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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