In the business of healthcare, where ethical integrity and adhering to regulatory requirements are critical to an organization’s success, promoting a culture of compliance is not merely a goal; it's a necessity. That said, implementing compliance policies or appointing an individual to be the compliance officer is not enough. There has to be a commitment throughout all levels of an organization to do the right thing—and do things right.
In other words, a culture that is contagious.
Not too long ago I stumbled across a book by Jonah Berger, Ph.D., entitled "Contagious: Why Things Catch On." Dr. Berger’s book explores the science behind why certain ideas, products, or messages go viral, while others do not. According to Dr. Berger, there are six key psychological drivers for word-of-mouth communication among humans:
1. Social Currency
2. Triggers
3. Emotion
4. Public
5. Practical Value
6. Stories
As compliance officers, we are continually placed in a position to influence the actions of others. For that reason, we play a significant factor in shaping our organizations’ culture of compliance. The question then becomes— How can we make a culture of compliance worthy of word-of-mouth?
Using Dr. Berger’s framework as a roadmap, below are some ideas to get you started.
Social Currency
This concept relates to the things we talk about that make us look good to others or enhance our social status. Dr. Berger’s theory is that when something makes people feel knowledgeable or "in the know," they are more likely to share it. For example, think about that new “bingworthy” show you came across via a streaming service. You likely went and told others about your experience, right?
That’s social currency.
So how can we create social currency in the context of compliance work?
Here are some suggestions:
Find a compliant and business-friendly solution for a proposed new venture that’s being advanced by one of your healthcare leaders.
Identify lost revenue for a department director while investigating a matter or conducting an audit.
Incorporate feedback from a department leader in a compliance-related decision (e.g., finalizing a new process or policy).
These are just a few examples where the effort you put into your work will result in your leaders looking good—which in turn improves your chances that they will tell others about what you did for them.
Triggers
Triggers are certain cues in the environment that can prompt people to talk about a product or idea. According to Dr. Berger, familiarity and everyday reminders play a significant role in keeping things top-of-mind. For example, if I were to say “Peanut butter and...,” you’re most likely thinking of jelly even though I didn’t have to say it.
That’s a trigger.
So how can we create triggers in the context of compliance-work?
Here are some ideas:
Get out of your office and walk around your organization so others physically see you.
Conduct routine rounding (e.g., consistently visit with staff to see how they’re doing, what’s working well, and what’s not working well).
Make sure compliance hotline posters are not only displayed throughout the organization, but they have your name and photo on them so others identify you as the person to contact.
These are just a few examples of how you can establish triggers that keeps compliance on the minds of your colleagues. It also helps you establish rapport with others in the organization.
Emotion
According to Dr. Berger, stories with strong positive or negative emotional elements are more likely to be passed on because they create a deeper connection with the audience. For example, you’ve likely seen advertisements for pet adoption services. As a pet owner, those ones are tough for me to watch, but they do grab my attention.
That’s emotion.
Here are ways to use emotion in compliance:
Celebrating milestones and achievements (e.g., 100% completion rate for training, a successful audit, or acknowledging a process change that reduced non-compliance rates).
Using situational examples from a patient’s point-of-view when discussing potential non-compliance.
Outlining the financial and reputational impact to a department or organization when discussing concerns of non-compliance (e.g., a breach of PHI that leads to patients’ loss of trust).
By taking these approaches, you are embedding an emotional connection to your compliance message. Over time, this results in a message that resonates with your audience, and is not forgotten when they’re confronted with the next problem to solve.
Public
Public refers to the behavior of others that people mimic, especially in public settings. If something is observable and easily seen, it's more likely to be shared. For example, when my 10-year-old sees one of her friends at school with a cell phone, she comes home and makes an argument to my wife and I that we need to buy her a cell phone.
That’s the “public” drive of something that is contagious.
Here’s how we can build this kind of behavior in others:
Emphasize to your organizational leaders that leading by example demonstrates to employees that a culture of compliance is desired.
Recognize a leader or employee in a public forum (e.g., a meeting or newsletter) when they have supported the compliance program.
Send a thank-you note to an employee’s supervisor when the employee supported the compliance program (e.g., they reported a concern that needed to be corrected).
These are just a few examples of taking a public approach to your work—and fostering word-of-mouth about your compliance program.
Practical Value
People share things that help others solve problems or improve their lives. For example, when I was a kid, there was a TV commercial for Super Glue. In this commercial, they would show a gentleman hanging from a steel beam because they had glued his hard-hat to it. Though I wasn’t working in construction, this image did seem useful if I ever found myself in such a situation.
So how can we create practical value in the context of a culture of compliance?
Here are some ideas:
When you are explaining complex compliance-related concepts, show others how the organization needs to comply rather than telling them. Find or create interesting or memorable visuals, and then use them.
As you are communicating your compliance message, emphasize how meeting the requirements benefits your audience, not you.
Making sure that compliance resources are easily accessible (e.g., make it easy to find and use).
Stories
According to Dr. Berger, stories make content more relatable, memorable, and shareable. For example, a few years ago, automobile manufacturer Subaru ran an ad campaign featuring owners of their cars and their stories of how they survived accidents. The ads reinforced the message that Subaru builds a safe car, and used customers’ stories to convey that message.
We also can use stories to generate word-of-mouth within our organizations.
For example, we can:
Show examples of when non-compliance affected patient care (in a way that doesn’t violate HIPAA, of course).
Discuss how a similarly sized organization arrived at a recent settlement when presenting a training.
Profile employees who are courageous enough to talk about an important compliance matter (in a way that doesn’t reveal the identity of the employee).
Pulling it All Together
Creating a contagious culture of compliance is a continuous journey. It requires dedication, consistent effort, and a genuine commitment to ethical values. When done well, and compliance becomes ingrained in the organization’s DNA, it has tremendous benefits including minimizing risk and enhancing the organization's reputation. It also can help you navigate the compliance program through the politics of healthcare by building stronger relationships with your leaders.