Compliance Perspectives

By Adam Turteltaub

Most companies don’t start out with a full-time compliance team.  Heck, most probably don’t even start with a part-time team.  But as an organization grows, eventually it is time to take the plunge.

Tony Joy from Empower Audit Training & Consulting has worked with several companies who have made the transition from a parceled out compliance function to a dedicated one.  Not surprisingly, over the years he has found that sooner is better than later when it comes to starting a compliance program.

That doesn’t mean, however, that you need to dive completely in.  He recommends a phased approach beginning with leadership buy-in.  Then it’s time to get some help, whether by forming an internal team, engaging outside consultants or turning to resources of outside groups like the SCCE.

Listen in to this podcast as he provides some more helpful insights into the formation of a compliance program, as well as the missteps that can leave you farther behind than if you hadn’t started at all.

By Adam Turteltaub

On April 16, 2018 Daniel R. Levinson, the Inspector General at the Department of Health and Human Services once again returned to the stage for the HCCA Compliance Institute.  As he has done so many times and so well, he provided the Institute attendees the latest in thinking from the Office of Inspector General.

This year he also sat down to record a podcast covering the highlights of his talk.  Whether you attended the session looking for a refresher or were unable to attend, you’ll find his insights invaluable.

Listen in as he addresses key issues such as:

* The importance of mastering data

* Rethinking compliance and healthcare in terms of inputs, outputs and outcomes

* The need to separate luck and risk: they are sides of the same coin, but you can’t rely on luck

* Thinking of self-disclosure in terms of demonstrating an understanding of risk and a commitment to reduce it

* Thinking about “dynamic compliance” to reflect a fast-changing healthcare environment

* How the OIG’s office is responding to the opioid crises, and the role compliance can play

The podcast is filled with invaluable information and takes less than fourteen minutes to listen to.  Still hungry for more?  Visit the OIG’s new Compliance Resources Portal

By Adam Turteltaub

On April 16, 2018 Daniel R. Levinson, the Inspector General at the Department of Health and Human Services once again returned to the stage for the HCCA Compliance Institute.  As he has done so many times and so well, he provided the Institute attendees the latest in thinking from the Office of Inspector General.

This year he also sat down to record a podcast covering the highlights of his talk.  Whether you attended the session looking for a refresher or were unable to attend, you’ll find his insights invaluable.

Listen in as he addresses key issues such as:

* The importance of mastering data

* Rethinking compliance and healthcare in terms of inputs, outputs and outcomes

* The need to separate luck and risk: they are sides of the same coin, but you can’t rely on luck

* Thinking of self-disclosure in terms of demonstrating an understanding of risk and a commitment to reduce it

* Thinking about “dynamic compliance” to reflect a fast-changing healthcare environment

* How the OIG’s office is responding to the opioid crises, and the role compliance can play

The podcast is filled with invaluable information and takes less than fourteen minutes to listen to.  Still hungry for more?  Visit the OIG’s new Compliance Resources Portal

By Adam Turteltaub

There is a lot written and discussed about ethical business practices.  Not so much, though, if anything, on ethical business regulation.

Ruth Steinholtz of AreteWork wants to change that.  A former general counsel with a passion for ethics, she works with numerous companies on making their values real.   She is also the co-author of Ethical Business Practice and Regulation.

In her book, and in this podcast, Ruth argues for the development of a new approach to regulation based on informed trust.  In a nutshell, companies with a strong commitment to ethical, compliant behavior, and, critically, with the evidence to prove it, should be able to bring their data to regulators.  The goal:  to lay a foundation of trust, which leads to a more constructive relationship both day to day, and when things go bad.

Listen in for her thought-provoking ideas that are already being piloted with one government.

By Adam Turteltaub

There is a lot written and discussed about ethical business practices.  Not so much, though, if anything, on ethical business regulation.

Ruth Steinholtz of AreteWork wants to change that.  A former general counsel with a passion for ethics, she works with numerous companies on making their values real.   She is also the co-author of Ethical Business Practice and Regulation.

In her book, and in this podcast, Ruth argues for the development of a new approach to regulation based on informed trust.  In a nutshell, companies with a strong commitment to ethical, compliant behavior, and, critically, with the evidence to prove it, should be able to bring their data to regulators.  The goal:  to lay a foundation of trust, which leads to a more constructive relationship both day to day, and when things go bad.

Listen in for her thought-provoking ideas that are already being piloted with one government.

By Adam Turteltaub

For years most of the focus on compliance training has been focused on web-based programs.  While there is much discussion about issues like the use of comedy in that training, or whether it should be a full hour or just a few minutes, there is relatively little talk about when is live training better?  And, how do we make live training work at its best?

David Barr of the firm CampbellBarr is a specialist in live compliance training.  In this podcast he argues that live training is best when looking for a behavioral change.  For simply exchanging knowledge, web-based training is idea, but when looking at affecting human dynamics, live training can be a better choice because of the interaction with the instructor and with their peers in the room.

He shares his advice for making live training work at its best including:

* Avoiding training with so large a group that interaction is limited

* Getting participants active and moving

* Training in the language participants truly are comfortable in

* Recognizing that the invitation to the training is the actual start of the learning process

Listen in, if you can get past the irony of turning to web-based training to learn about the virtues of in-person learning.

By Adam Turteltaub

For years most of the focus on compliance training has been focused on web-based programs.  While there is much discussion about issues like the use of comedy in that training, or whether it should be a full hour or just a few minutes, there is relatively little talk about when is live training better?  And, how do we make live training work at its best?

David Barr of the firm CampbellBarr is a specialist in live compliance training.  In this podcast he argues that live training is best when looking for a behavioral change.  For simply exchanging knowledge, web-based training is idea, but when looking at affecting human dynamics, live training can be a better choice because of the interaction with the instructor and with their peers in the room.

He shares his advice for making live training work at its best including:

* Avoiding training with so large a group that interaction is limited

* Getting participants active and moving

* Training in the language participants truly are comfortable in

* Recognizing that the invitation to the training is the actual start of the learning process

Listen in, if you can get past the irony of turning to web-based training to learn about the virtues of in-person learning.

By Adam Turteltaub

NAVEX Global recently released its 2018 Ethics & Compliance Hotline and Incident Management Benchmark Report, which leverages their database of helpline/hotline calls and other incident data.  In 2017 the company logged approximately 900,000 reports, which it used for this analysis.

Compliance veteran Carrie Penman, who serves as the company’s Chief Compliance Officer and Senior Vice President, Advisory Services join us for a podcast in which she covers some of the highlights of the report.  Among the points discussed from the report:

* A rise in the amount of reporting

* Substantiation rates across reports as a whole, as well as the differences in rates between helpline calls and incidents reported through other means

* The wide “normal” range for the number of reports in an organization

* The substantiation rates of anonymous calls – it’s higher than many would think

* The rise in harassment reports

* The latest figures on retaliation

Be sure to listen to the podcast.  A copy of the report can be found here on the NAVEX site.

By Adam Turteltaub

NAVEX Global recently released its 2018 Ethics & Compliance Hotline and Incident Management Benchmark Report, which leverages their database of helpline/hotline calls and other incident data.  In 2017 the company logged approximately 900,000 reports, which it used for this analysis.

Compliance veteran Carrie Penman, who serves as the company’s Chief Compliance Officer and Senior Vice President, Advisory Services join us for a podcast in which she covers some of the highlights of the report.  Among the points discussed from the report:

* A rise in the amount of reporting

* Substantiation rates across reports as a whole, as well as the differences in rates between helpline calls and incidents reported through other means

* The wide “normal” range for the number of reports in an organization

* The substantiation rates of anonymous calls – it’s higher than many would think

* The rise in harassment reports

* The latest figures on retaliation

Be sure to listen to the podcast.  A copy of the report can be found here on the NAVEX site.

By Adam Turteltaub

Your organization has just reached a settlement with the government, and you have a corporate monitor.  Making that relationship work is essential not just for meeting the terms of a Deferred Prosecution Agreement.  It’s also essential for coming out of the monitorship with a much stronger compliance and ethics program.

Eric Feldman of Affiliated Monitors, Inc. and Tom Topolski worked closely together when Tom’s previous employer had engaged Eric as a monitor.  In this podcast they discuss what made their relationship work, and the lessons every compliance professional can take away when in the middle of, or about to face, a monitorship.

They explain:

* Getting a monitor is not always negative; it’s also a good opportunity to adopt best practices

* Red flags that a monitor would see as a symptom of a larger problem than expected

* The importance of trust to the relationship

* The monitor has to go in with a mindset that they are there to be collaborative, and that collaboration and independence are not mutually exclusive

* The goal is to work together to build the best organization possible using compliance best practices