The Society of Corporate Compliance and Ethics and the Health Care Compliance Association, recently published a report: The Relationship between the Board of Directors and the Compliance and Ethics Officer.
This report summarizes the results of a survey of compliance and ethics professionals. Among other things, the professionals were asked to rate the importance of seven compliance officer traits:
- Empathy/Ability to Assess a Situation
- Ability to Influence
Interestingly, the majority of respondents rated all of the traits either a 4 or 5 on a scale of 1 to 5, with 5 being the most important. That's a tall order.
Of all the traits, Independence was rated the most important: 74% of men, and 72% of women, rated Independence a 5; 16% of men, and 21% of women rated Independence a 4. If you add up those numbers, it is clear that the great majority of respondents believe Independence is a very important trait in a compliance officer--and MPA agrees.
We also know that many smaller providers, such as stand-alone nursing homes, appoint someone from within to be the compliance officer, making "Independence" hard to achieve. For example, what if the best candidate for compliance officer is your DON: someone who has every trait on your "DON" wish list. This means the DON is a quality assurance expert, and is probably highly involved in the home's quality assurance program. This also means the DON lacks the independence to do the quality audits in the compliance officer's job description.
What is the solution? Don't throw the compliance officer--in this example the DON--out with the bath water, and settle for a less worthy candidate who is more independent. Instead, assemble a compliance team to support the DON as compliance officer, and provide the independence your program needs. Is there another high-integrity employee who can bring a level of independence to the quality assurance audits?
MPA hopes you get everything on your compliance officer wish list this year. But if the best person for the job is shy of one of these traits, don't despair. You can still put together a compliance leadership team of integrity. Remember: The goal is to maximize compliance with the resources you can identify. The specifics of your compliance effort will need to be customized to your organization, and your talent.