Leveraging the Similarities of Your Role to the CFO to Change the Perception of Compliance

In the highly regulated world of healthcare, the Compliance Officer (CO) and the Chief Financial Officer (CFO) play pivotal roles in ensuring the organization operates effectively and within the bounds of the law. 

While I do not advocate for a CO reporting to a CFO, I think there is value in getting your leadership team to see your role like that of a CFO.

Why?

The responsibilities for each area often mirror one another, yet for whatever reason, CFOs tend to be looked at more like a business partner, whereas CO’s are viewed like an obstacle. For example, I’ve never seen a CFO struggle to get a seat at the table, yet I can recall countless times I, and other CO’s have faced this challenge.

So if you can get your leadership team to see your role like that of a CFO, it will help you change the perception of compliance—and effectively navigate the politics of healthcare. This article will cover some of the key parallels between these two roles and how you can leverage them to demonstrate to your leadership team that you are a business partner.

(Note: For purposes of discussion, I’m generically using the term “Compliance Officer” to also includes roles such as a Chief Compliance Officer or Compliance Director depending on organizational nomenclature and how the program is set up.)

Strategic and Advisory Leadership

Both the CO and CFO are strategic leaders who guide their organizations through intricate landscapes. Each role ensures their respective areas align with the organization’s broader mission and objectives. 

More specifically, the CFO ensures financial stability, while the CO ensures adherence to laws and regulations. For example, the CFO must manage budgets, revenue cycles, and investments in a way that sustains clinical operations. Similarly, the CO ensures that billing, patient privacy, and clinical practices comply with regulations such as HIPAA, the Stark Law, and the Anti-Kickback Statute. As a result, both areas support the organization’s mission by protecting it from legal, financial, and reputational risk. Both roles also advise their leaders on how to make the best business decision for the organization.

The Takeaway:

• Pay attention to how your CFO interacts with your operational leaders—and more importantly, how your leaders respond to the CFO. Is there a difference? If so, why? If they’re responding to the CFO more favorably, then connect with your CFO to see if there are some insights you can apply to your own communications.

Mitigating Risk

Mitigating risk is a core function of both roles. The CFO manages financial risks—such as market fluctuations, reimbursement challenges, and operational inefficiencies. Meanwhile, CO oversees compliance risks, including audits, regulatory changes, and internal misconduct.

Inherent to this work, both roles often collaborate to identify and mitigate overlapping risks, such as billing fraud, which can have both compliance and financial repercussions. As a result, their shared goal is to protect the organization from harm, whether it’s a financial loss or a regulatory penalty.

In many cases, the CFO and CO also work together, especially on issues such as audits, internal controls, and fraud prevention. Their joint efforts ensure the organization’s financial health and compliance integrity are upheld.

The Takeaway:

• The old saying—“there is safety in numbers.” If you haven’t already done so, build a strong relationship with your CFO. This can help you effectively collaborate and communicate on projects with your leadership teams to gain their buy-in.

Delivering the Good News—and the Bad

Given the CO and CFO have to manage issues involving organizational risk, both roles have to be adept at delivering good and bad news.

For the CFO, financial statements, budget discussions, and performance metrics all represent areas ripe for potentially good or bad news. For the CO, investigations, audit findings, and regulatory changes similarly have the potential to be positive or negative information depending on the circumstances.

The Takeaway:

• Pay attention to how your CFO interacts with your operational leaders when delivering bad news. Are there any insights you can apply to your own communications that are real and fun, but not real fun? If this is an area you struggle with, then I invite you to check out a separate article I wrote about delivering bad news.

Balancing Proactivity and Reactivity

Both the CO and the CFO must anticipate potential challenges and respond effectively during times of true emergency. For example, the CFO might have to prepare for potential funding cuts, while the CO monitors emerging regulatory changes to preempt non-compliance. The CFO may have to navigate an unexpected loss of significant revenue, while the CO has to guide the organization through a large scale data breach.

Proactivity involves building systems that prevent little issues from becoming big ones. Internal and external audits, compliance training, monitoring, and corrective action are all examples applicable to either role in the organization. Reactivity, on the other hand, demands calm but swift action such as targeted corrective action or overcoming a financial shortfall.

The Takeaway:

• In my experience, CFO’s tend to take a big picture approach and maintaining a calming presence when navigating proactivity and reactivity. These are models that can aid in the approach to your work. If these are areas that you struggle with, you can check out additional articles I wrote on taking a big picture approach and maintaining a calming presence.

Pulling it All Together

The CO and CFO share a common goal: to safeguard a healthcare organization’s ability to deliver high-quality care to the communities it serves. While they operate in distinct domains, their roles often converge in areas such as strategic advisement, risk mitigation, and cross-departmental collaboration. 

Though the responsibilities for each role often mirror one another, CFOs tend to be looked at more like a business partner than a CO. Instead of viewing this a negative, see it as a positive. That is, an opportunity to gain insights that you can use to alter your approach to more effectively communicate with your leadership team. I have found that when my leadership team identified my role to be similar to that of the CFO, I was able to change their perception of compliance—and effectively navigate the politics of healthcare.

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A step-by-step guide to help you change the perception of compliance from obstacle to business partner.

And the best part?

You can earn CEU credits while you’re at it

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If so, check out my new book.

It contains additional communication and relationship-building strategies to help improve buy-in to your compliance program.

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Identifying and Closing Communication Loops

Earlier this year, I wrote about a communication challenge that compliance officers face on a daily basis—determining who to tell and when to tell related to an issue that has surfaced. In this article, I’ll address another challenge that often comes up—that is, when someone hasn’t closed a communication loop.

Ensuring a communication loop is closed—where information flows back to confirm receipt, understanding, and follow-up—is critical for healthcare organizations. That is true whether the matter pertains to patient safety, operational efficiency, or corporate compliance.

Being able to identify when there is a communication loop that needs to be closed, and how to close it, is key to the effectiveness of any compliance officer. It can mean the difference between a little mess becoming a big one. It is also a skillset that can help you in navigating the compliance program through the politics of healthcare.

Failing to Close the Loop

When someone doesn’t follow through and close a communication loop, it’s a variation on figuring out whom to tell and when to tell, but this version occurs on the back end of the issue after it’s been resolved.

What causes these communication gaps? Some examples include the following:

• Isolated Decision-Making: Decision-making confined to specific departments without seeking input or insights from other relevant teams.
  

• Strict Hierarchical Communication: Hierarchical communication structures that inhibit open dialogue between employees at different levels and departments.

• Limited Information Sharing: Employees or departments not sharing crucial details related to an operational process or organizational objective with other teams.

• Communication Barriers: Limited or no communication channels between departments (e.g., no cross-functional meetings or cross-departmental projects).

• Competing Objectives: Departments pursuing individual objectives without considering broader organizational goals.

• Departmental Rivalries: Unhealthy competition or rivalries between departments.

• Inadequate Training Across Departments: Employees lacking training in areas outside their immediate department, limiting their understanding of the organization as a whole.

• Limited Cross-Functional Understanding: Employees having a narrow understanding of their own roles and responsibilities without a broader awareness of how their work contributes to the organization’s overall success.

While the above list is not intended to be all-inclusive, it does represent common scenarios where organizational departments operate in isolation, thereby creating the potential for someone to fail to close a communication loop. 

Strategies for Closing the Loop

So what can you do to minimize communication gaps related to a compliance matter? Below are some strategies that can help:

• Clarify Roles and Responsibilities: When appropriate for your role on a project, clearly define roles and responsibilities within each department to avoid confusion. If it is not within your role, then speak up to identify a need for clarity for the good of the group. 

• Establish Clear Communication Protocols: Set standard protocols for how information is shared, documented, and confirmed. Also, using formats like SBAR (Situation, Background, Assessment, Recommendation) or IRAC (Issue, Rule, Analysis, Conclusion) can also minimize ambiguity and ensure everyone is on the same page.

• Self-Awareness: Be mindful about your own actions to ensure that you’re not engaging in siloed communication. When appropriate and respectful, communicate with others in the organization who have a legitimate need-to-know.

• If You See Something, Say Something: If you are communicating with others, and recognize that someone with a legitimate need-to-know is not included in the discussion, say something. You can either speak up to whomever controls the communication, or close the loop yourself if it’s appropriate to do so.

• Leverage the Speak-Back Method: When giving instructions or updates to another team member or operational leader, have the recipient repeat or paraphrase the information. This speak-back method helps confirm mutual understanding and highlights any areas requiring clarification.

• Encourage Cross-Functional Teams: When addressing a compliance-related matter, create cross-functional teams that include members from different departments so that all affected employees understand the broader picture of the matter.

• Promote Open Communication: When appropriate, be mindful of promoting a culture of openness where employees feel comfortable sharing ideas and information (e.g., establish regular project meetings, feedback sessions, surveys, one-on-one discussions, or open forums).

• Provide Cross-Training Opportunities: Whenever possible, cross-train employees to develop a broader understanding of the different roles involved in a project. This can be particularly helpful when it comes to ensuring the organization is meeting compliance requirements.

• Engage in Communication Self-Assessment: Encourage teams to evaluate their communication. For example, during investigations, audits, or educational roll-outs, assess whether any communication breakdowns contributed to a communication gap. Apply lessons learned to refine processes and training.

In addition the above-noted strategies, developing a communication plan, being aware of your political landscape, and thinking like a healthcare leader can also help you overcome this challenge.

Pulling it All Together

Closing a communication loop is not just a best practice—it’s a necessity for ensuring patient safety, operational efficiency, and corporate compliance. By implementing these strategies, you can strengthen the communication frameworks within your organization. It can also help you improve the effectiveness of your compliance program and navigate it successfully through the politics of healthcare. 

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The course is now live!

A step-by-step guide to help you change the perception of compliance from obstacle to business partner.

If you want to your healthcare leaders to …

✅ Proactively reach out to you with questions or concerns
✅ Champion a compliance program initiative
✅ Spot issues and direct their staff to contact you

Then check out the link below for all details on this new course.

And the best part?

You can earn CEU credits while you’re at it.

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How to Get Others to Accept a Difficult Decision

Making difficult decisions is a challenging part of the daily life of a compliance officer—and getting others to accept those decisions—can be even more daunting. Whether you're confronting a high dollar repayment to Medicare or implementing a major organizational change, having a plan for communicating difficult decisions is key to your ability to navigate the politics of healthcare.

Below are five strategies to consider including as part of your communication plan. 

#1–Communicate Transparently

When you're faced with a difficult decision, transparency is key. Clearly explain the reasoning behind the decision (i.e., “the why”), the relevant factors considered, and the potential impacts. 

Transparent communication also means not minimizing the downside. Be honest about the pros and cons, and allow space for questions and concerns. This openness can mitigate feelings of frustration and confusion, helping people to see the bigger picture.

#2–Involve Stakeholders—Early and Often

One of the most effective ways to gain acceptance for a difficult decision is to involve key stakeholders in the decision-making process from the beginning. When people feel they have a voice, they are more likely to support the outcome, even if it’s not their preferred choice. 

Engagement can take on many forms such as conducting surveys, holding meetings, and gathering individual feedback. Regardless of approach, the focus should be on the perspectives of those affected by the decision.

In my experience, inclusion fosters a sense of ownership and collaboration, which greatly improves your chances for buy-in to the difficult decision. 

#3–Highlight the Benefits

While a difficult decision often has clear downsides, it’s important to emphasize the benefits (e.g., reducing organizational liability, cost savings, or improved efficiency). Seek out the silver lining and make sure to articulate the positive outcomes that will result from the decision. For example, you could show how the decision will ultimately benefit patient care, the organization, or the community. 

When people can see the potential advantages, they are more willing to accept short-term discomfort.

#4–Empathize and Acknowledge Emotions

From disappointment to anger, difficult decisions often evoke strong emotions. Acknowledging these feelings—and any sacrifices—shows that you understand the human impact of the decision. Take the time to listen to concerns and validate the emotions of those affected.

In my experience, empathy goes a long way in easing tensions and fostering a supportive environment. When people feel heard and understood, they are more likely to move forward, even if they don’t fully agree with the decision.

#5–Be Prepared to Adapt and Offer Support

Even after a difficult decision is made, the process isn’t necessarily over. Be prepared to adapt if the implementation faces significant operational resistance or unforeseen challenges. Offering support, whether through resources or training, can help ease the transition and reinforce the message that you’re committed to everyone’s success despite the difficult circumstances.

Pulling it All Together

Every compliance officer has to make tough decisions, and those decisions often have consequences that can affect reputations and careers. Gaining acceptance for a difficult decision is rarely easy, but the approaches outlined above will help you work through the process more effectively. Taking this approach will also help you navigate the politics of healthcare more successfully. As you work through a challenging situation, remember that the goal isn’t just to enforce the decision but to bring the organization together to move forward constructively.

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If you liked this article, check out my book. It contains additional interpersonal communication strategies—a great gift for onboarding new team members.

(Note: Bulk order discounts are also available—contact me at janstine@bluebirdhealthlaw.com for more information.)

How to Sell Compliance Without "Selling" Compliance

From conducting investigations to advising leadership to educating staff, as compliance officers, we are continually placed in a position to influence the actions of others. Unfortunately, a reality of our profession is that we are challenged when it comes to the perception of our role in the organization. Before we even have a chance to utter a single word, healthcare leaders often see us as an obstacle—some sort of grown-up version of a hall monitor.

That doesn’t mean the perception can’t be overcome. We just need to work at it—which means focusing on how we are communicating a compliance message of “do this” or “don’t do that”.

If we want to increase engagement to our compliance programs, then we need to interact with our leaders in a way that is selling compliance—without, ya know—“selling” compliance.

So how do you do that?

Below are five strategies that will help.

1-Establish Rapport with Your Leaders

While there are endless ways in which you can establish rapport with a leader, two specific tactics that have helped me include (1) knowing the organization’s market, and (2) taking an active interest in my healthcare leaders.

Knowing the Organization’s Market

Aside from carrying out your compliance officer duties, be intentional about knowing the market in which your organization participates. That means knowing what services your organization provides, who are your business partners, and who your competitors. It also means knowing where your organization sits in the market (i.e., who is better at providing ___ services to patients). To improve your knowledge, study up on your market through general internet searches, talking with your leaders, and paying attention to what they are saying.

Take an Active Interest in Your Leaders

Any time you are interacting with a healthcare leader you have an opportunity to find out as much as you can about them professionally. For example, you could ask questions such as the following:

• “How did you get into this line of work”?

• “What does your day, week, or month look like?”

• “What’s been your biggest accomplishment so far?”

• “What’s been your biggest challenge so far?”

You can also seize these moments to find out as much as you can about them personally. Now, in order to keep the conversation from becoming too personal and super awkward, just ask—

“So, what do you like to do when you’re not working?”

When you take time to understand your organization’s market and take an active interest in your leaders, it positions you to initiate or engage in dialogue about topics unrelated to compliance. Over time, these approaches establish rapport with your leaders which helps you in selling compliance to them.

2-Do Your Homework

Another strategy for selling compliance, (which also helps in establishing rapport), is to do your homework. Since that’s admittedly a super vague statement, let me define it. When I say “do your homework”, I mean learn as much as you can about the role of the leader(s) you’re working with, and the operations-in-question to the issue you are addressing. Below are two tactics that I typically factor into my homework on any issue I’m working on.

Know your Audience

When it comes to knowing your audience, always approach the compliance message with consideration of the audience’s point-of-view (POV). How would [insert your audience] view this particular topic? What questions would they have? If you are not sure of the answers to these questions, then what I typically do is ask the staff —or the leaders over the staff—for feedback and insight.

Also, using relatable examples when communicating a compliance message demonstrates knowing your audience. For example, if I were educating a group of physicians about HIPAA and safeguarding PHI, I might use an example of discussing a patient’s treatment plan in front of friends or family members.

Understand Their Operations

Ensuring that you understand the operations related to the specific issue you are addressing also demonstrates that you did your homework. Here, you want to be thinking about the matter from the perspective of the individuals that are having to live with the regulatory requirements—not the person enforcing them. In order to do that, there are a couple different approaches you can take.

First, you can learn about the department and their processes, by interviewing the leader(s), and staff. Ask very detailed questions about how they perform the work. As you are asking questions, be mindful to make sure it’s coming across as you being curious and not judgmental. An approach I’ve found helpful is to have them explain what they do as if they were explaining it to someone off the street with no healthcare operational experience.

Another approach is to have them lead you on a department walkthrough, or shadow their staff. In my experience, if you really want to understand the work, (and show interest in your leaders), see and experience the work first-hand.  

Taking the time to do your homework sends a message to your leader(s) you are genuinely interested in the work they do and empathetic to the challenges they face. This will leave them felling like you are understanding their point-of-view (POV) and trying to find a solution that will work for them.

3-Anticipate Their Questions

Another approach to selling compliance is to anticipate your leaders’ questions and be prepared with the answers. Below are a couple tactics that have helped me. 

Think Like a Healthcare Leader—Not a Compliance Officer

Recalling back to my POV comments above, you have to momentarily climb into the mind of your leader by looking at the matter from their perspective—not yours. If you were the leader over this department, what questions would you have about the regulatory requirements? Are there specific terms within the regulation that I would want to understand? What do certain words and phrases mean as applied to my operations? What challenges do I face in trying to meet these requirements? What organizational pressures am I currently facing (e.g., budgetary constraints, staffing, resources, meeting performance goals). These are some of the questions you need to be thinking about in order to think like your leaders.

Know How Decisions are Made in the Organization

Another tactic is knowing how decisions are made in the organization. For example, let’s say there was an audit that identified a billing error which resulted in a six-figure repayment to Medicare. If you are going into a discussion with your CEO to explain what happened and the path forward for resolution, be mindful that a CEO will want to make sure the CFO is aware. That means before you meet with CEO, either invite the CFO to participate in the discussion or, alternatively, let the CEO know you have already vetted the matter with the CFO.

Similar to the other strategies discussed, taking this approach is another way to demonstrate that you are taking into account your leaders’ POV, which helps you in selling compliance to them.

4-Focus On How Your Work Benefits Them—Not You

Another approach for selling compliance is to keep your message focused on how your work supports their department or the organization as a whole and not the compliance program.

For example, let’s assume you are conducting an investigation into a breach allegation reported from a patient. Here, you want to communicate the need to ensure the organization appropriately handles the investigation and response so that trust is restored with the patient. Also, you want to focus on highlighting your concerns that the organization does not suffer financial or reputational harm should the patient choose to report the matter to the Office for Civil Rights.

Anytime you can keep the focus of your message on how it benefits your audience, it will significantly improve your chances of ensuring the message is relatable. Over time, this will improve your ability to sell compliance to your leaders.

5-When You Bring a Problem, Bring a Solution

Finally, if you want to improve your engagement to a culture of compliance then be intentional to communicate the identified issue—and the proposed solution—as a packaged communication.

For example, let’s assume you have been made aware that the organization inadvertently billed Medicare for a particular procedure in error (e.g., the wrong procedure code was billed).  When you alert the appropriate leader(s) of the news, you want to explain what occurred, how it occurred, and why it occurred. That’s bringing the problem which is step one to the communication.

If you want to sell compliance, then you need to take your message a step further by explaining the solution (e.g., what steps you are taking to resolve the matter).

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. Over time, this approach will help you in selling compliance to your leaders.

Pulling it All Together 

With all the different strategies you may have noticed a common theme—focusing on the perspective of your audience instead of you.

While it may seem counterintuitive, (i.e., to get more engagement you have to focus on things other than the compliance program), following these strategies will help you sell compliance and improve your engagement. Over time, these strategies will also help you navigate the compliance program through the politics of healthcare.

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If you liked this article, check out my book. It contains additional interpersonal communication strategies—a great gift for onboarding new team members!

(Note: Bulk order discounts are also available—contact me at janstine@bluebirdhealthlaw.com for more information.)

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Compliance Communications: Determining Who to Tell and When To Tell

I’ve been fortunate enough to have had the opportunity to be a compliance officer for organizations of all shapes and sizes. Some of them had numerous lines of business and over 200,000 employees, while some had a single line of business and only 20 employees.

Though the size of the organizations differed, I found that many the political battles I had to navigate were still the same and based on two underlying themes—miscommunication and misunderstanding. For example, if the people who were supposed to be “in the know” were not included in a discussion, then mis-understandings, hurt feelings, and errors resulted because of the miscommunication.

While there is an endless list of scenarios that can play out for a compliance officer fitting these themes, in this article I want to focus on one—determining who to tell about a compliance matter—and when to tell them. Having this skillset will improve your ability to build stronger relationships with others, gain buy-in to the compliance program, and effectively navigate the politics of healthcare.

Determining Who to Tell and When to Tell

Almost on a daily basis, compliance officers are confronted with two questions in their minds as they approach their work (“Who do I need to tell?” and “When do I need to tell them?”).

For some issues, those questions will be pretty straightforward to answer. For others, it may be a bit more complicated. For example, if an issue involves processes covering more than one department, it may require figuring out which healthcare leaders to include. Additionally, depending on the level of compliance risk involved, you may also need to first communicate to your supervisor and any leaders over the impacted departments. From there, involve others on a need-to-know basis.

Another complication that often comes up with these scenarios is the fact that you may not be in a position of having all the facts at the time you first become aware of the issue. The question then becomes this:

Do you say something now or wait until you have more information?

If you’re not sure how to proceed, your first thought should be to have a conversation with your most trusted resource— your supervisor. I have found that going through the motion of speaking out loud with a supervisor about your thought processes can help determine the most appropriate communication plan. Having this conversation will also help you understand what is expected of you with future communications.

Develop a “No Surprises Act” Communication Plan

Another angle to this communication challenge is not surprising your operational leaders, or your supervisor. For that reason, and with a nod to a recent US Federal healthcare law surrounding price transparency)—it’s best to set up what I like to think of as a “No Surprises Act” communication plan.

I’ve mentioned in other articles that healthcare leaders do not like to be surprised. That is true whether one of their direct reports is notifying them of a budgeting or clinical care mistake, or if you as the compliance officer, are notifying them of something like an overpayment.

When it comes to communicating about compliance issues, you want to avoid dropping a surprise on your leaders as much as possible. For example, if you sense there may be a delay in finding out an answer to resolve an issue, it’s best to proactively communicate with others identified as “need to know.”

During this initial communication, you’ll cover the fact that the issue surfaced and what steps you are taking to resolve it. From there, continue to communicate with this group until the issue is resolved. The same policy should be applied when communicating with your supervisor. Taking this approach will help you maintain a strong business relationship with both audiences.

While such a communication plan sounds like a no-brainer, the reality is that certain parts of your job will force you to strategically think through when to communicate with others in the organization. For example, if you are working on an investigation that has political implications (e.g., investigating one of your senior leaders), you may need to find a sweet spot between not alarming others unnecessarily and avoiding a surprise. To help navigate this challenge, I offer a quick tip:

Put yourself in the shoes of your audience.

Ask yourself, “If I were in this person’s role, when would I want to know this information?” Going through that process can help in you determining who to tell about what you are working on, and when to tell them.

Pulling it All Together

When it comes to overcoming this political battle, there are a couple of universal thoughts to keep in mind. First, whenever you are working on a compliance matter, develop a communication plan. Identify who you want to communicate with and when you plan to communicate with them. Second, always be aware of the political landscape around you. Often the landscape will help guide your communication plan. Finally, remember to think like a healthcare leader when communicating with them. This will help you in determining, from your audience’s perspective, when they would like to be looped into certain communications.

Having the ability to know who to communicate with, and when to communicate with them, will help you in maintaining the trust of your supervisor and other healthcare leaders. Over time, these strategies will improve your ability to build stronger relationships with others—and more effectively navigate the compliance program through the politics of healthcare.

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If you liked this article, check out my book. It contains additional interpersonal communication strategies—a great gift for onboarding new team members to your organization.

Overcoming Siloed Communication

In today’s fast-paced business environment, effective communication is critical to an organization’s success. As it relates to the complex regulatory landscape of healthcare, effective communication also plays a pivotal role in ensuring that the organization remains compliant. Compliance officers, tasked with maintaining adherence to these regulations, often face significant challenges when communication within the organization is siloed. 

A few months ago I wrote an article entitled, Overcoming Communication Blindspots, where I briefly touched upon siloed communications as one example of a blindspot. This article will extend that discussion by offering some strategies to help overcome siloed communications. Having this skillset improves your ability to gain buy-in to your compliance program—and help you effectively navigate the compliance program through the politics of healthcare.

What is siloed communication?

For purposes of this article, I define “siloed communication” as a situation where an employee, or a department, is not communicating with others in the organization who have a legitimate need-to-know. Sometimes these situations are the intentional, while other times they are not. To help illustrate what these situations look like, consider the following examples of siloed communication:

• Isolated Decision-Making: Decision-making confined to specific departments without seeking input or insights from other relevant teams.

• Strict Hierarchical Communication: Hierarchical communication structures that inhibit open dialogue between employees at different levels and departments.

• Limited Information Sharing: Employees or departments not sharing crucial details related to an operational process or organizational objective with other teams.

• Communication Barriers: Limited or no communication channels between departments (e.g., no cross-functional meetings or cross-departmental projects).

• Competing Objectives: Departments pursuing individual objectives without considering broader organizational goals.

• Departmental Rivalries: Unhealthy competition or rivalries between departments.

• Inadequate Training Across Departments: Employees lacking training in areas outside their immediate department, limiting their understanding of the organization as a whole.

• Limited Cross-Functional Understanding: Employees having a narrow understanding of their own roles and responsibilities without a broader awareness of how their work contributes to the organization’s overall success.

While the above list is not intended to be all-inclusive, it does represent common scenarios where organizational departments operate in isolation, thereby hindering collaboration and overall efficiency.

Depending upon the circumstance, siloed communications can spill over into a compliance issue. For example, let’s assume there is a new Medicare billing requirement affecting a clinical department (e.g., medical imaging). If the medical imaging department was never made aware of the new requirement and continues to treat and bill for services provided to patients under the old requirement, the organization is now looking at an investigation and potential repayment. For that reason, it’s helpful for compliance officers to have some strategies for overcoming siloed communications in order to foster a more efficient—and compliant, organization. 

Strategies for Overcoming Siloed Communication

Below are some strategies that can help you when it comes to siloed communications:

• Self-Awareness: Be mindful about your own actions to ensure that you’re not engaging in siloed communication. When it is appropriate, and respectful, communicate with others in the organization who have a legitimate need-to-know.

• If You See Something, Say Something. If you are communicating with others, and recognize that someone with a legitimate need-to-know is not included in the discussion, say something. You can either speak up to whomever controls the communication, or close the loop yourself if it’s appropriate to do so.

• Encourage Cross-Functional Teams: When addressing a compliance-related matter, create cross-functional teams that include members from different departments so that all affected employees understand the broader picture of the organization.

• Promote Open Communication: When appropriate, be mindful of promoting a culture of openness where employees feel comfortable sharing ideas and information (e.g., establish regular project meetings, feedback sessions, surveys, one-on-one discussions, or open forums).

• Provide Cross-Training Opportunities: Whenever possible, cross-train employees to develop a broader understanding of different roles within the organization. This can be particularly helpful when it comes to ensuring the organization is meeting compliance requirements.

• Clarify Roles and Responsibilities: When appropriate for your role on a project, clearly define roles and responsibilities within each department to avoid confusion. If it is not within your role, then speak up to identify that need for the good of the group that is working on the project.

Pulling it All Together

Siloed communication is often a significant factor producing misunderstanding and conflict in an organization. At times, these situations can spill over into a compliance issue that needs to be addressed.

By implementing the above-noted strategies, you can help break down silos and create a more collaborative and compliant environment. Over time, developing this skillset will improve your ability to gain buy-in to the compliance program—and effectively navigate the politics of healthcare.

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If you liked this article, check out my book. It contains additional interpersonal communication strategies—a great gift for onboarding new team members to your organization.

Five Strategies for Handling Tough Feedback

Receiving tough feedback can be challenging, but let’s face it—it’s an essential part of personal and professional growth. In my opinion, that’s really true whether you work in compliance, or any other profession.

Yes, there are times when someone could say something in a kinder way, but as the recipient of the message, we have also a responsibility in how we respond. Learning how to accept critical feedback with grace and resilience can make all the difference in your development journey—and improve your ability to gain buy-in to your compliance program.

In this article, I’ll explore some common places where tough feedback intersects with compliance work, and provide some strategies to help you in overcoming this challenge.

Tough Feedback and Compliance

Call it criticism, or as a close friend of mine used to say—“a self-esteem workshop”—tough feedback is receiving a less-than-positive message about something you’re working on, or how you’re working on it.

In the compliance officer role, we often have to be the bearer of bad news with our healthcare leaders. To that end, tough feedback can take on many different forms. For example, it could be pushback from a department leader about how a regulatory change impacts their operations. It could be a disagreement about your response to a proposed business deal or the results of an audit. And tough feedback can be tied to how you are communicating your compliance message surrounding all these activities.

Knowing how to accept critical feedback can be a key factor between engagement and avoidance with your compliance program. For that reason, let’s take a look at some strategies that will help.

Strategies for Handling Tough Feedback

When it comes to handling tough feedback, you need to have the ability to focus on the content of the message instead of the messenger, or the way the message is being conveyed.

If that sounds easier said than done, then consider the following five strategies:

#1-Separate Emotion from Fact

It's easy to let emotions cloud your judgment when receiving tough feedback. When it comes to any situation, there are facts—and then there are interpretations of facts. The trick becomes identifying which one you are basing your response on.

To handle tough feedback effectively, you need to separate the emotion behind the feedback from the actual facts. To do that, keep your state of mind grounded in curiosity and not judgment. This will allow you to evaluate the feedback more objectively.

#2-Seek Clarification from a Curiosity State of Mind—Not a Judgmental One

Piggybacking off of the first strategy, if the feedback you’re receiving is unclear or ambiguous, then don't hesitate to ask for clarification—but do so from a state of mind rooted in curiosity and not judgment.

Keep in mind that when you’re receiving information, your state of mind will be felt by others. For example, if you’re bogged down in judgment, it will come across negatively as being defensive. On the other hand, if your state of mind is based on curiosity, it come across positively as being focused on how to improve.

To maintain your focus on curiosity, seek specific examples or instances where you may have fallen short. Also, even with the toughest feedback, there is often a grain of truth that you can learn from. Search for that instead of focusing on the negativity.

Taking these approaches not only helps you understand the feedback better but also demonstrates your willingness to learn and improve.

#3-Embrace a Growth Mindset

Building off of the last strategy, adopting a growth mindset is also crucial when handling tough feedback. Instead of viewing it as a criticism of your abilities, see it as an opportunity to learn and grow.

To that end, don’t be afraid to reach out for support from colleagues, mentors, or friends during challenging times. Discussing the feedback with others can also provide valuable insights and perspective to help you grow professionally.

#4-Keep Your Focus on Solutions—Not the Problem

Rather than dwelling on the problem that is the subject of the feedback, shift your focus to finding solutions. Here, you want to brainstorm actionable steps you can take to address the feedback and make meaningful changes.

By taking this approach, you not only develop your critical thinking skills, but also build confidence by independently developing potential solutions.

#5-Reflect and Process

Finally, take time out to reflect on the feedback once your initial emotions have settled. Here, it’s very important to climb outside of your head and identify “the why” behind the feedback that was given and how you can use it to become better.

For some practical steps, you can set aside this time for personal reflection, try journaling, or discussing the feedback with a trusted mentor or friend. These can all be strategies to help you process the feedback more positively and effectively.

Lastly, a disclaimer.

Despite my joking above, receiving tough feedback can be hard on ones’ self-esteem, so practice self-compassion by reminding yourself that nobody is perfect, and everyone makes mistakes. If you are passionate about your work, others will easily see that, and you’ll have the capital to lighten up on yourself when you make a mistake.

Tough Feedback and The Politics of Healthcare

Having the ability to handle tough feedback is a critical asset to help you in navigating the politics of healthcare. For example, when you are able to accept negative feedback and maintain a calming presence while doing so, you will position yourself as having a sense of professional judgment that can be trusted. Over time, this helps you build trust and develop stronger relationships with others in the organization.

Also, when you can focus on acting on the message being delivered and not evaluating how it’s being delivered, you become better equipped to think creatively to find solutions that work under any scenario.

Finally, being skilled at handling though feedback, aids your ability to resolve conflict by taking into account the point-of-view—and emotions—of other interested parties.

Pulling it All Together

Let’s be honest, handling tough feedback is never easy, and quickly challenges your ability to remain professional. With the right mindset and approach though, it can be a powerful asset for your growth and development.

Having this skillset will keep you from losing  your cool—and the trust of your healthcare leaders. Over time, these strategies will improve your ability to build stronger relationships with others in the organization and more effectively navigate the compliance program through the politics of healthcare.

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If You Want Buy-in to Your Compliance Program—Avoid "Gotcha Moments”

As compliance officers, we are continually placed in a position to influence the actions of others and shape our organization’s culture of compliance. Unfortunately, with a title like “compliance officer,” we have an image issue to overcome which makes our job that much harder. Before we even have a chance to say a word, healthcare leaders often see us a grown-up version of a hall monitor.

One way to change this perception is to avoid creating what I like to call “gotcha moments”.

In this article, I’ll define gotcha moments and take a look at how they can negatively affect your ability to influence the actions of others. I’ll also provide some strategies to help you in changing the perception of compliance so that you can successfully navigate your compliance program through the politics of healthcare.

What are Gotcha Moments?

For purposes of this discussion, a gotcha moment means trying expose or embarrass someone for doing something wrong. For example, let’s assume my six year old tells me he brushed his teeth this morning. If I surreptitiously go into his bathroom to see if his tooth brush is wet, and then confront him about it because it’s dry—that’s a gotcha moment.

In the context of the corporate world, let me give you another example. Assume a fellow employee sneaks around to find the answer to a question and then asks someone on the team the question to see if he or she knows the answer, or potentially catch a co-worker in a lie—that’s also a gotcha moment.

Compliance and The Gotcha Moment

So, what does a gotcha moment look like relative to compliance work?

Let’s imagine someone in the compliance department is conducting an audit involving the review of medical-necessity documentation to substantiate billing Medicare for physical therapy services. For funsies, let’s call this person“Schmidlap”.

Let’s assume Schmidlap holds an entrance conference with the department director, (“Laurie”), to explain the purpose and scope of the audit. After the meeting, Schmidlap goes off to review the documentation against the regulatory requirements, but never asks Laurie about how the department provides and documents the service for billing purposes. At the end of the audit, Schmidlap holds an exit conference with Laurie, and her supervisor, where he reveals that all the claims audited in his sample were missing documentation to support medical necessity. As a result, Schmidlap tells the Laurie that the organization now has to refund several thousand dollars in overpayments and implement a corrective action plan.

Since Schmidlap waited until the end of the audit to reveal the issues he was finding, it’s going to feel like a gotcha moment to Laurie. Relatedly, she is going to feel like the purpose of the audit was to embarrass her in front of her supervisor.

The problem with engaging in such behavior, as a compliance professional is that our job title alone sends a message that the very goal of our position is to do this. For that reason, being mindful of gotcha moments and avoiding them whenever possible, will go a long way to obtaining buy-in to your compliance program.

The Political Fallout from “Gotcha Moments”

The biggest downside to gotcha moments is that they signal deception. This contradicts, and can render moot, any efforts you’ve made to establish the compliance program as something to be trusted.

In that audit example above, if Schmidlap didn’t talk to Laurie about what he was finding and then delivered shocking news to her…at best,Laurie is going to feel blindsided. At worst, she is going to feel disrespected as a human being.

Gotcha moments can also cause others to question your credibility or professionalism. In the audit example, what if Schmidlap was wrong in his conclusion that the documentation didn’t exist? What if the documentation ended up living in another part of the medical record that Schmidlap wasn’t aware of, because he didn’t take the time to talk with Laurie. Such a situation would potentially raise concerns about the quality of Schmidlap’s work product and whether it can be trusted.

Strategies to Avoid “Gotcha Moments”

So, how can you avoid creating gotcha moments in compliance work? Here are four strategies that will help.

#1-Subscribe to a “No Surprises Act” Communication Plan

Whether you are consulting to employees on a matter related to the organization’s business or compliance agenda, conducting an audit, or anything in between—communicate with them. Have an open dialogue with those you encounter to make sure you understand the facts.

Also, if you identify a potential issue, bring it up promptly and be transparent. If there is one thing I’ve learned in my career, it’s that healthcare leaders do not like to be surprised. That’s true whether one of their direct reports is notifying them of a budgeting or clinical care mistake, or if you as the compliance officer are notifying them of a high-risk issue.

#2-Have a Strategy for Delivering Bad News

Unfortunately, sometimes, it’s our job to be the messenger of bad news. When faced with this situation, have a plan for how you will deliver the news that addresses two central questions:

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

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

Since bad news has the potential to shock, the first question will help you figure out how the news will land with your audience. The second question is intended to help you see the issue from your audience’s perspective and reduce their anxiety.

#3-Assume Neutral Intent When Consulting to Your Healthcare Leaders

When you are consulting to healthcare leaders, assume neutral intent until your facts prove otherwise. Neutral intent means that we don’t know whether a person acted with good or bad intent. When you assume neutral intent, you avoid inappropriately judging others or jumping to conclusions. (Note: Your communications also will be received with more respect.)

#4-Establish a Default Mindset of Curiosity—Not Judgment

If you are working on an audit, or advising about whether or not certain conduct is compliant, question people from a place of curiosity and not judgment. Given your role, others will assume that you are attempting to judge them. You can avoid that perception by proactively disclaiming that your intent in asking questions is merely to understand the facts.

Pulling it All Together

As a compliance officers, we work hard to foster a healthy culture of compliance and positively influence the actions of others. We also want our colleagues to have a psychologically safe place to report issues and concerns. That said, gotcha moments undermine this work and cause employees to lose trust in the compliance department.

By following the above-noted strategies, you will be more self-aware of potential gotcha moments and put yourself in a position to avoid them whenever possible. When you take this approach, it will not only improve buy-in to your compliance program, but help you successfully navigate the compliance program through the politics of healthcare.

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How to Avoid Creating a False Sense of Urgency

In the fast-paced environment of today’s highly regulated healthcare industry, urgency often appears in compliance work as a driving force behind productivity and success. Not all matters are urgent though, and creating a false sense of urgency can backfire in the form of heightened stress, burnout, and ineffective decision-making. 

Given that our audience generally assumes urgency based on our job titles alone, it is critical to be able to distinguish between genuine urgency—and a manufactured one.

In this article, I’ll explore circumstances that create a false sense of urgency and provide some strategies for overcoming this challenge. Having this skillset can keep you from losing the trust of your healthcare leaders and improve your ability to navigate the compliance program through the politics of healthcare.

A False Sense of Urgency

So what is a false sense of urgency? It’s self-explanatory, but to illustrate what it looks like in the field, consider the following situational examples…

• The Overuse of “Urgent” Communications. The practice of labeling every task as urgent, even the ones that aren’t true emergencies.

• Setting Arbitrary Deadlines. This conduct involves setting deadlines for others without a clear rationale or consideration for the actual time needed to complete the task.

• Micromanagement. The practice of demanding immediate updates or engaging in continual oversight on tasks that don’t warrant such attention.

• Procrastination. Waiting until the last minute to address important tasks.

• Perceived Competition. Believing that success hinges on outpacing others in a race to achieve what is an internally-imposed goal.

While not an all-inclusive list, they do have a common theme—they all represent manufactured emergencies.

A False Sense of Urgency and The Politics of Healthcare

The problem with creating a false sense of urgency is that it negatively affects your ability to navigate the compliance program through the politics of healthcare. For example, let’s look at overuse of urgent communications. This approach is similar to the story in Aesop’s fable—The Boy Who Cried Wolf. If you’re labeling every task as urgent, it dilutes the significance of your true emergencies. The end result is that your audience will tune you out at a time when you need it most.

Also, if your audience is receiving emails consistently marked as urgent, but the matters are trivial in nature, you may experience difficulty in building strong relationships. That is because the overuse of urgent communications creates unnecessary stress felt by others. It also causes them to question if your professional judgement is one that can be trusted.

Strategies to Avoid Creating a False Sense of Urgency

So what can you do to reduce your chances of creating a false sense of urgency? Below are six strategies that can help.

• Prioritize Tasks Objectively. Take the time to prioritize tasks based on their true importance and deadlines. Avoid inflating the urgency of every task so as not to dilute the significance of genuinely time-sensitive matters. Ask yourself is this deadline important to serving your needs, or that of the organization?

• Evaluate Your Consequences. Before labeling a task as urgent, consider the actual consequences of delayed completion. Is your deadline related to a government audit, or revising an internal document? Not every task carries equal weight and recognizing that will help you prioritize effectively.

• Set Realistic Deadlines. Establish deadlines that are reasonable given competing demands for time. This will allow for adequate time to complete tasks effectively.

• Impose Buffer Zone Deadlines. Add in a buffer zone to your project timelines. For example, if your actual deadline is June 30th, seek to have it completed by June 15th. This will help you account for unexpected delays or revisions that are needed to your work.

• Communicate Clearly. Articulating clearly about the expectations for timelines, deliverables, and the rationale behind urgent requests can help avoid misunderstandings about urgency.

• Judiciously Label Communications as Urgent. Reserve the "urgent" label for situations that genuinely require immediate attention and pose heightened risk to the organization.

(Note: For some additional strategies, consider checking out two companion articles I wrote last year: How to Maintain a Calming Presence when Responding to Compliance Issues and How to Take a Big Picture Approach to Compliance Work.)

Pulling it All Together

Distinguishing between genuine urgency and manufactured pressure is essential for maintaining productivity, and fostering a healthy culture of compliance throughout the organization. In the long-run, having this skillset can also help you effectively navigate the politics of healthcare.

Keep in mind that in order to avoid creating a false sense of urgency, you’ll need healthy dose of self-awareness about how you are interacting with others. By following the above-noted strategies though, you will not only improve your self-awareness, but also experience an increase in buy-in to your compliance program.

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Overcoming Communication Blind Spots

Effective communication is a cornerstone of successful interactions, whether it’s personal relationships or in a professional setting. That said, even the most well-intentioned communicators can fall victim to blind spots that hinder mutual understanding and connection.

As it relates to resolving a compliance matter, knowing how to interact with others in the organization can be the difference between getting push-back and obtaining buy-in. For that reason, being able to recognize and address these blind spots can be helpful for fostering clearer, more meaningful communication.

In this article, I’ll identify a few common communication blindspots and provide some helpful tips to improve your ability to navigate the politics of healthcare.

Communication Blind Spots

While not an all-inclusive list, below are four common communication blindspots that tend to exist in healthcare organizations. Getting a handle on each of these can help you avoid misunderstandings and potential conflict.

The Hierarchical Barrier

With any healthcare organization, there is some type of organizational structure consisting of employees, supervisors, managers, directors, senior leaders, and a governing board. With all these different layers, it is very easy for information to get filtered or distorted as it moves up or down the organizational hierarchy.

While there is a legitimate need for controlling certain information within the organization so as not to jeopardize the ability to make effective business decisions, there can be a downside. Gaps in understanding get created and details or feedback from some levels in the organization may not reach the decision-makers accurately.

Here are some tips that can help you navigate this blind spot:

• Be mindful of need-to-know communication. If you’ve identified another individual or department that has a legitimate need-to-know, then ask if they have been made aware of the information, or if appropriate, take steps to close the knowledge gap.

• When appropriate, encourage open communication channels with those who have a legitimate need-to-know.

• Empathize with those who are not in-the-know. Ask yourself, “If I was in this person’s shoes, would I want to know this information?” Then be judicious about taking action. If you own the communication and it’s appropriate to be transparent, then proceed in letting the other person know. If you do not own the communication, then determine if it is appropriate to voice your concerns to your supervisor, or whomever owns the communication.

The Assumption Trap

“The Assumption Trap” occurs when one assumes that others in the organization share the same knowledge or perspective as the communicator. The risk here is that if the audience does not share the same knowledge or perspective, it leads to misunderstandings, which often leads to conflict.

Here are some tips that may help overcome this blindspot:

• Actively listen, ask clarifying questions, and speak back information to ensure all parties understand the facts.

• Challenge your assumptions and the assumptions of others. 

• Make sure that conclusions are based on facts and not personal opinions. 

(Note: For more information on challenging assumptions, check out this companion article.)

The Siloed Communication

Ahhhh, the dreaded silo. You’re likely familiar with this little gem, but if not, this communication blindspot happens when departments or individuals fail to appropriately communicate with others (thus operating in isolation like a silo).

“The Siloed Communication” often leads to a lack of coordination and shared understanding about a particular matter. As a consequence, projects suffer from misalignment and healthcare leaders get surprised with unexpected information. For example, if an internal auditor conducts an audit and identifies payer refunds, but neglects to notify the CFO about the refunds—that’s siloed communication.

When it comes to the politics of healthcare, the problem with siloed communication is that it leads to frustration and creates the potential for conflict. Additionally, in the context of my internal audit example, taking such an approach signals deception—which renders moot—any efforts to establish the compliance program as something to be trusted.

If siloed communications is something you’d prefer to avoid, here are some tips that can help:

• Promote collaboration and open communication during meetings and calls by identifying all interested parties that need to be aware of the content of a communication.

• Follow the tips I mentioned above for “The Assumption Trap” to avoid presuming that an individual is aware of a communication.

• As appropriate, validate with the communicator that an individual with a legitimate need-to-know is made aware of the content of a communication.

The Unclear Expectation

Finally, we come to “The Unclear Expectation”. Here, the concern with this blindspot is that lack of clarity leads others to not understand their roles, which leads to confusion or inefficient productivity. This can be especially true when the communication is coming from the compliance department and it relates to getting others to follow a regulation or internal policy.

Keep in mind that when you are communicating with a healthcare leader about a compliance issue, these folks likely will not be as knowledgeable about the rules as you are—so there is a knowledge gap. Be mindful of that potential and close the gap if you’ve identified one exists.

You also want to make sure you are clear about the compliance expectation. Here, my recommendation would be to ask yourself honestly, “Am I clear about what I’m expecting of others?” If you’re struggling with answering that question, then chances are you’ve either not critically thought through the matter, or there are some questions that still need to be answered.

(Note: A separate discussion on the importance of critical thinking skills in compliance can be found here.)

So how can you overcome this communication blind spot?

Here are some tips that may help:

• Strive for clarity in your communication by avoiding jargon, ensuring conclusions are based on facts, and mapping out the communication from beginning to end in an outline.

• Before you communicate with a healthcare leader about a compliance expectation, make sure you can answer this question from their perspective—”So what do you need from me?”

• If someone else owns the communication and has not clearly communicated an expectation, speak up and let them know. (You can use the question mentioned in the bullet point directly above.)

Pulling it All Together

Communication blind spots play a significant role in the politics of healthcare. For example, workplace conflict often exists because of a lack of information or false assumptions based on limited information. Additionally, engaging in siloed communications, or ones involving “gotcha” moments, can damage your relationships with healthcare leaders and contradict your efforts to build a strong culture of compliance.

For those reasons, it is important to be mindful of communication blindspots and address them whenever possible through the above-noted tips. These can help avoid conflict, or at a minimum, prevent a little mess from turning into a big one.

If there is one piece of parting advice I can offer it is this—when it comes to communication blindspots, follow your own recommendation to employees for reporting a concern—if you see something, say something. 

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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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If you liked this article, there are many more effective communication strategies in my new book…

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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If you liked this article, there are many more effective communication strategies in my new book…

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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For more communication strategies, check out my new book…

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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