When it rains, we don’t walk around saying “Oh, no! I’m so worried I might get struck by lightning. I better stay inside all day and change my whole day around.”
Nobody says that. When it rains, I DO hear people saying “It’s raining – this is so good for my garden.” Or the grass or the flowers. Or the basil plants.
Why? Because the odds of getting struck by lightning are LOW. The odds of the rain nurturing plants, however, is HIGH. It’s pretty much guaranteed.
Why, then, when we talk about compliance with leadership and the board room, do we tend to focus so much on penalties?
Yes, penalties are a very important reality and leadership does need to know about them. This is especially important for board members, who have a fiduciary duty to ensure an organization’s compliance program is functioning properly, so as to avoid penalties from the DOJ and the OIG.
But the truth remains that the likelihood of receiving a penalty is relatively low (this of course assumes that your organization is diligently operating a compliance program and trying to do the right thing. I think it’s safe to say that if you are reading this blog, you likely fall into that category). So perhaps the focus of our compliance messaging should be less on lightning, and more on helping the flowers grow?
How has your compliance program helped your organization this year?
Odds are, your compliance program bears good news.
Did your hotline encourage employees to report potential false claims internally, so they could be self-reported? Did this hotline call possibly avoid a whistleblower situation?
Did routine compliance audits find a documentation issue – so you could correct it before it became a widespread problem?
Maybe the compliance department collaborated with the HIPAA Security Officer to run a ransomware and phishing campaign, educating employees about potentially hazardous emails and links. As a result, the Compliance Officer and Security Officer received dozens of calls from employees reporting suspicious emails and links that potentially contained ransomware or malware. Can you put a price tag on potentially avoiding a costly ransomware attack?
Did your quality assurance program reduce adverse events? Lower the amount of pressure ulcers? Improve patient care? Did that lead to an increase in census? Higher patient satisfaction? Positive perception in the community?
Perhaps your annual employee compliance survey shows a more supportive workplace due to a recent compliance education effort, and that employee turnover has also decreased.
What else did compliance do? Did compliance boost the bottom line? Make it easier for employees to do their jobs? What processes did compliance improve? How did the compliance department contribute to your organization’s culture? Make your company a better place to work? A better place to receive care?
Once you have taken a moment to tally up everything your compliance program has done for your organization this year, ask a second question:
Who did you tell?
Did you tell your managers, so they can see how the compliance department is working for them?
Did you share the good news with your staff?
I repeatedly hear from compliance officers who have trouble getting money in the budget for compliance. So I ask them: What has compliance done for you lately? A lot, I bet. Who have you told? Did you share the good news with your senior leadership and board? (Or the president, or CEO, or whomever else is at the helm of your organization?) They are in charge of the budget. Do they know that investments in compliance have yielded greater advances in quality care, patient satisfaction, employee satisfaction, billing accuracy, occupancy, and more.
Because if you don’t tell anyone, no one will know how powerful your compliance effort really is. Spend more time on the good news, and less time talking about lightning.