Interview with Compliance Officer
Chen and Soltes (2018) report that a compliance program is a set of protocols created to assure adherence to all laws, contracts, and other agreements regulating organizational operations. A compliance program should not be rigid and dogmatic. It is subject to perpetual amendments to ensure that the best and current corporate values, ethics, and legal aspects are adhered to (Chen & Soltes, 2018). Ideally, a compliance program should promote self-awareness and ensure all stakeholders work together to achieve organizational goals. The organization gains a competitive advantage by maintaining its reputation among key stakeholders such as customers. Compliance programs are essential for all types of businesses: private, governmental, and non-profit (Chen & Soltes, 2018). This paper analyzes an interview with a compliance officer of a three-hundred-bed capacity healthcare facility.
Qualifications of the Compliance Officer
The first question was, kindly describe yourself. The compliance officer is aged 45 years. He reports that he has more than 15 years of experience as a compliance officer. According to him, he has a Bachelor’s and master’s degree in business management. My interaction with him revealed that he has good communication skills and embraces verbal and nonverbal cues.
Furthermore, he emphasized attention to detail and properly understood state and federal legal requirements. The second question stated, what is the impact of your job on your overall career? The compliance officer reported that his job description had enabled him to develop other soft skills such as strategic, critical, and analytical thinking and moral integrity. The third question was, would you describe the trajectory of your occupation as a compliance officer? The compliance officer reported that he started working in the healthcare facility’s legal department before being promoted. The fourth question was, would you briefly highlight the scope of your work? He plays a significant role in assessing employees, formulating organizational policies, and addressing cases of policy breaches. As such, he ensures that all stakeholders adhere to all legal frameworks and internal policies and procedures (Krambia-Kapardis, 2019).
Reporting Relationships
The fifth question stated, tell me about the compliance structure of this healthcare facility. The compliance officer is the healthcare facility’s chief compliance officer. He reports to the healthcare facility’s board of directors and Chief Executive Officer (CEO). The healthcare facility’s compliance committee reports to the chief compliance officer. The compliance committee comprises various stakeholders. They include the administrator, chief financial officer, risk manager, chief legal officer, and representatives from multiple departments. This is harmonious with reporting relations used in other healthcare facilities. For example, Trillium Health, Inc. has a compliance committee whose primary role is to advise the chief compliance officer (TrilliumHealth.org, n.d.). Similarly, MD Anderson Cancer Center compliance committees report and notify the chief compliance and ethics officer (MDAnderson.org, n.d.).
The Five Key Components
Organizations should include evidence-based components in their compliance programs. Notably, five key components represent best practice aspects. They have policies, procedures, leadership, oversight, risk assessment, and training and communication (Ofaclawyer.net, n.d.). The sixth question during the interview was, does your compliance plan have the five fundamental components? The compliance officer revealed that the healthcare facility’s compliance plan has these five essential components.
The seventh question asked the compliance officer to describe how the facility’s compliance program has incorporated leadership as an essential component. According to the compliance officer, leadership is demonstrated by an elaborate chain of command and reporting relationships. The board of directors is responsible for the daily operations of the healthcare facility. As such, they are at the top of the hierarchy of the compliance program. The chief executive officer reports directly to the board of directors. Such reports entail matters related to the organizational compliance level and the general aspects.
Further, the chief compliance officer reports directly to the CEO. In addition, the chief compliance officer works autonomously to ensure that pertinent policies and procedures are formulated and implemented effectively. Next, the compliance committee reports directly to the chief compliance officer. The committee consists of members such as the administrator, chief financial officer, risk manager, chief legal officer, and representatives from various departments. The representatives from multiple departments provide timely updates on the actions of other employees.
Ofaclawyer.net (n.d.) reports that the compliance program’s risk assessment is evidenced by sections that address aspects such as employee intimidation, fraud alerts, kickbacks, and proper documentation. Notably, the eighth question asked the compliance officer to describe how the facility’s compliance program has incorporated risk assessment as an essential component. According to the compliance officer, employees’ freedom of speech will be upheld. Employees can raise their grievances without the fear of being sidelined or punished. Any deviation from organizational policies should be reported promptly to the compliance officer.
Additionally, whistleblowers are protected from profiling and penalization.
Furthermore, fraud threats will be detected and addressed accordingly. The compliance programs prohibit all forms of bribery, such as kickbacks. This applies to all stakeholders, including suppliers and employees. The healthcare facility emphasizes proper and adequate documentation to avert legal implications. The healthcare facility also retains all documents for at least seven years.
The ninth question was, would you describe how your facility’s compliance program has incorporated policies and procedures as an essential component? The healthcare facility’s compliance program has elaborate policies and procedures. Firstly, it has a code of conduct. The code of conduct demonstrates organizational values and ethics that should be upheld by all stakeholders (Schroeder et al., 2019). According to the compliance officer, the healthcare facility’s code of conduct includes aspects such as equity, honesty, interdisciplinary collaboration, and respect. Secondly, the compliance program has elaborate standards and policies. These policies are clear and concise and address billing, fraud, kickbacks, HIPAA, conflict of interest, and employee protection. The guidelines apply to all stakeholders, including third parties such as patients.
The tenth question required the compliance officer to describe how the facility’s compliance program has incorporated training and communication as an essential component. Training is relevant because it equips employees with the knowledge and skills required daily. This enables them to remain competitive and perform optimally to increase the organization’s productivity (Chen & Soltes, 2018). On the other hand, open communication is critical because it enables the management to convey the goals and objectives of an organization. Furthermore, open communication helps to avert detection and address conflicts (Wahyuni, 2018). Timely detection and conflict management are essential de-escalation strategies that ensure all team members are harmonious. According to the compliance officer, the healthcare facility conducts staff training. The training focuses on policies and guidelines and standard operating procedures. The healthcare facility has advocated for open communication using verbal and nonverbal cues.
The last question asked the compliance officer to describe how the facility’s compliance program has incorporated oversight as an essential component. The compliance officer reported that oversight enables the organization to evaluate the extent to which stakeholders adhere to the compliance program. This should happen periodically to allow the chief compliance officer to detect and address any deviation from the expected performance. The compliance officer should investigate the etiology of any deviation from the norm. After that, relevant measures are put in place to avert future breaches. According to the compliance officer, the healthcare facility has an elaborate internal and external auditing framework. The auditing is conducted annually. It evaluates aspects such as compliance with the anti-kickback guides and proper billing. Additionally, external auditing investigates fraud-related allegations and different forms of abuse.
The Strengths and Weakness of the Program
The compliance program has beneficial elements that indicate its strengths. Firstly, the compliance program addresses all of the five critical elements of a compliance plan. As mentioned, the compliance programs address leadership by describing an elaborate chain of command and reporting relationships (Chen & Soltes, 2018). In this context, the board of directors oversees the healthcare facility’s routine operations. The chief executive officer is the second in command, whereas the chief compliance officer is the third in command. A compliance committee comprising various representatives is also part of the top management hierarchy. Having elaborate leadership is essential because it establishes a single point of contact for advice and information regarding compliance requirements (Chen & Soltes, 2018).
The compliance program also addresses risk assessment. This is advantageous because it optimizes the healthcare facility’s operational efficiency (Chen & Soltes, 2018). The program addresses critical concerns such as fraud, kickbacks, and retaliation against employees. Provisions on fraud and kickbacks ensure that the healthcare organization is a corrupt-free zone. This reduces the risk of legal implications related to corruption cases. Employee protection ensures that the healthcare facility does not intimidate or retaliate against its employees. This is important because it creates a workplace of trust.
The compliance program advocates for collaboration and improved productivity through training and communication. As aforementioned, open communication is critical because it enables the management to convey the goals and objectives of an organization. Furthermore, open communication helps to avert, detect, and address conflicts. As such, open communication promotes teamwork and increases the productivity of employees (Wahyuni, 2018). On the other hand, training equips healthcare providers with pertinent knowledge and skills required in their daily activities. By so doing, their productivity will increase, and better,r patient outcomes will be recorded.
The compliance program establishes a framework of continuous monitoring and evaluation. This is accomplished by addressing the principle of auditing and monitoring. Ongoing evaluation will optimize the healthcare facility’s operational efficiency (Chen & Soltes, 2018). It will allow the compliance officer to detect shortcomings and address them promptly. Adequate monitoring and evaluation will increase adherence to the compliance program, lower the likelihood of penalization, and besmirch the healthcare facility’s reputation.
The compliance program promotes accountability and prevents financial and reputational liabilities by establishing elaborate policies and procedures. As already mentioned, the code of conduct demonstrates organizational values and ethics that should be upheld by all stakeholders (Schroeder et al., 2019). Additionally, the program’s standards and policies are concise and address billing, fraud, kickbacks, HIPAA, conflict of interest, and employee protection. As a result, the compliance program creates a culture of accountability and compliance among healthcare providers. For example, HIPAA directs healthcare providers to uphold the privacy and confidentiality of patients when transmitting their data electronically (Moore & Frye, 2019).
Further evaluation of the healthcare facility’s compliance program revealed some weaknesses. Firstly, the compliance plan focuses on employees at the bottom of the hierarchy as the primary source of risk to the healthcare facility. This may be misleading because stakeholders at the top of the hierarchy make vital decisions and are the highest risk to the healthcare facility (ComplianceandEthics.org, n.d.). Stakeholders occupying management positions play a crucial role in evaluating other employees and setting precedence in the compliance of organizational policies and procedures (ComplianceandEthics.org, n.d.). As such, the compliance program should focus on these stakeholders to ensure that their operations are optimized to increase the overall productivity of the healthcare facility.
Secondly, the compliance program fails to acknowledge the importance of rewards and positive reinforcement. Rewards and incentives reinforce desirable behaviors to increase employee productivity (ComplianceandEthics.org, n.d.) The use of reward systems will increase adherence to the compliance program. By so doing, the operational efficiency of the healthcare facility will increase. This will manifest in improved quality of healthcare services, patient satisfaction, and patient safety. Thirdly, the compliance officer reported that the program had not been updated for three years. Consequently, this increases the possibility of using outdated and misleading guidelines.
Compliance risks are likely to be caused by the observation that the compliance plan focuses on employees at the bottom of the hierarchy as the primary source of risk to the healthcare facility. Accordingly, stakeholders occupying high management positions are likely to violate the five fundamental components of the compliance plan. Violations may occur when these stakeholders fail to take corrective action against subordinates. Furthermore, compliance risks can arise when these stakeholders breach the law directly. The lack of rewards and positive reinforcements is likely to increase compliance risks. The absence of reward systems implies that healthcare providers (stakeholders) are not motivated periodically. They are likely to breach critical provisions of the compliance plan, such as training and policies and procedures.
Recommendations for Improvement
Firstly, the healthcare facility should review its compliance program regularly. It should be reviewed and updated annually to ensure the best evidence-based practices are adopted (Chen & Soltes, 2018). As a result, the risk of reputational or financial harm will be reduced significantly. The regular update also forms the basis for continuous monitoring and evaluation of stakeholders. Secondly, the compliance program should be modified to incorporate rewards and positive reinforcement. As stated earlier, rewards and incentives reinforce desirable behaviors to increase employee productivity (ComplianceandEthics.org, n.d.). Using reward systems will motivate stakeholders and improve adherence to the compliance program.
Thirdly, the compliance program policies and procedures should be modified to focus on the stakeholders at the top of the hierarchy as critical sources of organizational risks. This will help to avert potential problems when these stakeholders fail to take corrective action against subordinates and when they breach the law directly. Stakeholders occupying management positions play a crucial role in evaluating other employees and setting precedence in the compliance of organizational policies and procedures.
Conclusion
A compliance program refers to protocols created to assure adherence to all laws, contracts, and other agreements that regulate organizational operations. A compliance program should not be rigid and dogmatic. It should be evaluated and reviewed annually to ensure the best evidence-based practices are adopted. My interview with the compliance officer revealed that the healthcare facility’s compliance plan has five essential components. They include policies, procedures, leadership, oversight, risk assessment, training, and communication. The compliance officer reports to the board of directors and the healthcare facility’s Chief Executive Officer (CEO). On the other hand, the healthcare facility’s compliance committee reports to the chief compliance officer.
References
Chen, H., & Soltes, E. (2018). Why compliance programs fail and how to fix them. Harvard Business Review, March–April 2018(April).
ComplianceandEthics.org. (n.d.). Five Common Weaknesses in OFAC Sanctions Compliance Programs. https://www.complianceandethics.org/five-common-weaknesses-in-ofac-sanctions-compliance-programs/
Krambia-Kapardis, M. (2019). The Skillset of an Effective Compliance Officer. In: Krambia-Kapardis, M. (eds) Financial Compliance. Palgrave Macmillan, Cham. https://doi.org/10.1007/978-3-030-14511-8_8
MDAnderson.org. (n.d.). MD Anderson Institutional Compliance. https://www.mdanderson.org/content/dam/mdanderson/documents/about-md- anderson/about-us/compliance-program/Hospital%20Compliance%20Plan.pdf
Moore, W., & Frye, S. (2019). Review of HIPAA, Part 1: History, protected health information, and privacy and security rules. Journal of Nuclear Medicine Technology, 47(4), 269–272. https://doi.org/10.2967/JNMT.119.227819
Ofaclawyer.net. (n.d.). Five Essential Elements of a Sanctions Compliance Program. https://ofaclawyer.net/compliance/five-essential-elements/
Schroeder, D., Chatfield, K., Singh, M., Chennells, R., & Herissone-kelly, P. (2019). Partnerships: A Global Code of Conduct to Counter Ethics Dumping Foreword by Klaus Leisinger.
TrilliumHealth.org. (n.d.). Compliance Plan – Trillium Health. https://www.trilliumhealth.org/storage/files/0436830/Compliance%20Plan%202021.docx
Wahyuni, A. (2018). The Power of Verbal and Nonverbal Communication in Learning. 125(Icigr 2017), 80–83. https://doi.org/10.2991/icigr-17.2018.19
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Question 
Interview with Compliance Officer
Interview a corporate compliance officer (via any virtual platform of your choosing) of any healthcare organization and analyze the strengths and weaknesses of the organization’s compliance program. You can do this via phone, Skype, in person, or even e-mail. How you obtain the information is your decision. Some organizations publish their compliance plans on the Web. It is OK to reference web-based resources, but you must make a connection with the corporate compliance officer to ask questions about their background, reporting relationships, and, if they are willing to describe what they believe are the most significant compliance challenges and successes they have faced—more details included in Blackboard.
Prepare a 6 to 8-page paper describing the organization’s compliance function. Include descriptions of the qualifications of the compliance officer, reporting relationships, and how (or whether) the compliance plan contains the five key components. Using primary resources and APA format:
1. Analyze the strengths and weaknesses of the program. Identify compliance risks.
2. Make recommendations for improvement.
*Be sure to include/identify the 10-12 questions in the paper*