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 about thinking like a CMO and how position compliance to someone in a CMO role. This week we’ll take a look at another leader that the compliance officer has to interact with when it comes to clinical matters—the CNO. We’ll look at CNO’s role and responsibilities, what shapes their point-of-view (POV) and how to position compliance to appeal to a CNO’s POV.
CNO Role and Responsibilities
The CNO is the highest-ranking nursing leader in the organization. Overall, the CNO’s role is to ensure that patient care and clinical quality standards are maintained. In fulfilling this duty, CNOs have the responsibility of overseeing the daily operations of nursing staff, which may also include other clinical staff (e.g., lab techs). CNOs tend to have significant knowledge of the organization’s clinical processes and procedures as well as local, state, and federal regulations impacting clinical care services.
Similar to other senior management positions, CNOs are often excellent communicators, having spent years developing their leadership and business skills. CNOs are often highly skilled in critical thinking and strategic planning. They also have the ability to adapt quickly to unexpected changes as their clinical staff are required to do on the floor every day.
While the specific duties of a CNO will vary, they often include the following:
Clinical operations oversight. Overseeing the daily clinical operations of the organization, including planning, organizing, coordinating, and directing clinical care services.
Nursing leadership. Serving as a nursing spokesperson to the board, other members of senior management, and the employees.
Physician and provider liaison. Serving as a communication link between clinical staff and physicians or other healthcare providers.
Patient safety oversight. Ensuring any patient-safety-related issues are resolved with specific steps outlined to prevent future occurrences.
Clinical performance. Ensuring the organization is meeting identified clinical metrics tied to quality, reimbursement, and patient satisfaction.
Financial performance. The CNO ensures clinical departments are meeting operational budgets.
Clinical policies and procedures. Overseeing clinical policies and procedures to ensure they are developed, implemented, and current as well as ensuring staff are trained on them.
Organizational compliance. The CNO must ensure the organization is maintaining compliance with all federal, state, and local laws and regulations as well as supporting a healthy culture of compliance.
Thinking Like a CNO
A CNO’s POV is going to be shaped by three primary self-interests. First, what is the best interest of the patient? If a negative outcome occurs involving a patient, the CNO may be involved to oversee the matter. Relatedly, a CNO will be thinking about how best to provide leadership to ensure the issue is resolved and that steps are taken to prevent future occurrences.
Second, what is in the best interest of the organization? Here, the CNO’s focus is going to be ensuring the organization is competitive in the market and meeting certain clinical standards. For example, CNOs may implement new nursing strategies or revise existing ones to ensure patients receive high-quality, safe, and efficient care.
Finally, what is in the best interest of the clinical staff? Here, the CNO’s focus is going to be ensuring effective communication and processes exist to support clinical staff in making decisions that impact patient care.
CNO Political Pressures
A CNO’s POV is also going to be shaped by a number of political pressures. While not an all-inclusive list, some of these pressures include:
The CEO/board and community expecting the CNO to deliver high-quality care to patients.
The CEO/board and community expecting the CNO to keep patients safe and resolve identified clinical risk concerns involving patient care.
The CEO/CFO/board expecting the CNO to meet quality standards tied to reimbursement.
The CEO/board expecting the CNO to successfully pass organizational surveys and inspections tied to quality of care and patient safety.
The CFO expecting the CNO to meet operational budget goals and do more with less.
Department leaders expecting the CNO to keep up with the clinical staffing, equipment, and technology resources of the organization’s competitors.
The physicians expecting the CNO is to resolve workflow concerns involving physicians and clinical staff members.
The government and the compliance officer expecting the CNO to ensure the organization remains compliant with all laws and regulations.
Positioning Compliance for a CNO’s POV
When it comes to your work as a compliance officer, be thinking about it from the CNO’s perspective, which means there are two areas of focus. First, how does your work impact patients? Second, how does it impact clinical staff? For example, assume you were communicating with the CNO about a new regulatory change affecting operations. What impact will this change have on the communication between staff who are serving the patients? Will new policies and procedures, forms, or checklists need to be developed? Who will be responsible for implementing them? Who needs to be trained on the new changes, and who is responsible for conducting the training? These are just examples of some of the questions you need to anticipate a CNO may ask you as you work together on a compliance matter.
Pulling it All Together
Having an awareness of your CNO’s role and responsibilities, POV, and political pressures will help you understand how best to position a compliance matter for success. To help gain buy-in to your compliance program, develop a strong business relationship with your CNO. As an individual with clinical oversight for the organization, he or she is going to be deeply knowledgeable about clinical processes and procedures. For that reason, CNOs can provide you valuable insight into clinical operations and help enlist clinical staff to support your compliance program activities.