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.
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.
