The Compliance Officer’s Challenge of Building a Culture of Compliance
Written by Joanne Byron, BS, LPN, CCA, CHA, CHCO, CHBS, CHCM, CIFHA, CMDP, OHCC, ICDCT-CM/PCS
This article is provided by the American Institute of Healthcare Compliance in celebration and support of healthcare Compliance Officers and the many challenges faced in today’s environment when building a culture of compliance.
The Compliance Training Challenge
You are working against “Here we go, again” attitude. Workforce members attend HIPAA, compliance, OSHA and other mandatory training sessions, then go right back to their job without much change unless the trainer catches their attention and can influence behavior. The best approach to get the attention of others is through trust and respect. Otherwise, why would anyone listen to you? This can be difficult when the work environment is tense with increased demands made on workforce members, which includes providers.
Changing the dynamics takes time, but time well-spent
Connecting with your workforce happens when you are seen as a role model, as respecting everyone, taking responsibility even when things don’t turn out as expected and that you are present and available. This builds trust.
Training is more than talking, it involves excellent listening skills. Talk less, listen more. Understanding how things get done on various levels within the organization is important. Gaining this knowledge means asking the right questions and attentive listening. Be present, ask to attend various department meetings, not to talk, but listen. Get to know more members of the workforce so you can connect on a more personal level.
People won’t talk in front of you or directly to you if they can’t trust you.
You are only empowered to influence change in your organization by connecting, removing yourself from any internal politics, choosing your words carefully, being honest and paying attention to nonverbal cues.
Influence others to follow your lead in building a culture of compliance
Influence is not the same as manipulation, so don’t get confused. To be an effective compliance officer, you must achieve cultural intelligence.
This means having the ability to adapt your communication skills appropriately within the various cultures in your organization. Cultural intelligence is also called cultural quotient or “CQ” and refers to the skill where you can relate and work effectively in culturally diverse situations, a requirement for compliance consultants and compliance officers working in a large healthcare system. Cultural intelligence is a vital tool among the components of effective workplace communication, especially in a large organization with different cultural personalities.
As you connect with the workforce and listen to gain a better understanding of the various cultures within your organization, you should simultaneously be building trust.
A culture of trust is the foundation to building a culture of compliance
Trust not only builds a culture of compliance, but can directly influence quality of care for our patients. The health care system in the United States needs to continue improving quality, access and cost while operating in compliance to applicable rules and regulations. Health care must be safe, effective, patient centered and delivered timely, efficiently and in an equitable manner. This cannot be achieved unless the organizational culture is compliant and trustworthy.
A culture of trust is built on mutual respect, communication, and a shared commitment to success. It takes time to develop trust within a team or workplace, but it is worth the effort. A culture of trust can lead to increased participation in promoting the organization’s compliance program by improving engagement.
Building trust starts with you. Others are more likely to listen to you if they feel you are honest, competent and reliable. Working on these attributes may be the first step you take.
Be sincere. Sincerity is the assessment that you are honest, that you say what you mean and mean what you say; you can be believed and taken seriously. It also means when you express an opinion it is valid, useful, and is backed up by sound thinking and evidence. It also means that your actions will align with your words. Your sincerity can be questioned if you appear to say one thing to one person and something different to another, or if what you say isn’t consistent over time. The key word here is “appear.”
The purpose of developing a culture of compliance is obvious. What may not be so obvious is that it can discourage the incidence of whistleblowing.
How Can Building a Culture of Compliance Reduce Potential Whistleblowing?
Whistleblowing can be internal (disclosure to someone of higher authority in the organization) or external (disclosure to outside persons or organizations, such as government agencies, public-interest groups, or the news media).
The whistleblower is a person who makes an unauthorized disclosure regarding some action or practice within the organization that the person judges to be ethically wrong or unacceptably dangerous. Whistleblowing is unauthorized disclosure and it almost always involves activity that management considers disloyal to the organization. In addition, organizations and individuals can be harmed, perhaps in an irreparable manner, by public accusations.
Encourage internal reporting from your workforce and respond to these concerns to avoid whistleblowing. When your employees know they can communicate concerns related to unethical or illegal circumstances and realize that that their concerns will be investigated, it reduces the likelihood of external whistleblowing. Institute the phrase “see something, say something;” but you need to back it up by having a swift and effective investigation process.
We encourage you to read Whistleblowing: Don’t Encourage It, Prevent It, published by the International Journal of Health Policy and Management.
Company employee surveys can be a source of detecting problems or they can be a curse. When results are published and your organization ignores problems identified in the survey and only reports on achievements or a “job well done,” the workforce will quickly learn that internal reporting will not be heard. Your workforce will know when negative results of the survey have been eliminated from being published in the survey results. Frame it as an area where the organization needs to improve and thank your workforce for honestly responding to survey questions.
Conclusion
No One Said It Would be Easy - Obtaining a culture of compliance can be a difficult task for even the smallest health care organization. The approach must differ contingent upon the size and buy-in from the top of the organization. Stakeholders, C-suite executives and management must set the example because the top-down approach is necessary to cultivate your workforce.
Healthcare professionals operate in high-stress environments, facing long hours and the emotional demands of patient care. Without a supportive culture, these challenges can lead to burnout and high turnover. Cultivating a positive workplace culture of compliance based on trust is essential for maintaining staff well-being, enhancing teamwork, and improving overall job satisfaction which results in the delivery of quality care.
The job of a compliance officer is difficult, to say the least. Your role is to influence others to care about compliance which requires commitment, caring, consistency and competence on your part. If you need to strengthen certain aspects of yourself, get into leadership training, register for compliance training and certification or take a class in communications. Lead with your strengths and build your weaknesses into attributes.
If you are not passionate about your job and willing to learn to improve, then perhaps it is time to resign. Others will see that you are only going through the motions and you can actually do more harm than good for the organization.
About the Author
Joanne Byron, BS, LPN, CCA, CHA, CHCO, CHBS, CHCM, CIFHA, CMDP, OHCC, ICDCT-CM/PCS serves as the Board Chair of the American Institute of Healthcare Compliance (AIHC) and oversees the Volunteer Education Committee.
AIHC is a licensing/certification partner with CMS and offers online training w/certification in the field of Corporate Compliance, Internal Forensic Auditing on How to Conduct Internal Investigations and Auditing for Compliance for those requiring more than on-the-job training.
