For the compliance officer, an effective strategy for navigating the politics of healthcare is to think like a healthcare leader. This is true whether you’re consulting to leaders on a proposed business deal, conducting an investigation, or anything in between.
Last week I talked generally about how to think like a healthcare leader. This week we’ll piggyback off that discussion by focusing on one leader—a healthcare CEO. We’ll take a look at the CEO’s role and responsibilities, what shapes their point-of-view (POV) and how to position compliance to appeal to a CEO’s POV.
CEO Role and Responsibilities
As the highest-level healthcare administrator, the CEO has the overall responsibility for the organization’s day-to-day operations and fulfilling its strategic vision. CEO positions are often filled by individuals possessing business backgrounds; however, there has been an increasing trend of CEOs possessing a clinical background too (e.g., an MD or RN). While the exact CEO responsibilities will vary by organization, they likely will include the following:
Organizational vision. The CEO must have a vision for the organization’s future, such as an identified market presence or access to high-quality healthcare.
Strategic planning. The CEO must have an identified roadmap of future goals and objectives for achieving the organizational vision.
Maintaining financial stability. The CEO needs to ensure the organization maintains financial health and stability. If the organization is a tax-exempt organization, there are additional responsibilities for ensuring it is meeting its charitable mission.
Recruitment. The CEO must ensure the organization has the physicians and other clinical staff to meet the needs of providing services to the community.
Patient safety. The CEO must ensure patients are cared for safely through established safety measures.
Promoting high-quality healthcare. The CEO must be committed to improving the quality of healthcare provided to the organization’s patients.
Patient satisfaction. The CEO must ensure the organization is meeting established patient satisfaction benchmarks.
Organizational compliance. The CEO must ensure the organization is maintaining compliance with all federal, state, and local laws and regulations, and maintaining a healthy culture of compliance.
In order to carry out these responsibilities, the CEO needs to fulfill several different roles. First and foremost, the CEO is a business leader. He or she must balance the management of operations against the organization’s finances to ensure it is effectively utilizing resources. CEOs of organizations providing patient care must additionally manage the added pressure of competition from other market participants.
The CEO must also fill the role of politician. They continually have to manage communications and relationships. Since CEOs are responsible for overseeing a number of different operations, akin to those of a small town, the CEO is the face of this community, much like a mayor is for a city. That requires being adept at knowing what information needs to be shared with constituents and when it needs to be shared. Externally, the CEO has to manage relationships with several parties, such as business partners (e.g., physicians), business competitors, government regulators, community leaders, patients (and their families), and the media. Given the demands in managing all these relationships, they must be skilled in communication and conflict resolution. When it comes to a day in the life of a CEO, their schedules are typically packed from early morning meetings to business dinners lasting well into the evening.
A CEO’s POV
A CEO’s POV is going to be shaped by fulfilling the organization’s identified objectives that support the overall strategic plan approved by the board. With that said, many of the decisions a CEO has to make can be traced to one of three self-interests. First, what is in the best interest of the patient? That is true whether the matter is starting a new service line, resolving a complaint, or terminating a physician from the medical staff. Second, what is in the best interest of the organization? Whether it’s a business decision of the CEO or any of his or her direct reports, CEOs are motivated by the ones that result in the least amount of legal, financial, or reputational risk. Finally, the CEOs are motivated by acting in the best interests of their own careers. I’m not saying that to be judgmental, but rather, as a matter of fact. We’re all motivated to act in the best interest of our careers. As part of the organization’s strategic plan and objectives, the board will be evaluating the CEO on how he or she is performing based on criteria set by the board.
A CEO’s Political Pressures
A CEO’s POV is also going to be shared by a number of political pressures. While not an all-inclusive list, some of these pressures include:
The community expecting the CEO to deliver high-quality, low cost patient care services.
The board expecting the CEO to do more with fewer resources.
The department leaders expecting the CEO to provide more resources.
The physicians expecting the CEO to increase their compensation and have more control over clinical decisions.
The employees expecting the CEO to be a great leader (inspiring and visionary).
The community leaders expecting the CEO to be an active participant who is contributing to the community.
The board expecting the CEO to be competitive in the market.
The government and the compliance officer expecting the CEO to ensure the organization remains compliant with all laws and regulations.
As you approach your work as a compliance officer, it is important to keep these political pressures in mind as they may provide you with “the why” behind the decisions he or she is making.
Positioning Compliance for a CEO’s POV
When it comes to your work as a compliance officer, you should be thinking about it from the CEO’s perspective. If you were in his or her shoes, what information would you want to know? For example, let’s say you identified a potential breach of one thousand patient records. As the CEO you’re going to want to know the details of what happened and how this issue was discovered. You also want to know the risk involved with a breach (e.g., financial and reputational). Finally, you want to know what steps the compliance officer is taking to correct the issue and prevent a future occurrence.
Keep in mind that depending upon the nature of the issue, the CEO may be duty-bound to report the matter to the board, so consider his or her perspective in carrying out that responsibility. As a general rule, the level of detailed information you need to provide the CEO should match the level of risk involved. For example, if you’re addressing a six-figure overpayment to Medicaid, a high level of detail is needed; if it’s a small refund involving a few claims, an overview or summary will do.
Pulling it all Together.
Having an awareness of your CEO’s role and responsibilities, POV, and political pressures will help you understand how best to position a compliance matter for success. You will understand why certain decisions are made, recognize why you are getting pushback, and have the ability to anticipate future decisions. It will also help you in successfully navigating the politics of healthcare to gain buy-in to your compliance program.
Now, that we’ve climbed into the mind of a healthcare CEO, next week we’ll take a look at another healthcare leader-the CFO.