Compliance Perspectives

By Adam Turteltaub

Compliance officers are used to answering questions from the workforce, management, regulators and sometimes even prosecutors.  Increasingly, some are answering questions about their compliance program from bank underwriters.

Margaret Hambleton, who is the Vice President for Corporate Compliance and Chief Compliance Officer for Dignity Health (and current president of the Society of Corporate Compliance and Health Care Compliance Association), is no stranger to this relatively new phenomenon.  She’s been through the process more than once and in this podcast shares her experience.

Thankfully, as she reports, it’s not an interrogation and is generally a very collegial process with questions provided in advance.  Listen in as she explains how the discussions typically go, how best to prepare for them, and some of the side benefits of the process.

By Adam Turteltaub

At the 2018 HCCA Compliance Institute, Lloyd Dean, the CEO of Dignity Health wowed the crowd as he discussed his very positive perspective on compliance and the importance of compliance programs to the organization.

During his speech he shared five compliance-related questions that he always asks when evaluating a new business opportunity.  Two things were intriguing about those questions.  First, they had clearly been internalized within executive decision making.  The compliance team didn’t have to ask them;  management already did.  Second, the questions were both simple and insightful, enabling management to quickly get a sense of whether there were potential risks that would require the compliance team’s help.

Margaret Hambleton, the Vice President for Corporate Compliance and Chief Compliance Officer for Dignity Health (and current president of the Society of Corporate Compliance and Health Care Compliance Association), is the author of those questions.  They are specific to healthcare, but, as she explains in this podcast, could be customized for any industry.

* Does the idea/process/opportunity require an exchange of anything of value with a patient, physician or other referral source?

* Does it change the way services are documented, billed, coded or reimbursed?

* Are there any improper motives or conflicts for doing the planned thing, particularly those related to clinical decision making?

* Does it require sharing protected healthcare information or business confidential information outside of our network?

* Does it require evaluation by any other experts in the organization?

Listen in as she explains the genesis of the questions, how she helped management learn them, and how the right set of questions can make a big difference in how management looks at compliance.

By Adam Turteltaub

At the 2018 HCCA Compliance Institute, Lloyd Dean, the CEO of Dignity Health wowed the crowd as he discussed his very positive perspective on compliance and the importance of compliance programs to the organization.

During his speech he shared five compliance-related questions that he always asks when evaluating a new business opportunity.  Two things were intriguing about those questions.  First, they had clearly been internalized within executive decision making.  The compliance team didn’t have to ask them;  management already did.  Second, the questions were both simple and insightful, enabling management to quickly get a sense of whether there were potential risks that would require the compliance team’s help.

Margaret Hambleton, the Vice President for Corporate Compliance and Chief Compliance Officer for Dignity Health (and current president of the Society of Corporate Compliance and Health Care Compliance Association), is the author of those questions.  They are specific to healthcare, but, as she explains in this podcast, could be customized for any industry.

* Does the idea/process/opportunity require an exchange of anything of value with a patient, physician or other referral source?

* Does it change the way services are documented, billed, coded or reimbursed?

* Are there any improper motives or conflicts for doing the planned thing, particularly those related to clinical decision making?

* Does it require sharing protected healthcare information or business confidential information outside of our network?

* Does it require evaluation by any other experts in the organization?

Listen in as she explains the genesis of the questions, how she helped management learn them, and how the right set of questions can make a big difference in how management looks at compliance.

By Adam Turteltaub

You hear a lot about compliance programs in healthcare, but not so much about ethics programs.  Sure, there are many discussions of medical ethics, but not as many conversations, at least at conferences, about the business ethics issues.

Ryan Meade, Director, Regulatory Compliance Studies at the Center for Compliance Studies at Loyola University Chicago School of Law believes that the sheer volume of regulations that the healthcare industry faces tend to keep the focus on compliance.  Medicare alone, after all, has over 200,000 pages of rules.

Yet, healthcare isn’t the only heavily regulated industry with lots of compliance requirements.  Defense contractors have their own mountain of regulations to climb and yet manage to maintain a strong focus on ethics.

As you’ll hear in his podcast, Ryan argues that compliance has three characteristics:

* The law

* The organization’s policies

* Ethics

Organizations need to comply with the law, he explains, but also have to instill a culture of ethics so help answer tough questions:  What do you do when the law is silent and your policies are silent?  How do you want yourself and your workforce to act?

Listen in to learn about the value in making ethics a more integral part of your compliance program, steps you can take to make it happen, how to overcome resistance, and the benefits you can expect.

By Adam Turteltaub

You hear a lot about compliance programs in healthcare, but not so much about ethics programs.  Sure, there are many discussions of medical ethics, but not as many conversations, at least at conferences, about the business ethics issues.

Ryan Meade, Director, Regulatory Compliance Studies at the Center for Compliance Studies at Loyola University Chicago School of Law believes that the sheer volume of regulations that the healthcare industry faces tend to keep the focus on compliance.  Medicare alone, after all, has over 200,000 pages of rules.

Yet, healthcare isn’t the only heavily regulated industry with lots of compliance requirements.  Defense contractors have their own mountain of regulations to climb and yet manage to maintain a strong focus on ethics.

As you’ll hear in his podcast, Ryan argues that compliance has three characteristics:

* The law

* The organization’s policies

* Ethics

Organizations need to comply with the law, he explains, but also have to instill a culture of ethics so help answer tough questions:  What do you do when the law is silent and your policies are silent?  How do you want yourself and your workforce to act?

Listen in to learn about the value in making ethics a more integral part of your compliance program, steps you can take to make it happen, how to overcome resistance, and the benefits you can expect.

By Adam Turteltaub

Auditing and monitoring are essential elements of compliance programs and an ongoing challenge for organizations.  Many struggle with what to assess, how often and who should do the assessing.

To help compliance professionals address this challenge, Cindy Matson, Senior Executive Director, Compliance, Sanford Health and two of her colleagues led a session on the topic at the 2018 Compliance Institute.  Cindy was also good enough to sit down for a podcast.

Here she lays down practical advice for auditing and monitoring including:

* How frequently you should assess specific elements of your program

* The need to taking a risk-based approach to auditing and monitoring

* The value of audit histories

* Working with internal audit collaboratively

* Understanding precisely what it is you are auditing

Listen in, and start rocking your auditing and monitoring efforts.

By Adam Turteltaub

Auditing and monitoring are essential elements of compliance programs and an ongoing challenge for organizations.  Many struggle with what to assess, how often and who should do the assessing.

To help compliance professionals address this challenge, Cindy Matson, Senior Executive Director, Compliance, Sanford Health and two of her colleagues led a session on the topic at the 2018 Compliance Institute.  Cindy was also good enough to sit down for a podcast.

Here she lays down practical advice for auditing and monitoring including:

* How frequently you should assess specific elements of your program

* The need to taking a risk-based approach to auditing and monitoring

* The value of audit histories

* Working with internal audit collaboratively

* Understanding precisely what it is you are auditing

Listen in, and start rocking your auditing and monitoring efforts.

By Adam Turteltaub

At the 2018 Compliance and Ethics Institute (CEI) we will be joined by keynoter Scott Eblin, founder of The Eblin Group and the author of Overworked and Overwhelmed and The Next Level:  What Insiders Know About Executive Success.  He is an inspiring and thoughtful speaker who earned great praise from attendees of the Compliance Institute.

In this podcast, he gives a preview of some of the concepts he’ll be presenting during his talk at the CEI.  He begins by discussing the importance of three types of presence:

* Personal presence is about how you manage yourself

* Team presence is about how you manage your team and move from self to team reliance

* Organizational presence is about engaging your colleagues and picking up an outside-in view of your organization.

Scott then addresses a tool he created known as the LifeGPS.  It asks three questions designed to help business people function more successfully.

Finally, he discusses the importance of mindfulness.

Listen in and then hear Scott live at the 2018 Compliance and Ethics Institute.

By Adam Turteltaub

At the 2018 Compliance and Ethics Institute (CEI) we will be joined by keynoter Scott Eblin, founder of The Eblin Group and the author of Overworked and Overwhelmed and The Next Level:  What Insiders Know About Executive Success.  He is an inspiring and thoughtful speaker who earned great praise from attendees of the Compliance Institute.

In this podcast, he gives a preview of some of the concepts he’ll be presenting during his talk at the CEI.  He begins by discussing the importance of three types of presence:

* Personal presence is about how you manage yourself

* Team presence is about how you manage your team and move from self to team reliance

* Organizational presence is about engaging your colleagues and picking up an outside-in view of your organization.

Scott then addresses a tool he created known as the LifeGPS.  It asks three questions designed to help business people function more successfully.

Finally, he discusses the importance of mindfulness.

Listen in and then hear Scott live at the 2018 Compliance and Ethics Institute.

By Adam Turteltaub

Roz Bliss is the Manager, Global Integrity at Northrop Grumman.  One of the responsibilities of that role is putting together a meeting for the global ethics team.  It’s not an easy task, with such a large and spread out team.

Over the years she’s learned to manage not just the logistics but the substance of the meeting as well.  By chance Northrop Grumman was having a team meeting at the same time and hotel as the 2018 SCCE Basic Compliance and Ethics Academy in Amsterdam.  While we were both there, she sat down to share her experience on the ingredients of a successful team meeting.

Listen in as she shares her tips, including:

* Know your audience, including how on-time it tends to be (it varies by country)

* State your purpose and manage expectations up front

* Be considerate of the time of participants

* Involve the right people in planning, including some who may oppose what you plan on doing

* Plan on asking questions: don’t make the whole program a speech

* When following up, include people who were unable to participate