Compliance Perspectives

By Adam Turteltaub

An engaged compliance committee can be a dramatic and positive influence on a compliance program.  Danette Slevinski (Chief Compliance Officer of University Hospital) and Judith Marber Fox (founder and CEO of JF Real Compliance Solutions) have seen it firsthand.

So how do you get there?  In this podcast, which is focused on healthcare entities but has easily extractable lessons for all organizations regardless of industry, they share their experiences and lessons learned.

Listen in as they discuss:

* The value of senior leaders, and how to engage them

* The importance of voices on the committee that come from outside of senior leadership

* Comprehensive meeting preparation and how to do it

* The role of the committee charter and how it should be structured

* Conducting the meeting effectively

By Adam Turteltaub

Operating a compliance program in Europe is not the same as running one in the US.  Paris-based Maria Lancri knows this well from having worked as a compliance offer and currently as an attorney with GGV Avocats.

For one, in Europe there is a strong need to consider the position of employees and the union.  They must be consulted on many parts of the program, which means that compliance professionals have to be prepared to explain the advantages to workers of the compliance efforts.

Other challenges include:

* NGOs who scrutinize company activities closely

* The Duty of Care Law, which covers Corporate Social Responsibility obligations

* Tougher privacy law and aggressive antitrust/anti-cartel regulators

* Increased demands on boards to oversee compliance programs

As she explains in the podcast, there is much to do to meet these challenges. In addition, there is a strong need to localize the program, not just the language, but also in approach.

Listen in to learn more about what you need to know to effectively manage your European compliance efforts.

By Adam Turteltaub

Operating a compliance program in Europe is not the same as running one in the US.  Paris-based Maria Lancri knows this well from having worked as a compliance offer and currently as an attorney with GGV Avocats.

For one, in Europe there is a strong need to consider the position of employees and the union.  They must be consulted on many parts of the program, which means that compliance professionals have to be prepared to explain the advantages to workers of the compliance efforts.

Other challenges include:

* NGOs who scrutinize company activities closely

* The Duty of Care Law, which covers Corporate Social Responsibility obligations

* Tougher privacy law and aggressive antitrust/anti-cartel regulators

* Increased demands on boards to oversee compliance programs

As she explains in the podcast, there is much to do to meet these challenges. In addition, there is a strong need to localize the program, not just the language, but also in approach.

Listen in to learn more about what you need to know to effectively manage your European compliance efforts.

By Adam Turteltaub

Joanne Chiedi, Principal Deputy IG and acting Inspector General at the US Department of Health and Human Services, recently addressed the attendees at the 2019 Compliance Institute.  To help inform those who couldn’t attend the event, she was kind enough to record a podcast covering some of the key points from her talk.

Listen in as she delivers several key messages to compliance teams, starting with the call to be bold and take action.  With so much technological change and innovation in healthcare, compliance professionals can’t be shy and must have a seat at the table.  Compliance and innovation must advance together, she argues, both to ensure controls are in place but also to provide compliance teams with data on how the program is performing.

Two keys to future success for compliance teams, according to Ms. Chiedi, are agility and adaptability.  Compliance will increasingly need multidisciplinary teams to work across the organization to gain new insights into program vulnerabilities and develop solutions for addressing them.

This will require compliance leaders to reassess their staffing plans and engage in continuous reprioritization.  Changing times can’t rely on static priorities.

Don’t miss this opportunity to hear what the IG sees coming down the road for healthcare compliance.  And, for those outside of healthcare, it’s good advice, as well.  Technology is changing every industry.

By Adam Turteltaub

Joanne Chiedi, Principal Deputy IG and acting Inspector General at the US Department of Health and Human Services, recently addressed the attendees at the 2019 Compliance Institute.  To help inform those who couldn’t attend the event, she was kind enough to record a podcast covering some of the key points from her talk.

Listen in as she delivers several key messages to compliance teams, starting with the call to be bold and take action.  With so much technological change and innovation in healthcare, compliance professionals can’t be shy and must have a seat at the table.  Compliance and innovation must advance together, she argues, both to ensure controls are in place but also to provide compliance teams with data on how the program is performing.

Two keys to future success for compliance teams, according to Ms. Chiedi, are agility and adaptability.  Compliance will increasingly need multidisciplinary teams to work across the organization to gain new insights into program vulnerabilities and develop solutions for addressing them.

This will require compliance leaders to reassess their staffing plans and engage in continuous reprioritization.  Changing times can’t rely on static priorities.

Don’t miss this opportunity to hear what the IG sees coming down the road for healthcare compliance.  And, for those outside of healthcare, it’s good advice, as well.  Technology is changing every industry.

By Adam Turteltaub

Data risks are enormous for any organization these days, which is why, Marti Arvin (Executive Advisor at CynergisTek) and Don Ahart (Internal Auditor, Hunterdon Healthcare) advocate for data management audits.

As they explain on this Compliance Perspectives podcast (and also at the 2019 HCCA Compliance Institute), a data management audit is about the logistics of your data:  where it is located, how it is classified, where it is stored, how it is used, who owns it, and who is responsible for maintaining it.  That’s even more complex than it sounds because the temptation is to just look across the network, forgetting that much data is saved on laptops, removable devices and even mobile phones.

To avoid getting overwhelmed by the audit, they advise to break it down into manageable parts and recognize that this can be, and probably will be, a multi-year process: once you have the audit done you still need to remediate.

Listen in to learn more about what to look for, how to prioritize risks, and how to make your remediation efforts successful.

By Adam Turteltaub

Data risks are enormous for any organization these days, which is why, Marti Arvin (Executive Advisor at CynergisTek) and Don Ahart (Internal Auditor, Hunterdon Healthcare) advocate for data management audits.

As they explain on this Compliance Perspectives podcast (and also at the 2019 HCCA Compliance Institute), a data management audit is about the logistics of your data:  where it is located, how it is classified, where it is stored, how it is used, who owns it, and who is responsible for maintaining it.  That’s even more complex than it sounds because the temptation is to just look across the network, forgetting that much data is saved on laptops, removable devices and even mobile phones.

To avoid getting overwhelmed by the audit, they advise to break it down into manageable parts and recognize that this can be, and probably will be, a multi-year process: once you have the audit done you still need to remediate.

Listen in to learn more about what to look for, how to prioritize risks, and how to make your remediation efforts successful.

By Adam Turteltaub

It happens to the best and worst of people:  An ethical lapse.  Sometimes it’s minor, and sometimes it’s major.  But it happens.  The question is why and what can we in compliance and ethics do about it.

Professor Stuart Pardau argues in this episode of the Compliance Perspectives podcast that to understand these behaviors it is more instructive to look at the common cases rather than the extreme ones.  And, while doing that, pay close attention to the culture.  For one, corporate culture is a place where compliance can have an impact.  The second reason:  culture can be an effective control.

Some of the other suggestions he provides to prevent lapses:

* Slow down: fast-moving organizations and individuals don’t have enough time to think clearly

* Give people a goal beyond just making money

* Use training that provides rationales and reasons behind policies, not just what the rules are

* Give real-life examples showing the consequences of ethical lapses, including on people’s families

Listen in to learn more about ethical lapses, and how you can help prevent them.

By Adam Turteltaub

It happens to the best and worst of people:  An ethical lapse.  Sometimes it’s minor, and sometimes it’s major.  But it happens.  The question is why and what can we in compliance and ethics do about it.

Professor Stuart Pardau argues in this episode of the Compliance Perspectives podcast that to understand these behaviors it is more instructive to look at the common cases rather than the extreme ones.  And, while doing that, pay close attention to the culture.  For one, corporate culture is a place where compliance can have an impact.  The second reason:  culture can be an effective control.

Some of the other suggestions he provides to prevent lapses:

* Slow down: fast-moving organizations and individuals don’t have enough time to think clearly

* Give people a goal beyond just making money

* Use training that provides rationales and reasons behind policies, not just what the rules are

* Give real-life examples showing the consequences of ethical lapses, including on people’s families

Listen in to learn more about ethical lapses, and how you can help prevent them.

By Adam Turteltaub

Scott M. Giordano, VP, Data Protection, Spirion

Session P14:  GDPR Compliance Post-Mortems:  Lessons Learned from Facebook, Uber and Others

September 15, 2019, 10:30 AM – 12:00 PM

GDPR has been in effect for just months but already tens of thousands of breaches have been reported to data authorities.  Scott Giordano, Vice President of Data Protection for Seattle-based Spirion reports in this podcast that this is a sign that business is taking GDPR seriously.

It also reflects a key requirement of the legislation: the rule requiring notification of a breach – whether by a hacker or even due to a contract violation – within 72 hours.  That requirement forces companies to act quickly.  It is also a mandate that is spreading, with US laws and regulations also increasingly requiring similar notification timelines.

Along with the new legislation has already come enforcement.  Google ran afoul of CNIL, the French data regulator, for the way in which users provided consent to the use of their data.  CNIL concluded it was too difficult for consumers to determine how their data was being used and stored.

In general, Giordano recommends that organizations err on the side of caution.  They should take practical steps to ensure that they are handling data properly, starting with asking the basic question:  is there any reason to question the integrity of the data in their care?

Businesses need to practice information security 101 – both to safeguard the data and to avoid running afoul of regulators – and to conduct a data inventory and risk assessment.

Finally, looking to the future, Giordano counsels businesses to expect more legislation coming from states across the US.  Many have already taken notable steps to ensure that consumer data is protected.

Listen in to help understand how your organization can better meet the challenges of GDPR and the ever-increasing number of data protection laws.