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 healthcare CFO and how position compliance to someone in a CFO role. This week we’ll take a look at another leader that the compliance officer has to interact with when it comes to physician-related matters—the CMO. We’ll look at CMO’s role and responsibilities, what shapes their point-of-view (POV) and how to position compliance to appeal to a CMO’s POV.

CMO Role and Responsibilities

A CMO has the overall responsibility for ensuring that safe, effective, and high-quality care is delivered to patients by physicians on the medical staff. CMOs are typically physicians who have made a shift from clinical practice to an administrative role, either on a part-time or full-time basis. The CMO is a liaison role between the hospital and various internal and external parties. These parties may include other members of senior management, the board, and community business partners, as well as patients and their families. The CMO represents the hospital but also serves as a spokesperson for the employed or contracted physicians on the medical staff.

While the specific duties of a CMO will vary, they typically involve the following:

Physician services operational oversight. Overseeing all clinical operations involving physicians on the medical staff.
Established clinical performance goals. Defining and monitoring clinical performance to ensure goals are met by the medical staff.
Quality improvement. Overseeing any quality improvement activities involving physicians on the medical staff.
Policies and procedures. Assisting with policy and procedure development specific to the medical staff (e.g., organizational policies, medical staff bylaws, medical staff rules and regulations).
Accreditation oversight. Assisting departments or organizations in obtaining and maintaining accreditation (e.g., The Joint Commission, American College of Radiology).
Financial oversight. Assisting the organization in developing cost-containment strategies that involve the medical staff, in addition to ensuring that quality-based metrics tied to reimbursement are met.
Strategic planning. Participating in long-range planning of the organization, including decisions related to equipment, budgeting, and physician staffing.
Education. Facilitating educational offerings to physicians on the medical staff or offerings to the community.
Resolving identified issues. Assisting with physician-to-physician communication as well as communication with patients and their families to resolve clinical care concerns.
Organizational compliance. The CMO 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.

In order to carry out these responsibilities, physician leaders like a CMO need to be excellent communicators, adept at conflict resolution. They also need to possess the technical skills to step in and review either a physician’s performance or a department’s clinical processes.

A CMO’s POV

The POV of a CMO is going to be shaped by three primary interests. First, what is in the best interest of the patient? As a medically trained physician, the CMO is predisposed to be thinking about all operational decisions from the perspective of the patient.

Second, what is in the best interest of the organization? Here, the CMO’s focus is ensuring the physicians on the medical staff are following the organization’s policies and procedures as well as all applicable regulatory requirements. Additionally, the CMO will be motivated by fulfilling the organization’s strategic plan by being competitive in the market and providing high-quality care.

Finally, what is in the best interest of the physicians? Given the CMO’s role, all physicians on the medical staff, regardless of specialty, are going to be the CMO’s constituency. The CMO serves as a voice for them as he or she resolves identified issues with the hospital or any external parties (e.g., patient, government agency).

CMO Political Pressures

A CMO’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 CMO to deliver high-quality care to patients.
The physicians on the medical staff expecting the CMO to fight for what they think is the right.
The CEO/board expecting the CMO to keep the physicians aligned with policies, directives, and business goals of the organization.
The CEO/board expecting the CMO to resolve any clinical performance or behavior-related concerns involving physicians on the medical staff.
The CFO expecting the CMO to meet operational budget goals and do more with less.
The physicians expecting the CMO to keep up with the clinical staffing, equipment, and technology resources of the organization’s competitors.
The physicians expecting the CMO to resolve workflow concerns involving physicians and clinical staff members.
The government and the compliance officer expecting the CMO to ensure the organization remains compliant with all laws and regulations.

Positioning Compliance for a CMO’s POV

When it comes to your work as a compliance officer, be thinking about it from the CMO’s perspective—which is to say, like a physician. Keep in mind that what you are telling the CMO is going to be interpreted from the vantage point of a physician and how patients are going to be impacted. Any time you have a need to speak with a physician about a compliance matter, it is best to have a CMO, or another appropriate physician leader, involved. In my experience, physicians respond more positively to a compliance message when another physician is involved.

Pulling it All Together

Having an awareness of your CMO’s role and responsibilities, POV, and political pressures will help you understand how best to position a compliance matter for success. Similar to the other healthcare leaders we’ve covered the past few weeks, you will understand why certain decisions are made and recognize why you are getting pushback. You will also develop a skill to anticipate future questions or decisions from your CMO.

To help gain buy-in to your compliance program, develop a strong business relationship with your CMO. The CMO can be a critical ally for you when addressing identified physician clinical or behavioral concerns impacting the compliance program. Additionally, the CMO can serve as a physician champion to help promote the compliance program to all physicians on the medical staff.

Now, that we’ve climbed into the minds of a healthcare CEO, CFO, and CMO next week we’ll take a look at one last healthcare leader—the Chief Nursing Officer (CNO).