered with yes or no (e.g., Are there any questions?) Instead, use open-ended questions. Leading with the words “what” or “how” can help you reframe a question to be open-ended. Some examples include: 

• What questions can I answer?

• What areas are you struggling with?

• What concerns you the most about this new requirement?

• How will this change affect your department?

• What other issues are important to you?

• What processes will your department need to change to remain compliant?

Taking the approach ensures an honest and open discussion that creates a psychologically safe place for others to ask questions and share information.

On the backend, you want to reward staff for asking questions (e.g., That was a great question. Thank you for asking it.) Long ago (...like 20 years ago), I had a supervisor once tell me, “I’d rather you ask questions, then not. It helps make sure we do things right, the first time.” That wisdom has stuck with me, and I carry it forward on a daily basis when I’m meeting with clinical, operational, and compliance colleagues. He made me feel not only safe – but as though I had a responsibility to engage deeply with questions so I could help shape a solution. When you encourage and reward questions, you are sending a message to others that your compliance program is a psychologically safe place to ask questions, which helps improve your organization’s overall culture of compliance.

Pulling it all Together

It’s a bit counterintuitive – to get people to be compliant, we have to give them the power to question us about the regulations or compliance concepts. If we want them to do the right thing and do things right though, we have to let them ask questions so they can truly embody the policy or practice—not just go through the motions. You have to keep in mind that your workforce members are not as close to the compliance program and the regulations as you are. There is a knowledge gap has to be closed. The only way to do that is through asking questions and providing answers.

As it relates to navigating the politics of healthcare, taking this approach also does wonders for building strong relationships with your workforce members and getting buy-in to your compliance program’s agenda.   

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To learn about additional communication strategies, check out my new book…

How to Effectively Communicate with Physicians About Compliance Issues

When it comes to communicating diplomatically with physicians about compliance issues, it can be a little—oh what’s the word? Tricky?

Over the years I’ve come to realize that it is important to keep a few thoughts in mind about physicians when they are your audience. First, physicians tend to be competitive by nature. Their educational experience consisted of striving to be the top of their class in order to enhance their career path.

Also, physicians, unlike healthcare leaders, were trained to be autonomous decision makers. As a consequence, physicians have an internal expectation to be efficient with their decisions. The autonomous decision-making trait of physicians is much different than the groupthink model of healthcare leaders.

Finally, physicians are specifically trained to be precise. As a result, they tend to expect the same from those they work with (whether it’s clinical or administrative staff).

Since physicians are trained to make their own decisions, they tend to not like to be told what to do. Unfortunately for you as the compliance officer, they will see your communications with them as doing just that. Additionally, some physicians tend to feel “the rules” are a nuisance, getting in the way of providing patient care.

So how can you shift a physician’s mind-set from “You can’t make me do that” to one that is engaged in compliance?

Below are some communication strategies that will help.

Define Your Message Going In

When you’re communicating with physicians about a compliance matter, before meeting with the physician, define your message going in. More specifically, what are your concerns, and what is your rationale for those concerns? For example, assume you have identified a lack of documentation in the medical record to substantiate the billing of a particular service. In that case, you need to be able to articulate the specific concern, have documentation of the billing requirement at issue, and outline other regulations or authority that impacts billing for the service (Medicare billing guidelines, False Claims Act, etc.).

As part of defining your message, you also need to make sure you have identified any action items you are expecting from the physician. Continuing with the above example, outline what documentation must be present in the medical record going forward.

One final thought to add here is that if you’re working through a complex matter, you may want to consider running the discussion past a physician leader first (such as the CMO or medical director). Since other physicians are the constituency for physician leaders, their interests will be aligned with yours to ensure that the discussion goes smoothly with the physician. For that reason, they can provide helpful and constructive feedback to help shape the eventual discussion with the physician.

“So What Do You Need from Me?”

If there is one single piece of advice I could give you related to physician communications, it is this: before you have a conversation with any physician, make sure you can answer in your head this question: “So what do you need from me?” Taking this approach is consistent with my earlier comment about making sure you have identified specific action items needed from the physician.

Early in my career, I learned this lesson a few times...the hard way. After communicating with physicians on various topics without putting thought into how the discussion might unfold, I consistently ran into this response. I got too focused on what I wanted to say in explaining a concern that I failed to be prepared for a basic question from the audience’s viewpoint.

Being prepared with a response to that question will help you in your communication with the physician for a couple of reasons. First, it demonstrates being efficient with the physician’s time, which they will appreciate. Second, by seeing the topic from the audience’s viewpoint, it will enhance their trust in you that you understand their POV. In my experience, taking this approach has helped me in gaining buy-in from physicians to the compliance program.

Leverage Physician Champions

Another way to diplomatically communicate with physicians is to leverage support from any available physician champions, such as the CMO or medical director. If you work in a hospital setting, there will be a medical staff office with a range of physician champions who may be available. These particular physician administrative roles are designed to address both clinical and administrative concerns involving physicians. As I mentioned earlier, anytime you can have physician-to-physician discussion related to a compliance matter, your chances of buy-in will significantly improve. Physician champions can help communicate your objectives into terms a physician can relate to, and the physician can feel heard if he or she is in disagreement. Generally speaking, CMOs and medical directors will have “ensuring compliance with all federal, state, and local laws and regulations” as a requirement in their contract. To that end, your interests will be aligned.

Pulling it All Together

Due to the nature of our role in the organization, we are in a position to influence the behavior of others on a daily basis—that includes physicians. In order to positively influence their behavior, you need to communicate your compliance message in a way that results in gaining their buy-in. By focusing on the above strategies, you will significantly increase your chances of obtaining their buy-in, and be in a far better position for navigating the politics of healthcare.

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To learn about additional communication strategies, check out my new book…

Now available at Amazon, Barnes & Noble, and most other major book retailers.

How to Deliver Bad News as a Compliance Officer

The work of a compliance officer constantly challenges your ability to remain professional. When you consider the organizational risk involved in our work, combined with the politics of healthcare, you have a recipe for frustration, stress, and anxiety. For that reason, professional communication strategies can help you build stronger relationships with your healthcare leaders. This week, I wanted to focus on one of those strategies: delivering bad news—a common reality associated with our profession.

Defining “Bad News”

Before discussing a communication strategy, we need to first define “bad news”, because I’ll admit, that’s a vague term. Let’s assume you were working on resolving an identified billing and coding issue for a high dollar surgical procedure. You have conducted an investigation and determined the organization does not have documentation to substantiate medical necessity as required by CMS. In addition to addressing process changes to correct the issue going forward, you have identified a six-figure refund that must be paid back to Medicare. Given the financial impact to the organization, it is likely your leadership team, will not be too thrilled to hear this news. Additionally, let’s assume that through the investigation, it has become clear the issue could have been prevented if the one of the leaders had held a direct report more accountable. So you have the potential for a leader to take your news personally too. Awesome.

Developing a Communication Strategy

So, how would you go about approaching your discussion with the leadership team? If it were me, I would spend some time thinking about a strategy. As part of my thought process, I would make sure I have identified a communication plan around two topics:

1. How will I mentally prepare the leaders to hear the news?

2. What is my recommended solution to resolve the issue and prevent a future occurrence?

Let’s take a deeper dive into both these questions.

How will I mentally prepare the leaders to hear the news?

The first question is really aimed at softening the blow of the news you’re about to deliver. It’s no surprise that as humans we tend to have a fight or flight response when confronted with shocking news. Just think about times when you found out about a catastrophic news event. The same shock factor can apply to a healthcare leader when confronted with news of a large overpayment, an employee suspected of drug diversion, or an employee committing fraud.

If you are working on an issue that has such a shock factor, then you need to prepare for that response. Think about being in that person’s shoes and how you would appreciate hearing the information. For example, it may be best to allow the person to hear the information, process it, and then come back at a later time to discuss the topic. This approach can help ensure he or she is engaged in the discussion (and not distracted by the shock). It can also improve your chances of a more effective discussion about next steps.

You may also need to think about whether or not the leader will take the information defensively and if you can do anything counteract that defensiveness. For example, it may be helpful to lead the discussion with things the leader has done well before delivering the bad news. If multiple contributing factors were involved, you can also highlight those factors so the person doesn’t take full ownership. Every situation will be fact-specific, but these approaches may help to mentally prepare the leader to hear the news you’re about to deliver.

What is my recommended solution to resolve the issue and prevent a future occurrence?

The second question is about thoroughly thinking through the discussion. For example, giving thought to other communication strategies, such as anticipating questions, asking yourself “so what do you need from me,” and bringing a solution when you bring a problem. These are all questions you can walk through for responding to this second question and developing your overall strategy for delivering bad news to your healthcare leaders.

Pulling it All Together

Maintaining professionalism is critical to your success as a compliance officer because you need others in the organization to feel comfortable with you and trust you if you expect them to report concerns to you.

If you plan ahead for how you are delivering bad news, it will improve your chances for success because you’re taking a professional approach to an unpleasant conversation. In the short term, developing a strategy can help position you for a smoother conversation. In the long term, it will support your ability to build stronger relationships with your leaders and effectively navigate the politics of healthcare.

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To learn about additional communication strategies, check out my new book…

Now available at Amazon, Barnes & Noble, and most other major book retailers.

How to Maintain a Calming Presence when Responding to Compliance Issues

There is no shortage of opportunities to lose our cool in healthcare compliance. Investigations into high-risk issues (e.g., fraud, drug diversion, privacy breach), all get people’s hearts pumping fast. That can lead to murky thinking, flared tempers, and unproductive trips down rabbit holes.

According to Stressaholic author, Hedi Hanna, this behavior can lead to “second-hand stress”. That is, the issue itself is stressful, but how someone reacts to the issue creates additional stress that is felt by others. Think about a time when you saw a speaker experience technical difficulties like feedback from a microphone. If the speaker fumbles around for a solution or starts yelling at the AV team in the back – what happens? You start to feel anxious for that speaker. You might even lose confidence in the speaker or resent his or her berating behavior.

Now let’s apply that concept to your work as a compliance officer. What does that additional stress do when it shows up as you’re responding to an issue? Nothing good. At best, it’s distracting attention away from your actual response. At worst, it leaves your healthcare leaders questioning your ability to take the lead in managing an issue.

I find that when healthcare leaders come to us with a high-risk issue to resolve, they are functioning in a state of uncertainty and may already feel anxious. I have found this is often the result of them not understanding the regulations as much as compliance officers do. That leaves them unable to see a path forward. If I pile on to that anxiousness, it’s not going to help anyone.

Instead, my aim has been to show up as a problem-solver—someone who can lead the organization out of a mess. A significant way to accomplish that goal is modeling a calming presence as I’m responding to an issue that has been identified.

So how do you maintain a calming presence during stressful times? First, take a deep breath and make sure you’re physically and mentally ready to lead calmly. Then, follow these four approaches which have helped me greatly over the years.

Approach #1-Assess the Threat

When faced with a high-risk issue, the first thing to do is to assess the threat.  At this stage, your focus should be on the big picture, considering questions such as:

• What is the risk to patient care?

• What is the risk to the organization from a compliance and reputational standpoint?

• Does this appear to be accidental or intentional?

• Does this appear to be an isolated incident or a pattern of behavior?

Additionally, as part of your threat assessment, consider whether you or a colleague has seen something like this before. If so, there may be prior experience you can leverage for how to respond to the issue. That can help you remove some of the uncertainty of the next steps needed in order maintain a calming presence.

So what if this situation is unique, and there is no prior experience or other resources to draw from?  If that’s the case, then the latter approaches can help you.

Approach #2: Focus on the Facts—not Opinions or Assumptions

Another way to maintain a calming presence during stressful times is to focus your attention on facts and not opinions or assumptions. That is true whether the opinions or assumptions are coming from you or someone else.

At a very basic level, when it comes to making decisions, we do so based on the information we have available to us. When confronted with responding to a perceived crisis, you have to be able to determine what information is based on fact (i.e., verifiable) and what information is based on someone’s personal feelings.  One way to ensure you are focusing on the facts is to ask yourself “is this conclusion supported by facts or personal opinion?”  

As you are gathering your facts, be mindful about how you are asking questions.  For example, if you are asking a leading question (“Isn’t it true that…”), it’s going to feel like you’re cross-examining the person you’re interacting with. Taking such an approach would only add to their stress and anxiety.  Instead, you want to frame your questions from a place of curiosity—not judgment. Some examples of the types of questions you could ask include the following:

• “I am not familiar with X; please help me understand what you mean when you say X.”

• “ X is an area outside of my expertise; can you tell me what X means?”

• “To make sure we are on the same page, can you explain X to me like you would to someone off the street?”

When you take a curiosity approach to questioning, it demonstrates your thoughtfulness to a particular situation which can lower the stress and anxiety felt by others.

Approach #3: Focus on what you can control and don’t take ownership for what you can’t control

Another way to maintain a calming presence during a time of perceived crisis is to focus on what you can control and avoid taking ownership for what you can’t control. When it comes to responding to an identified compliance issue, one way to maintain that perspective is to focus on the present and the future rather than the past. For example, if one of your healthcare leader’s has entered into a business arrangement that turns out to violate a regulation, that’s a business decision that was made in the past. You can’t control that because you can’t undo what’s been done. Also, that was a business decision that was not yours to make.

Instead, your focus should be on what you can control and the business decisions that are yours to make which lie in the present and the future. More specifically, navigating the organization to resolving the issue (i.e., the present), and taking steps to prevent a future occurrence (i.e., the future). The government recognizes regulatory violations are going to occur and compliance officers can’t be everywhere at all times. That said, once an issue is identified, the government does expect the organization to address them and take steps to prevent future occurrences.

Keeping your focus on the present and the future will help you demonstrate a calming presence through your interactions with others as you are resolving the issue.

Approach #4: Focus on the Process

With any high-risk issue, it’s “the unknown” that probably scares us the most.  That in part is due to the trap that people can fall into with assumptions and opinions that I mentioned above. 

When something has gone wrong, as human beings, it is natural for our mind to shift to a never-ending list of “What ifs” (e.g., What if a government investigation or audit gets triggered from this issue?). If you want to maintain a calming presence you have to avoid falling into the “What if” trap. Instead, make your focus on the process of resolving the issue.

How do you do that?

By keeping the big picture in mind as you approach your work to resolve the issue. That means identifying upfront what your steps are going to be as you move forward.  For example, when an issue first gets reported to you, don’t jump to problem solving. That comes later.  Instead, this is the time to gather information and be thinking about questions like:

• What questions do you need to answer in order to resolve this issue?

• What information do you need in order to resolve the issue?

• Where can you get this information?

• What are going to be your next steps to bring about resolution?

Having a big picture perspective identifies what is most important to focus on—and when it is important to focus on it. This helps you determine what is a true priority, which can aid you in demonstrating a calming presence.

Pulling it All Together

As compliance officers, we are tasked with serving as a problem-solver for the organization. Once an issue has been an identified, you will inherently enter a period of time when emotions will be running high (e.g., anxiousness, frustration, anger).

These are also the times when it becomes important to respond appropriately, so that you can maintain a positive business relationship with others. By following the approaches outlined above, you will develop your skills at self-regulating your emotions so that you create a calming presence felt by others around you. By developing this skill set you will build stronger relationships with your healthcare leaders which puts you in a better position to successfully navigate the politics of healthcare.

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Now available at Amazon, Barnes & Noble, and most other major book retailers.

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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Now available at Amazon, Barnes & Noble, and most other major book retailers.

Lead with a Mindset of "Maybe?" Instead of "No!" When Giving Advice to Healthcare Leaders

In the world of a compliance officer, a sad reality is that with some exceptions, we don’t get to be the hero. One of those exceptions can be consulting to healthcare leaders on new service lines or proposed business deals. When you’re able to allow a healthcare leader to move forward in a manner that is both business friendly and compliant, it feels as if you drained a three pointer at the buzzer in overtime.

OK, that might be a slight exaggeration, but the point is, unlike conducting an audit, these are moments when your leaders will celebrate you. Since these times infrequently occur due to our role as compliance officers, you should embrace them for what they are: an opportunity to demonstrate to a leader you are a business partner and not an obstacle.

When you are consulting to your healthcare leaders, the most professional way to approach this work is to lead with a mindset of “maybe” instead of “no!” when they come to you.

Leading with a Mindset of “Maybe” Instead of “No!”

Compliance questions are a world of gray because most regulations are intentionally written by lawyers to fit changing circumstances over time. Think about HIPAA. For those of us old enough to remember, when HIPAA was signed into law in 1996, there was barely an internet and email. Few of us had cell phones. There was no texting. No social media. No smartphones. If you wanted to coordinate a time and place to meet up with your buddies, you called each other ahead of time. If they answered, they showed up; if they didn’t, well, they missed out. The point is, even though these forms of communication either didn’t exist or barely existed in 1996, we still have to apply them to HIPAA in today’s modern communication world.

When it comes to the language of healthcare regulations, there will be circumstances when it is clear you cannot engage in certain conduct. There may also be times where workable solutions do exist, ones that do not jeopardize compliance. Finding these workable solutions is the sweet spot you should be seeking when consulting to healthcare leaders.

(Note: This is where thinking like a healthcare leader and understanding their point-of-view will help you).

Fallout from the “No!” Mindset

If you go into a discussion with a leader about a new business venture with a mindset of “No!”, you’re inhibiting your ability of finding a workable solution. Over time, it can have disastrous consequences for you and the compliance program. I say that because I have seen it happen with other compliance officers over the years. They become known in the organization as the person who only says “no.”

And then what happens?

Their leaders go around them to find someone else who will work with them, or worse, they avoid the compliance officer and do what they want anyway. The end result is a mess that could’ve been avoided had the compliance officer not taken a standoffish position right out of the gate.

Pulling it All Together

An effective compliance program takes a village of committed folks throughout all levels of the organization in order to pull that off. That means having your healthcare leaders coming to you proactively instead of reactively. If that is the type of compliance program you want to foster, then you have to encourage them to come to you. Leading with a mindset of “Maybe” instead of “No!” does just that. It sends a message to the leader that you are keeping an open mind and willing to put in the time and effort to try and help them.

Over time, this approach encourages them to come to you on the front end for advice rather than avoiding you and creating a mess on the back end. There will be times when “no” truly is the answer, but saying no should be the last word out of your mouth. Not the first.

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Are you interested in more content like this?

Check out my new book, Navigating the Politics of Healthcare: A Compliance Officer’s Guide to Communication, Relationships, and Gaining Buy-in. It’s now available at Amazon, Barnes & Noble, and most other major book retailers.

How to Get a Compliance Officer to Think Like a Chief Nursing Officer

For the compliance officer, an effective strategy for navigating the politics of healthcare is to think like a healthcare leader. This is true whether you’re consulting to leaders on a proposed business deal, conducting an investigation, or anything in between.

Last week I talked about thinking like a CMO and how position compliance to someone in a CMO role. This week we’ll take a look at another leader that the compliance officer has to interact with when it comes to clinical matters—the CNO. We’ll look at CNO’s role and responsibilities, what shapes their point-of-view (POV) and how to position compliance to appeal to a CNO’s POV.

CNO Role and Responsibilities

The CNO is the highest-ranking nursing leader in the organization. Overall, the CNO’s role is to ensure that patient care and clinical quality standards are maintained. In fulfilling this duty, CNOs have the responsibility of overseeing the daily operations of nursing staff, which may also include other clinical staff (e.g., lab techs). CNOs tend to have significant knowledge of the organization’s clinical processes and procedures as well as local, state, and federal regulations impacting clinical care services.

Similar to other senior management positions, CNOs are often excellent communicators, having spent years developing their leadership and business skills. CNOs are often highly skilled in critical thinking and strategic planning. They also have the ability to adapt quickly to unexpected changes as their clinical staff are required to do on the floor every day.

While the specific duties of a CNO will vary, they often include the following:

• Clinical operations oversight. Overseeing the daily clinical operations of the organization, including planning, organizing, coordinating, and directing clinical care services.

• Nursing leadership. Serving as a nursing spokesperson to the board, other members of senior management, and the employees.

• Physician and provider liaison. Serving as a communication link between clinical staff and physicians or other healthcare providers.

• Patient safety oversight. Ensuring any patient-safety-related issues are resolved with specific steps outlined to prevent future occurrences.

• Clinical performance. Ensuring the organization is meeting identified clinical metrics tied to quality, reimbursement, and patient satisfaction.

• Financial performance. The CNO ensures clinical departments are meeting operational budgets.

• Clinical policies and procedures. Overseeing clinical policies and procedures to ensure they are developed, implemented, and current as well as ensuring staff are trained on them.

• Organizational compliance. The CNO must ensure the organization is maintaining compliance with all federal, state, and local laws and regulations as well as supporting a healthy culture of compliance.

Thinking Like a CNO

A CNO’s POV is going to be shaped by three primary self-interests. First, what is the best interest of the patient? If a negative outcome occurs involving a patient, the CNO may be involved to oversee the matter. Relatedly, a CNO will be thinking about how best to provide leadership to ensure the issue is resolved and that steps are taken to prevent future occurrences.

Second, what is in the best interest of the organization? Here, the CNO’s focus is going to be ensuring the organization is competitive in the market and meeting certain clinical standards. For example, CNOs may implement new nursing strategies or revise existing ones to ensure patients receive high-quality, safe, and efficient care.

Finally, what is in the best interest of the clinical staff? Here, the CNO’s focus is going to be ensuring effective communication and processes exist to support clinical staff in making decisions that impact patient care.

CNO Political Pressures

A CNO’s POV is also going to be shaped by a number of political pressures. While not an all-inclusive list, some of these pressures include:

• The CEO/board and community expecting the CNO to deliver high-quality care to patients.

• The CEO/board and community expecting the CNO to keep patients safe and resolve identified clinical risk concerns involving patient care.

• The CEO/CFO/board expecting the CNO to meet quality standards tied to reimbursement.

• The CEO/board expecting the CNO to successfully pass organizational surveys and inspections tied to quality of care and patient safety.

• The CFO expecting the CNO to meet operational budget goals and do more with less.

• Department leaders expecting the CNO to keep up with the clinical staffing, equipment, and technology resources of the organization’s competitors.

• The physicians expecting the CNO is to resolve workflow concerns involving physicians and clinical staff members.

• The government and the compliance officer expecting the CNO to ensure the organization remains compliant with all laws and regulations.

Positioning Compliance for a CNO’s POV

When it comes to your work as a compliance officer, be thinking about it from the CNO’s perspective, which means there are two areas of focus. First, how does your work impact patients? Second, how does it impact clinical staff? For example, assume you were communicating with the CNO about a new regulatory change affecting operations. What impact will this change have on the communication between staff who are serving the patients? Will new policies and procedures, forms, or checklists need to be developed? Who will be responsible for implementing them? Who needs to be trained on the new changes, and who is responsible for conducting the training? These are just examples of some of the questions you need to anticipate a CNO may ask you as you work together on a compliance matter.

Pulling it All Together

Having an awareness of your CNO’s role and responsibilities, POV, and political pressures will help you understand how best to position a compliance matter for success. To help gain buy-in to your compliance program, develop a strong business relationship with your CNO. As an individual with clinical oversight for the organization, he or she is going to be deeply knowledgeable about clinical processes and procedures. For that reason, CNOs can provide you valuable insight into clinical operations and help enlist clinical staff to support your compliance program activities.

How to Get a Compliance Officer to Think Like a Chief Medical Officer

For the compliance officer, an effective strategy for navigating the politics of healthcare is to think like a healthcare leader. This is true whether you’re consulting to leaders on a proposed business deal, conducting an investigation, or anything in between.

Last week I talked about thinking like a healthcare CFO and how position compliance to someone in a CFO role. This week we’ll take a look at another leader that the compliance officer has to interact with when it comes to physician-related matters—the CMO. We’ll look at CMO’s role and responsibilities, what shapes their point-of-view (POV) and how to position compliance to appeal to a CMO’s POV.

CMO Role and Responsibilities

A CMO has the overall responsibility for ensuring that safe, effective, and high-quality care is delivered to patients by physicians on the medical staff. CMOs are typically physicians who have made a shift from clinical practice to an administrative role, either on a part-time or full-time basis. The CMO is a liaison role between the hospital and various internal and external parties. These parties may include other members of senior management, the board, and community business partners, as well as patients and their families. The CMO represents the hospital but also serves as a spokesperson for the employed or contracted physicians on the medical staff.

While the specific duties of a CMO will vary, they typically involve the following:

• Physician services operational oversight. Overseeing all clinical operations involving physicians on the medical staff.

• Established clinical performance goals. Defining and monitoring clinical performance to ensure goals are met by the medical staff.

• Quality improvement. Overseeing any quality improvement activities involving physicians on the medical staff.

• Policies and procedures. Assisting with policy and procedure development specific to the medical staff (e.g., organizational policies, medical staff bylaws, medical staff rules and regulations).

• Accreditation oversight. Assisting departments or organizations in obtaining and maintaining accreditation (e.g., The Joint Commission, American College of Radiology).

• Financial oversight. Assisting the organization in developing cost-containment strategies that involve the medical staff, in addition to ensuring that quality-based metrics tied to reimbursement are met.

• Strategic planning. Participating in long-range planning of the organization, including decisions related to equipment, budgeting, and physician staffing.

• Education. Facilitating educational offerings to physicians on the medical staff or offerings to the community.

• Resolving identified issues. Assisting with physician-to-physician communication as well as communication with patients and their families to resolve clinical care concerns.

• Organizational compliance. The CMO must ensure the organization is maintaining compliance with all federal, state, and local laws and regulations as well as supporting a healthy culture of compliance.

 In order to carry out these responsibilities, physician leaders like a CMO need to be excellent communicators, adept at conflict resolution. They also need to possess the technical skills to step in and review either a physician’s performance or a department’s clinical processes.

A CMO’s POV

The POV of a CMO is going to be shaped by three primary interests. First, what is in the best interest of the patient? As a medically trained physician, the CMO is predisposed to be thinking about all operational decisions from the perspective of the patient.

Second, what is in the best interest of the organization? Here, the CMO’s focus is ensuring the physicians on the medical staff are following the organization’s policies and procedures as well as all applicable regulatory requirements. Additionally, the CMO will be motivated by fulfilling the organization’s strategic plan by being competitive in the market and providing high-quality care.

Finally, what is in the best interest of the physicians? Given the CMO’s role, all physicians on the medical staff, regardless of specialty, are going to be the CMO’s constituency. The CMO serves as a voice for them as he or she resolves identified issues with the hospital or any external parties (e.g., patient, government agency).

CMO Political Pressures

A CMO’s POV is also going to be shaped by a number of political pressures. While not an all-inclusive list, some of these pressures include:

• The CEO/board and community expecting the CMO to deliver high-quality care to patients.

• The physicians on the medical staff expecting the CMO to fight for what they think is the right.

• The CEO/board expecting the CMO to keep the physicians aligned with policies, directives, and business goals of the organization.

• The CEO/board expecting the CMO to resolve any clinical performance or behavior-related concerns involving physicians on the medical staff.

• The CFO expecting the CMO to meet operational budget goals and do more with less.

• The physicians expecting the CMO to keep up with the clinical staffing, equipment, and technology resources of the organization’s competitors.

• The physicians expecting the CMO to resolve workflow concerns involving physicians and clinical staff members.

• The government and the compliance officer expecting the CMO to ensure the organization remains compliant with all laws and regulations.

Positioning Compliance for a CMO’s POV

When it comes to your work as a compliance officer, be thinking about it from the CMO’s perspective—which is to say, like a physician. Keep in mind that what you are telling the CMO is going to be interpreted from the vantage point of  a physician and how patients are going to be impacted. Any time you have a need to speak with a physician about a compliance matter, it is best to have a CMO, or another appropriate physician leader, involved. In my experience, physicians respond more positively to a compliance message when another physician is involved.

 Pulling it All Together

Having an awareness of your CMO’s role and responsibilities, POV, and political pressures will help you understand how best to position a compliance matter for success. Similar to the other healthcare leaders we’ve covered the past few weeks, you will understand why certain decisions are made and recognize why you are getting pushback. You will also develop a skill to anticipate future questions or decisions from your CMO.

To help gain buy-in to your compliance program, develop a strong business relationship with your CMO. The CMO can be a critical ally for you when addressing identified physician clinical or behavioral concerns impacting the compliance program. Additionally, the CMO can serve as a physician champion to help promote the compliance program to all physicians on the medical staff.

Now, that we’ve climbed into the minds of a healthcare CEO, CFO, and CMO next week we’ll take a look at one last healthcare leader—the Chief Nursing Officer (CNO). 

How to Get a Compliance Officer to Think Like a Healthcare CFO

For the compliance officer, an effective strategy for navigating the politics of healthcare is to think like a healthcare leader. This is true whether you’re consulting to leaders on a proposed business deal, conducting an investigation, or anything in between.

Last week I talked about thinking like a healthcare CEO and how position compliance to someone in a CEO role. This week we’ll take a look at another leader that the compliance officer has to interact with—the healthcare CFO. We’ll look at CFO’s role and responsibilities, what shapes their point-of-view (POV) and how to position compliance to appeal to a CFO’s POV.

CFO’s Role and Responsibilities

As the highest ranking financial official in the organization, the CFO has the overall responsibility of managing the organization’s finances. A CFO oversees the organization’s financial plans, including budgeting, taxation, and developing strategies for boosting revenue. The CFO also ensures that internal controls are in place to manage the organization’s finances in a cost-effective manner. From a staffing perspective, the CFO is responsible for managing the organization’s financial and accounting department personnel. The CFO also serves as spokesperson to the CEO and board related to the organization’s finances.

Some specific CFO responsibilities include the following:

• Financial forecasting and budgeting. CFOs develop and administer operating and capital expenditure budgets as well as manage income and expenses.

• Revenue management. CFOs oversee the organization’s revenue, including strategies for increasing cash flow, billing and claims management, and investment.

• Financial analysis and performance reporting. CFOs routinely report out on the financial performance of the organization, including any strengths and weaknesses.

• Contract negotiation. CFOs help negotiate payment for vendor contracts and reimbursement from contracted payers.

• Funding source obligations. CFOs oversee financial obligations to funding sources (e.g., banks, commercial lenders, tax-exempt issued bonds, donors).

• Tax filings and financial reporting. Whether for profit or not, CFOs ensure the organization is compliant with all applicable tax filings and other reporting obligations.

• Organizational compliance. The CFO must ensure the organization is maintaining compliance with all federal, state, and local laws and regulations as well as supporting a healthy culture of compliance.

In order to carry out these responsibilities, the CFO needs to balance the management of operations against the organization’s finances to ensure it is effectively utilizing resources. As a member of senior management within the organization, the CFO also needs to be adept at communication. Internally, he or she needs to be mindful of what information needs to be shared with others, to whom it needs to be shared, and when it needs to be shared. Externally, the CFO has to manage relationships with several parties such as business partners or competitors, payers, community leaders, government regulators and patients (and their families) to name a few.

A CFO’s POV

Generally speaking, a CFO’s POV will be focused on the organization’s overall financial health. Thinking like a CFO means that you are factoring in financial impact to the organization for any business decision you make. If you’re discussing a compliance matter with a CFO, here are some examples of the types of questions he or she may be thinking of:

• How will this business decision impact the organization’s budget?

• What steps can be taken to mitigate financial risk?

• How does this business decision impact the organization’s contracts with payers?

• How does this business decision impact patient accounts (e.g. refunds or adjustments)?

• If the organization is tax exempt, does this impact the organization’s IRS 990 filing?

 CFO Political Pressures

A CFO’s POV is also going to be shaped by a number of political pressures. While not an all-inclusive list, some of these pressures include:

• The CEO/board expecting CFO to develop and administer a budget that allows the organization to drive a competitive strategy.

• The CEO/board expecting the CFO to control costs and generate revenue.

• Department leaders expecting the CFO to ensure the organization is keeping up with the space, equipment, staffing, and technology of its competitors.

• The CEO/board expecting the CFO to meet identified financial performance goals.

• The CEO expecting the CFO to negotiate favorable reimbursement rates with payers.

• The government and the compliance officer expecting the CFO to ensure the organization remains compliant with all laws and regulations.

Positioning Compliance for a CFO’s POV

When it comes to your work as a compliance officer, be thinking about it from the CFO’s perspective. If you were the CFO and listening to me, the compliance officer, what information would you want to know? For example, if you’re conducting an investigation involving an identified billing error, the CFO is going to be asking questions about the financial component of the investigation. More specifically, how many patient accounts are involved? What payers need to be refunded? Does this billing error impact any cost-sharing amounts paid by the patient that also need to be refunded? Does this matter create a cost-reporting error that also needs to be corrected? And of course, similar to the CEO, the CFO is going to want to know what circumstances led to the error and what steps are being taken to correct it going forward.

Similar to comments I made last week about the CEO, when discussing a compliance matter with a CFO, always be mindful of potential internal reporting obligations. More specifically, if you’re addressing a compliance matter of medium to high risk to the organization, the CFO may be duty-bound to report the matter to the CEO or the board.

Pulling it all Together

Having an awareness of your CFO’s role and responsibilities, POV, and political pressures will help you understand how best to position a compliance matter for success. Similar to the CEO, you will understand why certain decisions are made and recognize why you are getting pushback. You will also develop a skill to anticipate future questions or decisions from your CFO.

As a parting tip, to help gain buy-in to your compliance program, develop a strong business relationship with your CFO. As an individual with oversight of the financial operations of the organization, the CFO can enlist support from his or her staff to assist with investigations or audits (e.g., generate claims reports, accounts receivable or accounts payable information, payer data).

Now, that we’ve climbed into the minds of a healthcare CEO and CFO, next week we’ll take a look at another healthcare leader—the Chief Medical Officer (CMO).

How to Get a Compliance Officer to Think Like a Healthcare CEO

For the compliance officer, an effective strategy for navigating the politics of healthcare is to think like a healthcare leader. This is true whether you’re consulting to leaders on a proposed business deal, conducting an investigation, or anything in between.

Last week I talked generally about how to think like a healthcare leader. This week we’ll piggyback off that discussion by focusing on one leader—a healthcare CEO. We’ll take a look at the CEO’s role and responsibilities, what shapes their point-of-view (POV) and how to position compliance to appeal to a CEO’s POV.

CEO Role and Responsibilities

As the highest-level healthcare administrator, the CEO has the overall responsibility for the organization’s day-to-day operations and fulfilling its strategic vision. CEO positions are often filled by individuals possessing business backgrounds; however, there has been an increasing trend of CEOs possessing a clinical background too (e.g., an MD or RN). While the exact CEO responsibilities will vary by organization, they likely will include the following:

• Organizational vision. The CEO must have a vision for the organization’s future, such as an identified market presence or access to high-quality healthcare.

• Strategic planning. The CEO must have an identified roadmap of future goals and objectives for achieving the organizational vision.

• Maintaining financial stability. The CEO needs to ensure the organization maintains financial health and stability. If the organization is a tax-exempt organization, there are additional responsibilities for ensuring it is meeting its charitable mission.

• Recruitment. The CEO must ensure the organization has the physicians and other clinical staff to meet the needs of providing services to the community.

• Patient safety. The CEO must ensure patients are cared for safely through established safety measures.

• Promoting high-quality healthcare. The CEO must be committed to improving the quality of healthcare provided to the organization’s patients.

• Patient satisfaction. The CEO must ensure the organization is meeting established patient satisfaction benchmarks.

• Organizational compliance. The CEO must ensure the organization is maintaining compliance with all federal, state, and local laws and regulations, and maintaining a healthy culture of compliance.

In order to carry out these responsibilities, the CEO needs to fulfill several different roles. First and foremost, the CEO is a business leader. He or she must balance the management of operations against the organization’s finances to ensure it is effectively utilizing resources. CEOs of organizations providing patient care must additionally manage the added pressure of competition from other market participants.

The CEO must also fill the role of politician. They continually have to manage communications and relationships. Since CEOs are responsible for overseeing a number of different operations, akin to those of a small town, the CEO is the face of this community, much like a mayor is for a city. That requires being adept at knowing what information needs to be shared with constituents and when it needs to be shared. Externally, the CEO has to manage relationships with several parties, such as business partners (e.g., physicians), business competitors, government regulators, community leaders, patients (and their families), and the media. Given the demands in managing all these relationships, they must be skilled in communication and conflict resolution. When it comes to a day in the life of a CEO, their schedules are typically packed from early morning meetings to business dinners lasting well into the evening.

A CEO’s POV

A CEO’s POV is going to be shaped by fulfilling the organization’s identified objectives that support the overall strategic plan approved by the board. With that said, many of the decisions a CEO has to make can be traced to one of three self-interests. First, what is in the best interest of the patient? That is true whether the matter is starting a new service line, resolving a complaint, or terminating a physician from the medical staff. Second, what is in the best interest of the organization? Whether it’s a business decision of the CEO or any of his or her direct reports, CEOs are motivated by the ones that result in the least amount of legal, financial, or reputational risk. Finally, the CEOs are motivated by acting in the best interests of their own careers. I’m not saying that to be judgmental, but rather, as a matter of fact. We’re all motivated to act in the best interest of our careers. As part of the organization’s strategic plan and objectives, the board will be evaluating the CEO on how he or she is performing based on criteria set by the board.

A CEO’s Political Pressures

A CEO’s POV is also going to be shared by a number of political pressures. While not an all-inclusive list, some of these pressures include:

• The community expecting the CEO to deliver high-quality, low cost patient care services.

• The board expecting the CEO to do more with fewer resources.

• The department leaders expecting the CEO to provide more resources.

• The physicians expecting the CEO to increase their compensation and have more control over clinical decisions.

• The employees expecting the CEO to be a great leader (inspiring and visionary).

• The community leaders expecting the CEO to be an active participant who is contributing to the community.

• The board expecting the CEO to be competitive in the market.

• The government and the compliance officer expecting the CEO to ensure the organization remains compliant with all laws and regulations.

As you approach your work as a compliance officer, it is important to keep these political pressures in mind as they may provide you with “the why” behind the decisions he or she is making.

Positioning Compliance for a CEO’s POV

When it comes to your work as a compliance officer, you should be thinking about it from the CEO’s perspective. If you were in his or her shoes, what information would you want to know? For example, let’s say you identified a potential breach of one thousand patient records. As the CEO you’re going to want to know the details of what happened and how this issue was discovered. You also want to know the risk involved with a breach (e.g., financial and reputational). Finally, you want to know what steps the compliance officer is taking to correct the issue and prevent a future occurrence.

Keep in mind that depending upon the nature of the issue, the CEO may be duty-bound to report the matter to the board, so consider his or her perspective in carrying out that responsibility. As a general rule, the level of detailed information you need to provide the CEO should match the level of risk involved. For example, if you’re addressing a six-figure overpayment to Medicaid, a high level of detail is needed; if it’s a small refund involving a few claims, an overview or summary will do.

Pulling it all Together.

Having an awareness of your CEO’s role and responsibilities, POV, and political pressures will help you understand how best to position a compliance matter for success. You will understand why certain decisions are made, recognize why you are getting pushback, and have the ability to anticipate future decisions. It will also help you in successfully navigating the politics of healthcare to gain buy-in to your compliance program.

Now, that we’ve climbed into the mind of a healthcare CEO, next week we’ll take a look at another healthcare leader-the CFO.

How to Get a Compliance Officer to Think Like a Healthcare Leader

Assume for a moment you’re not a compliance officer. You’re the chief executive officer (CEO) of ABC Hospital, and you’re looking to expand the hospital’s service line. During a recent strategic planning meeting, your chief operating officer (COO) pitches an idea: “What if we partnered with a XYZ Cardiology, P.C. (XYZ)  to open a new clinic focused on vascular services?” The idea piques your interest. With the assistance of legal counsel, you move forward. You negotiate and sign compliant agreements with XYZ and set a go-live date.

During your most recent meeting with the cardiologists, there was discussion about a need to market this new venture and who would pay for it. The physicians are asking the hospital to bear the costs of marketing because the new clinic is going to be located on the hospital’s campus. You email your compliance officer to ask if the hospital can pay for these expenses since the physicians will be benefiting from the marketing. Your compliance officer responds by saying no. She doesn’t offer an explanation. She doesn’t ask any questions about the venture or the marketing campaign. She doesn’t even offer an alternative option.

If you were this CEO, would you feel supported?

A consistent theme in all of the strategies I will cover in this blog is being mindful of your audience. This is particularly important when it comes to healthcare leaders. That means at times, you need to be thinking like a healthcare leader—not a compliance officer.

That means listening to what they’re telling you, and approaching your work with consideration of their viewpoint, not yours. If you are a leader, what obstacles or challenges do you face? What motivates you in the performance of your role? What political pressures do you face? These are just some of the questions you need to be thinking about when communicating with your healthcare leaders about compliance matters.

Always be Identifying Their Point of View

A significant step toward thinking like a healthcare leader is identifying their point of view (POV). While POV is specific to a leader’s role, personality, and the issue being addressed, there are some POVs that apply to most healthcare leaders. For example, consider the topic of change—I mean from an evolutionary standpoint, not a monetary one. Healthcare at a very basic level is a service industry. Considering that a leader’s role and objectives are to move the organization forward, leaders must continually embrace change in order to succeed. As a consequence, implementing newer, faster, or better ways to deliver healthcare will always be a factor in the mind of your healthcare leaders. As the compliance officer, you have to accept that leaders will always be pushing for change.

Another universally held POV is determining what is in the best interest of the patient. With any business decision a healthcare leader makes, that question floats across the brain. Overall, this POV is focused on what is safe and of high quality yet practical and efficient.

A final example of a universal POV among healthcare leaders is determining what is in the best interest of the organization. Here, this POV is focused on ensuring the organization is moving forward within the market while protecting it from financial, legal, and reputational risk.

Pulling it All Together

Having an awareness for how your leaders think will help you in navigating the politics of healthcare. You will understand why certain decisions are made, recognize why you are getting pushback, and have the ability to anticipate future decisions. In order to think like a healthcare leader, we need to climb into their minds. 

Over the course of the next few weeks, we’ll take a look at several different types of healthcare leaders in a typical healthcare organization providing patient care. We’ll look what shapes their POV, some of their political pressures, and how to position compliance to appeal to their particular POV.

How to Manage Your Interactions with the Usual Suspects of Office Politics

No matter what organization you work for, you will have what I like to call the “Usual Suspects of Office Politics.” Generally speaking, these folks like to engage in various forms of destructive politics that I mentioned in my article related to developing a neutral political strategy.

Since our political strategy is focused on remaining neutral in the organization, you need to know how to manage your interactions with these folks. If you don’t, you may unwittingly end up an accomplice to their cause. When that happens, you jeopardize your ability to effectively navigate the politics of healthcare.

So, let’s take a look at this cast of characters, so you know what to look out for and how to manage them.

The Gossiper

Starting with the most obvious, we have The Gossiper. This person seems to know everything about everyone and takes great pleasure in telling you about it. The Gossiper lacks discretion or a filter. Since their conduct can be destructive in an organization, it is best to identify The Gossiper, be mindful of their motives, and not enable their behavior.

The best way to manage your interactions with The Gossiper is to keep your conversations limited to business, thereby cutting off a potential food source for this individual.

The Toady

Call it what you will (“fawning,” “brown-nosing,” “bootlicking”), The Toady likes to flatter people with compliments, especially those with a superior position in the organization. The problem with The Toady is that the comments aren’t genuine. They’re purely for personal gain. When it comes to The Toady, the good news is that the disingenuous behavior is easy to detect and obvious to everyone. Everyone except The Toady, of course.

The best way to manage your interactions with The Toady is to be aware of their ulterior motive and identify the why behind the flattery. What advantage is this person trying to gain? Be cautious about how much credibility to give them. For the most part, let The Toady do their toady thing. Most healthcare leaders know when someone is being fake.

The Saboteur

Next, we have The Saboteur. Arguably on the other end of the spectrum from The Toady, this person’s objective is not to compliment for personal gain, but rather disrupt for personal gain. This individual thrives off being critical of others, especially in public settings, like a meeting or conference call. The Saboteur can also have passive-aggressive tendencies such as forwarding your email onto others without your knowledge, or replying to your email, along with a laundry list of others, including your supervisor. If throwing people under the bus were an Olympic sport, this person would be a gold medalist—every time.

The best way to manage The Saboteur is to be cautious when communicating with this individual. And think at least two steps ahead. For example, if you send The Saboteur an email, expect that it will get forwarded to others. Thinking ahead will ensure your communication is professional and defendable. Also, keep your focus on the matter being addressed, and not the individual. If you allow The Saboteur to see your frustration, he or she will seize the moment to use it against you.

 The Debater

The Debater loves nothing more in life than playing devil’s advocate. They typically are argumentative and quick on their feet. They’re also not afraid to twist facts to fit their agenda. The Debater is also one you need to be cautious with in your communications. Dialogue in a meeting that is productive to the group’s objective is healthy and should be encouraged. Where you can get into trouble is when debate becomes about the other person and not the group’s objective. The Debater loves to provoke others, so be cautious not to take the bait. Make sure the points you are making are about the group’s objective, not The Debater.

The best way to manage The Debater is to give them space; allow them to be heard. That said, to avoid a conversation spiraling into a never-ending argument, acknowledge and validate their point. Then maintain your focus on accomplishing the goal of the discussion.

 The Credit Poacher

One of my personal favorites is The Credit Poacher. Another disingenuous type, this individual will do whatever it takes to get ahead in the organization, even if it means stealing some ideas and the work of others and passing it off as his or her own.

The best way to manage The Credit Poacher is to be aware of their presence and share your ideas and work product publicly whenever possible. You can also frequently update your supervisor so he or she knows who should be getting credit for the work. If you feel there is a legitimate need to call out The Credit Poacher, the best way to do so is to discuss the matter confidentially with the appropriate leader instead of in a public setting.

The Delegator

Next up is The Delegator. To be clear, the person I’m referring to here is not your supervisor, who of course is empowered to delegate tasks to you. Instead, this particular individual delegates tasks they are not in a position to delegate. Sometimes you’ll see this surface when you volunteer a thought or idea, but rather than your supervisor or a project leader delegating a task to you, someone else on the team does. The Delegator tends to believe the act of delegation is a demonstration of power. The only problem is The Delegator doesn’t actually have the power.

The best way to manage The Delegator is to make sure the task being delegated is within the scope of your role in the organization. If it is, then the request is legitimate and you need to be a business partner by following up on the task. If it is not, then you need to communicate what tasks fall within your role. Regardless of circumstance, if you have a concern about others inappropriately delegating, it is best to confidentially communicate those concerns to the appropriate leader to address with the employee.

 The Advisor

Saving the best for last, we come to The Advisor. Now, unlike all the other characters mentioned above, The Advisor tends be engaged in productive politics. This particular individual is one to whom other healthcare leaders in your organization turn for assistance. They tend to maintain a lot of influence in the organization and have an awareness of what is going on. For that reason, The Advisor can be an asset to you and not a liability.

The best way to manage your interactions with The Advisor is to align with this individual. These folks tend to hold informal power in the organization, which can help you in advancing the compliance program’s agenda when you need leverage or support.

Pulling it All Together

Whether you are involved in a conference call, a meeting, a hallway discussion—or my personal favorite, the meeting after the meeting—pay attention to your surroundings. Pay attention to what’s being said, how it is being said, and who is saying it. These are continual opportunities to observe a wealth of information orienting you to the political landscape around you.

Now that we’ve talked about the various elements of the political landscape around you, next week we will begin talking through another strategy for navigating the politics of healthcare—thinking like a healthcare leader.