The secret to effective regulatory change management and provable compliance is a one-two punch of expert human regulatory analysis with simple-to-use workflow software. Every day, this combination helps healthcare compliance teams across the U.S. move from reactive regulatory change to clear, assigned, trackable work. 

This blog looks at what’s behind “punch one” — human-led regulatory analysis. It explores the role of a regulatory analysis team and how they bring value to the compliance management lifecycle.  

What AI Can and Can’t Do Well in Compliance Management 

There’s a misconception that AI can automate a lot of the research involved in regulatory change management. AI looks impressive to people who don’t do the actual work, but what AI often really does is create more work. 

While AI tools can gather data points quickly, they sometimes pass the burden of validation back to your in-house team. Sorting through duplicate links, hallucinated details or overly broad summaries can easily turn a promised time-saver into a tedious cleanup project.  

AI excels at generating large-scale but basic, general responses, but it’s missing the domain expertise required to spot subtle regulatory nuances. The rest of this article explains why expert regulatory analysis remains essential and how human validators and analysts help compliance teams turn complex regulatory updates into clear, trackable work. 

What Regulatory Analysis Teams Do 

How do regulatory analysts add value to compliance management? They handle vital legwork by ensuring: 

• Regulatory sources are monitored for relevant updates. 
• Expert insight looks at what changed. 
• Analysis helps teams understand what needs attention 

Reliability in Regulatory Analysis: Where Human Value Wins and AI Fails  

The main thing a compliance leader should understand about expert regulatory analysis is that it comes down to a reliability issue. Humans alone bring the trustworthiness that’s needed.  

Partner teams like YouCompli take on the regulatory legwork and cut through the noise with actionable analysis that is reviewed and organized. 

Role of Validators in Regulatory Analysis Model 

Organizations don’t always save a lot of time with AI because of the potential need for error checking and rework. On the other hand, a human validator delivers confident time savings, because no one usually has to go back and verify the validator. That can’t be said of AI. 

Solid regulatory change management processes trust the final word of experienced, compliance-centric humans as validators of regulatory requirements. At YouCompli, a team of attorneys doublecheck the work to bake in the reliability factor.  

It comes down to accuracy, and that’s something that can’t be consistently accomplished through AI-driven automation alone. 

Regulatory Analysis Isn’t Typical Part of Daily Healthcare Compliance 

The gist of what a regulatory analysis team does isn’t necessarily something that translates to a healthcare compliance department’s daily workload. That might be why people don’t fully understand the unique value of a seasoned analysis team.  

Tracking regulatory changes also requires specialized infrastructure. Many health systems lack the budget for special software or the dedicated internal teams to monitor regulatory analysis.  

Partner Analysis Team: FTE-Equivalent Dedicated to Your Regulatory Compliance 

That’s where a specialized partner fills the gaps. Many health systems find it makes the most sense to partner with a human analyst team backed by a proven regulatory compliance management software platform. 

What skills and capabilities should a health system compliance leader look for in a partner for regulatory analytics? While most leaders might not think about asking a potential partner how their team handles puzzles, it is actually a good benchmark. In fact, one analyst team manager uses that exact question during the recruiting process, because unraveling regulation updates can be like solving a puzzle. 

Think of validators and an outsourced regulatory analytics team as the equivalent of an FTE dedicated to your compliance practice. The software, the analysts and the validators give you all of the work of at least a single FTE and more. 

One-Two Punch: Human Regulatory Analysis Plus Workflow Software 

No one else does what our unique combination of regulatory analysis and regulatory management software can do. But if you want to research capabilities and have conversations, this blog gives you an overview of what’s possible in regulatory compliance management today. 

We mentioned the one-two punch at the beginning of this article. Here’s an in-depth look at the second part – regulatory change management software. With a simple software framework, YouCompli helps teams manage regulatory compliance without relying on scattered emails and spreadsheets. 

• Clear ownership, due dates, and accountability 
• Progress tracking across departments and requirements 
• Reporting and documentation to support proof of completion 

What’s stalling progress in your compliance program? Let’s set up time to talk about some real solutions.  

About the Author

YouCompli was founded in 2016 by Jerry Shafran, a serial entrepreneur with a background in software, content solutions, information technology, and network solutions.

After selling a business focused on how insurance companies manage compliance, Jerry saw an opportunity to bring that experience into healthcare — where regulatory change creates constant pressure for compliance teams, operators, and leaders.

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The post Beyond the Algorithm:  Why Human Expertise Matters in Regulatory Analysis  first appeared on YouCompli.

This thought leadership update explains why it’s more important than ever to communicate in a common language. The piece brings compliance executives up to speed on the role of language and communication in today’s compliance programs. Fresh insights and tips capture the current views of the original author, Jerry Shafran, a compliance industry veteran and seasoned, effective communicator.  

With Compliance Maturity Come Higher Expectations 

Since I originally wrote this, compliance has become harder. It has matured as a function, and when that happens, other areas of the organization naturally raise their expectations.  

One expected hallmark of a mature business function is a defined, repeatable vocabulary. That way, when compliance professionals and outside departments share a common language, everyone understands each other, reducing friction in workflow and in relationships across the business. 

Communications as Part of Compliance Lifecycle Management Methodology 

The original blog talked about a methodology we refer to as compliance lifecycle management or regulatory life cycle management. Either way, the role of a methodology is to provide common ground, and communication is a big piece of that. When in place and working well, components of compliance methodology lead to better communication. 

Nothing in compliance happens without good communication, and we built our software based on this understanding. The software provides a reliable framework for required communications that healthcare compliance teams need. 

Communications Span Different Health System Groups and Perceptions 

Even if you lack a common methodology for regulations, you still have multiple departments dealing with constant regulatory change. Each department may do things differently — or do nothing at all — if you don’t clearly communicate the steps they must take to comply. 

With a good methodology, everyone understands their responsibility and where it resides in the process. And that’s why language is a key part of compliance methodology. 

Regulatory Compliance Must Tailor Language to the Audience 

Across the facilities and departments within a health system, people bring different expertise and understanding. You’ll need to give each department a clear way to comply with the regulation, and each may need its own approach to arrive at that goal. 

In such a setting, language can either lead to understanding or misunderstanding. As people communicate cross-departmentally or interdepartmentally, a common language is essential for reducing friction, delay and even risk.  

When dealing with so many different areas, compliance executives need different communication styles based on the audience.   

Adjust your style based on: 

• What you’re trying to convey 
• Who you’re trying to convey it to 
• How much time you have to convey it 
• What you want them to do with the information 

These variables affect how you choose to communicate with each audience. 

Example: How to Deliver Communications They Remember 

Imagine you’ve got a group of 100 people in a room looking at a PowerPoint presentation, and the set of slides is filled with bullet after bullet. If all you’re doing is reading those points, you’ll lose that audience very quickly.  

Instead, use a more contextual style where: 

• You share the fact or point you want to convey. 
• Then provide a relevant story your audience can connect to. 

Four Tips to Improve Compliance Communication and Language 

Follow these proven tips for effective communication and productive outcomes. 

1. Know your audience. 

2. Understand how your audience perceives your role. 

3. If you don’t know what their perception is, ask. Never assume. A safe way to ask is, “Tell me how you perceive compliance people?” or “What’s your perception of people you’ve come into contact within this role?”  

That’s a good way to phrase it so people will be more comfortable and honest. If you ask them point-blank “How am I doing,” your audience might be reticent to share their true perceptions. It’s another example of how the language you use impacts communications and relationships. 

Comfort levels and transparency are important. Keep in mind that not everybody is open or transparent, not because they want to be dishonest, but because it’s not always comfortable. 

4. To be a good communicator, you yourself have to be willing to be vulnerable and open about own your flaws and foibles. That gives people you engage with a path to connect to you at a human level, because they have the same problem, but may not be as comfortable talking about it. 

Navigating the AI Frontier: Communication and Culture in a Digital Age 

As with many other facets of work life, artificial intelligence is affecting how we speak, write and interact with each other. With AI agents generating human-like emails, text messages and internal updates, technology is stepping into conversational spaces once reserved for human interaction. 

While these new AI tools offer undeniable efficiency, they also present a unique challenge for healthcare compliance leaders: AI can replicate human syntax, but it cannot replicate organizational culture.  

When technology outpaces our shared compliance language, communication breaks down and creates deep-seated, hard-to-fix issues. 

Hidden Compliance Communication Risk: Dilution of Meaning 

Building a true compliance culture relies on a common organizational language that is best forged through human-to-human connection, whether one-on-one or one-to-many. 

When communication shifts heavily to automated or purely electronic channels, the rules of engagement change, and crucial nonverbal context gets lost: 

• Missing Cues: Digital channels strip away voice inflections, intonations, eye contact and hand gestures. 
• Diluted Intent: Without these physical or tonal guardrails, the true meaning of a message easily gets diluted, leaving room for assumptions and misinterpretations. 

A Real-World Example of Electronic Miscommunication 

Consider a simple administrative example from the field. An employee sending an email requesting extra tickets for an annual company outing typed the entire message in capital letters. They weren’t trying to yell or be aggressive. They simply didn’t understand the digital etiquette that all-caps signifies shouting. 

In a compliance setting, similar subtle gaps in digital literacy or tech-driven communication can inadvertently spark tension, mask urgent risks or alienate teams. 

Four Vulnerabilities Healthcare Compliance Leaders Must Consider 

As AI agents and digital channels become more embedded in your organization’s workflow, a unified compliance shorthand becomes more critical, not less. Without a grounded, human-centric language strategy, the disruption caused by AI will expand exponentially. 

To prevent poor communication practices from taking root, leaders should look closely at four critical vulnerabilities: 

• Fragile Culture: If your team doesn’t have a deeply rooted sense of organizational culture, technology might define it for you. 
• Absence of a Common Baseline: Without a predefined “compliance vocabulary,” automated text and human responses will drift apart, creating disjointed expectations. 
• Inconsistency Across Channels: A language strategy must span consistently across traditional face-to-face updates, standard emails and automated AI touchpoints. 
• Festering Misunderstandings: Because electronic text lacks tone, misunderstandings happen fast. If leaders don’t proactively address and correct these gaps, they quickly become cultural liabilities. 

The Bottom Line: The “language of compliance” isn’t just about the words on a page or a policy block. It’s about how those words are deployed and felt across the organization.  

As technology scales, compliance leaders must intentionally protect the human elements of communication to ensure clarity, trust, and ultimate alignment with regulations. 

Business Benefits of a Common Compliance Language 

Turning Communication Benefits into Data to Prove Compliance Value 

Measuring the intangible benefits of a shared compliance language is exactly what gets leadership and the Board to lean in. They want to see how culture translates into operational efficiency and risk reduction. 

Here’s how healthcare compliance leaders can convert qualitative benefits into concrete, board-ready metrics: 

1. Minimizing Misunderstandings and Boosting Productivity 

The Benefit: All members understand expectations. Time formerly spent correcting errors is now spent productively. 

Instead of trying to measure “understanding,” measure the reduction of friction caused by a lack of it. 

• “Time-to-Resolution” for Compliance Inquiries: Track how long it takes to close out basic compliance questions or internal reports. A shared language means less back-and-forth clarifying what a policy actually means, shortening the cycle. 
• Rework and Error Rates in Documentation: Partner with Quality Assurance or Billing/Coding to track the reduction in documentation errors or rejected claims stemming from “misinterpreted guidelines.” 
• Policy Attestation and Quiz Data: Move beyond completion rates. Track the average score on post-training compliance quizzes. A higher baseline score across departments indicates the language is actually sticking. 

2. Consistency for Staff and Patients 

The Benefit: Consistency throughout the organization enhances the image, cohesiveness, and reliability of the health system. 

Consistency can be measured by looking at how external and internal stakeholders perceive your reliability. 

• Patient Satisfaction Scores (HCAHPS): Look specifically at communication metrics like “Communication with Nurses/Doctors” or “Discharge Information”. When staff uses a unified, compliant language regarding patient rights, privacy and care expectations, it reflects in patient trust. 
• Standardized Scenario Testing: Conduct “mystery shopper” audits or drop-in assessments across different clinics or departments. Or present the same compliance scenario to different teams and measure the variance in how they explain the resolution. Lower variance = higher consistency. 

3. Creating an Operational “Shorthand” 

The Benefit: Provides a sort of language shorthand among the organization’s community of management and staff. 

An effective shorthand speeds up corporate velocity and reduces administrative drag. 

• Onboarding Velocity: Measure the time it takes for new hires (or contract clinical staff) to reach full compliance competency. If a common language exists, onboarding friction decreases, and “time-to-productivity” shortens. 
• Compliance Hotline / Helpdesk Efficiency: Track the volume of inquiries that can be resolved on the first contact (first contact resolution rate). A shared shorthand allows staff to articulate their issues clearly and helpdesk agents to resolve them faster without escalation. 

4. Cultivating a Strong Compliance Culture 

The Benefit: Creates a sense of culture — a major factor in organizational success. 

The OIG explicitly looks for a culture of compliance. You can quantify this shift directly. 

• The “Speak-Up” Metric (Reporting Volumes vs. Anonymity): A healthy compliance culture doesn’t mean zero reports. It means a steady stream of them. Track the ratio of named reports versus anonymous reports. As trust in the common culture grows, anonymous reporting typically drops because staff feel safe using the shared language to flag issues. 
• Annual Culture/Engagement Surveys: Insert two or three targeted pulse questions into the annual employee engagement survey. For example, “I understand what is expected of me regarding compliance,” or “Management uses clear, transparent communication regarding ethical issues.” Track the year-over-year positive shift. 
• Corrective Action Plan (CAP) Adherence: Measure how quickly departments implement CAPs after an infraction. A cohesive culture takes ownership faster, resulting in speedier compliance with corrective actions. 

Board-Room Tip for Presenting Compliance Metrics 

When presenting regulatory compliance metrics like these to the Board, bucket them into two categories:  

• Risk Mitigation such as lower error rates or survey shifts 
• Operational Efficiency such as time saved, faster onboarding  

This shows that compliance isn’t just a cost center; it’s an organizational value engine. 

In closing, the language of compliance should be like the language of anything. It should be supportive, simple to understand, and help whoever is listening to perform the work that the compliance team needs done. 

Would you like to know more about building common language and communication into your regulatory compliance practice? Reach out for a conversation.

The Original Idea Still Holds

When we first wrote about building a common compliance language, the goal was simple: help everyone involved in regulatory change understand the process, their responsibilities, and what successful completion looks like.

That foundation remains relevant. An effective regulatory change process should include:

• Identifying and documenting new regulatory developments
• Assessing their relevance to the organization
• Translating requirements into specific operational actions
• Communicating expectations to the appropriate stakeholders
• Assigning clear owners and deadlines
• Implementing the required changes
• Verifying completion and preserving evidence of the response

The terminology has evolved, and the original Compliance Lifecycle Management worksheet referenced in this article is no longer available. Today, YouCompli describes this broader discipline as Regulatory Operationalization, the process of turning regulatory change into assigned, completed, verified, and defensible action.

The tools may change, especially as AI becomes part of compliance work, but the need for shared language, human judgment, clear accountability, and documented follow-through remains the same.

The post Building a Common Compliance Language in the Age of AI first appeared on YouCompli.

With the release of the CIA changes within the General Compliance Program Guidance (GCPG), the OIG has officially moved the goal posts. This isn’t just a new set of rules for organizations under investigation. 

The May 2026 update to the Corporate Integrity Agreement (CIA) framework signals a definitive shift from passive reporting to active governance. Compliance is no longer an administrative sub-function. It’s now a board-level strategic imperative. 

The OIG’s Modernized CIA: Your New Compliance North Star 

Whether you’re a leader in an acute care organization, or in a non-acute care market like home health, ASCs, labs, or behavioral health, these updates represent your new “North Star.”  

This blog offers a roadmap to navigating the four pillars of this modernized framework. 

• Pillar 1: The Board’s Mandatory Compliance Partner 
• Pillar 2: Catching Every Whisper in the “Any Modality” Net 
• Pillar 3: Technological Accountability and the IT Governance Mandate 
• Pillar 4: The Elevated (and Independent) Compliance Officer 

Pillar 1: The Board’s Mandatory Compliance Partner 

What does the OIG’s mandatory independent board compliance expert requirement mean for healthcare leadership? 

For years, boards could fulfill their oversight duties by simply reviewing a quarterly slide deck. Those days are over. The OIG now requires the appointment of an independent compliance expert with federal healthcare program experience to review program effectiveness and report findings directly to the board. 

An expert is only as effective as the data they have to work with. To be truly “audit-ready,” your organization needs a living, centralized record of every regulatory change and the specific actions taken in response. Without this “evidence engine,” an independent expert will spend hundreds of billable hours just trying to find the paper trail. That could create a massive financial liability for the board. 

Boards are also now mandated to formally respond to the expert’s findings in their annual reports. You can’t “file and forget” an audit anymore. The OIG is looking for a “culture of inquiry” where board members aren’t just receiving information but actively challenging it. 

Pillar 2: Catching Every Whisper in the “Any Modality” Net 

How has the OIG expanded the definition of a healthcare disclosure program beyond the traditional hotline? 

The OIG has finally caught up with how the modern healthcare workplace actually communicates. A “disclosure” is no longer defined by the phone number it was called into. Now it’s defined as any report made through any modality. 

The reality is, in a busy lab or ASC, a compliance concern rarely starts with a formal hotline call. It starts with an email to a supervisor, a quick Teams message between nurses, or an “off-the-cuff” comment in a hallway or breakroom. 

The Roadmap Action: If a billing concern is raised in a Microsoft Teams thread but never makes it into your formal compliance log, you are in violation of the new standards. 

• Modality Audit: You must ensure your intake log captures: 
• Digital Channels: Email, Slack, Microsoft Teams, Zoom chat, and other messaging platforms. 
• Interpersonal Channels: In-person “walk-ins” and verbal reports made to management or HR. 
• The Log Requirement: Every report, regardless of how it is received, must be tracked with its nature, status, and corrective action taken. 

Pillar 3: Technological Accountability and the IT Governance Mandate 

What are the specific OIG reporting requirements for Generative AI and Information Technology in the 2026 CIA framework? 

In perhaps the most significant update to the compliance landscape in decades, the OIG is mandating technological accountability. IT has gone from support service to a governance partner. 

Set a Place for the Mandatory IT Seat at the Table 

The modernized CIA framework requires that the Compliance Committee formally include IT expertise. The OIG recognizes that in a digital-first environment, governance is impossible without an understanding of the underlying infrastructure, data flows, and automated systems. 

The Roadmap Action: Organizations should update their Compliance Committee Charters to include a CTO, CISO, or equivalent technical lead. This individual is responsible for bridging the gap between regulatory mandates and digital execution.

Defining and Inventorying Generative AI as a Requirement 

The OIG has introduced a formal, rigorous definition of Generative AI for reporting purposes. The new definition focuses on foundation models and systems that “generate new content or inferred outputs” used in clinical, billing, or administrative decision-making. 

Your Generative AI Inventory must track: 

1. Life Cycle Use Cases: Identifying where AI is deployed, such as automated utilization reviews, draft patient communications, clinical note summarization, or coding/billing reconciliation. 
2. Deployment Status: Reporting whether a tool is in the “Pilot,” “Pre-deployment,” or “Production” phase. 
3. Data Provenance and Security: Documenting how Protected Health Information (PHI) is shielded from being used as training data for public or foundation models. 

The Risk of “Shadow AI” 

The OIG is particularly focused on “Shadow AI”, meaning automated tools implemented by individual departments without the Compliance Committee’s knowledge. Under the new reporting mandates, a marketing team using an AI bot to answer patient queries or a billing department using a third-party “coding assistant” without formal approval is now a reportable risk. 

By mandating these inventories, the OIG is forcing a shift from “trust” to “verification.” Compliance committees must document their review and approval of any AI tool before it impacts federal healthcare program billing or patient care. This creates a mandatory “accountability trail” that proves the organization is managing AI risks, such as algorithmic bias and “hallucinated” clinical data. 

Pillar 4: The Elevated (and Independent) Compliance Officer 

How is the OIG changing the independence and stature of the Compliance Officer role? 

The OIG is giving the Compliance Officer (CO) role real “teeth.” The new framework explicitly states that the CO must report directly to the CEO and cannot be subordinate to the General Counsel or the CFO. 

This change is about removing conflicts of interest. Legal and Finance have their own mandates, and Compliance must be free to evaluate them both. 

The Roadmap Action: 

• Direct Board Access: The CO must have direct, unfiltered access to the board. 
• Executive Sessions: Mandatory quarterly meetings with the board, including at least one portion in “executive session” without other senior management present. 
• Board Supervision: The board is now responsible for the supervision and performance evaluation of the CO, further decoupling the role from the CEO’s sole influence. 

Conclusion: Your Proactive CIA Readiness Checklist: Four Tactical Steps 

The OIG isn’t about making the job harder. They’re making it more technical and more transparent. To align with these modernized expectations before a regulatory knock at the door, prioritize these four tactical steps: 

1. Appoint an IT Lead to Compliance: Update your charter to include a technical expert who can oversee your AI and data governance. 
2. Conduct an AI Audit: Identify where automated tools are being used. Document what tools are being used, for what purpose, and how the data is being protected. 
3. Centralize Your “Any Modality” Intake: Move away from fragmented email folders. You need a single source of truth that can export a defensible log of every hallway conversation and digital message. 
4. Adopt the Gold Standard Early: Treat these new CIA mandates as a “Pre-Settlement Readiness Review.” Adopting these standards now proves to the OIG that your organization is committed to a culture of integrity, not just the appearance of one. 

Need some help putting together your “evidence engine” and a proactive CIA strategy? YouCompli takes acute and non-acute care organizations from chaos to compliance confidence. Reach out with your questions and challenges. 

Blog Glossary 

• General Compliance Program Guidance (GCPG): The OIG’s definitive framework for healthcare compliance.  
• Active Governance: A model where leadership and the board are directly involved in compliance effectiveness, moving beyond “check-the-box” reporting to formal responses and resource allocation. 
• Corporate Integrity Agreements (CIA): Binding five-year contract between healthcare entity and the HHS Office of Inspector General (OIG), imposed as part of a civil settlement to resolve allegations of fraud or abuse. 
• Shadow AI: The unauthorized or undocumented use of artificial intelligence tools within an organization without the review or approval of the Compliance Committee or IT leadership. 
• Generative AI: A category of technology utilizing foundation models to generate new content or inferred outputs used in clinical, administrative, or billing decision-making. 

Six More Resources 

Four Ways to Engage Leaders in a Culture of Compliance – Building positive, proactive relationships with leaders is crucial to a culture of compliance. Learn four approaches to engage leaders. 

10 Tips for Building a Compliance Culture in Healthcare – The tips explore how you can convince leaders that a strong compliance culture adds value to the organization. 

What to Look for in Regulatory Change Management Software for Healthcare Compliance – A modern regulatory change management (RCM) system does more than just notify you when regulatory changes occur. Learn what’s really possible today and why it matters. 

Your Board Committee Is Only as Effective as You Make It – Ten ways to engage your healthcare compliance board committee. 

How to Use AI for Systems Thinking in Compliance Processes – Artificial intelligence is beginning to reshape the compliance landscape, but the field is still in the early stages of adoption. 

Experts Weigh In: The Oversight Role of a Healthcare Board of Directors – Whether new to the field or a seasoned professional, get ideas on how support your board’s oversight responsibility for the compliance program. 

About the Author 

Jerry Shafran is the founder and CEO of YouCompli with years of experience in the healthcare compliance space.

He is a serial entrepreneur who builds on a solid foundation of information technology and network solutions. Jerry launches, manages and sells software and content solutions that simplify complex work. His innovations help compliance professionals focus on their core priorities.  

AI Handbook for Compliance Pro’s

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The post OIG Compliance North Star: Roadmap to the 2026 Modernized CIA Framework  first appeared on YouCompli.

Regulatory compliance in healthcare is complex and ever-changing. There’s a steady stream of new and updated federal and state regulations that organizations have to stay on top of. Also, from CMS updates to accreditation standards, managing compliance across multiple departments is a significant challenge.   

Enter the Regulatory Lifecycle Management Maturity Model (RL3M): a brand-new framework that helps healthcare organizations assess their readiness to handle regulatory changes.  

The model will help you evaluate where your organization stands in regulatory readiness, and classify you in one of five levels – Initial, Developing, Defined, Managed, or Optimized. It also will offer tips and best practices for meeting regulatory requirements at seven key stages of regulatory lifecycle management:  

• Identifying & Documenting Regulations  
• Assessing Relevance  
• Translating into Business Requirements  
• Communicating to Stakeholders  
• Executing Compliance Activities  
• Monitoring & Validating Activities  
• Demonstrating Compliance  

With the model, organizations will be in a position to reach higher maturity levels – and experience fewer compliance breaches, reduced financial penalties, and greater operational efficiency.  

Take the Self-Assessment below to get started with the RLM Maturity Model.

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Qualified compliance professionals do the heavy lifting for you, simplifying regulatory change management  

The post Why Healthcare Organizations Need an RL3M (RLM Maturity Model) to Stay Compliant  first appeared on YouCompli.

CEO Jerry Shafran has prepared a festive video to help us wrap up the year. We wish you a safe and happy Holidays and New Year! 

Jerry Shafran

Jerry Shafran is the founder and CEO of YouCompli. He is a serial entrepreneur who builds on a solid foundation of information technology and network solutions. Jerry launches, manages, and sells software and content solutions that simplify complex work. His innovations enable professionals to focus on their core business priorities.  

Download our Latest White Paper

Qualified compliance professionals do the heavy lifting for you, simplifying regulatory change management  

Our in-house team works tirelessly to monitor U.S. regulators, carefully read the regulations in their entirety, and translate the information into simple regulatory intelligence you can use. We deliver model procedures and expert tools that can be used to fulfill your business requirements. Everything is validated by a third-party law firm.   

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The post Recapping 2024 and Ringing In 2025  first appeared on YouCompli.

“I solve problems you don’t know you have – in ways you may not always understand.” –Unnamed Compliance Officer, in a recent meeting with me  

In my lengthy career in both insurance and healthcare, I’ve met literally hundreds of compliance professionals. No matter who they are, where they live, how much experience they have, or anything else, they’ve all felt the same way about their role within their organization. It’s summed up beautifully by the above quote.   

Generally speaking, compliance professionals feel undervalued in comparison to others around their organization. They also think their leaders and revenue cycle colleagues don’t really understand what they do. It’s sad but true: in a world where a lot of healthcare professionals think of compliance as the “department of no,” or “where good ideas go to die,” these phrases tend to become self-fulfilling prophecies.  

Of course, anyone who really understands compliance knows these statements couldn’t be further from the truth. So how do we reverse this thinking, and elevate the level of understanding and credit that compliance receives for the invaluable work it does?  

Conventional Thinking About Compliance  

It all starts with understanding the prevailing schools of thought among healthcare executives. Of course, healthcare leaders are fully capable of understanding the value of compliance – they just don’t. This is probably because of two reasons.  

First, leaders often observe that their organizations aren’t penalized by regulators or otherwise in trouble. As a result, they wonder why they need a compliance department – why support a function that doesn’t seem to have much to do? Of course, they fail to realize that it’s exactly because of compliance that their organization doesn’t have those problems!  

Second, healthcare organizations are hard to run successfully due to financial constraints, the recent pandemic, staffing shortages, and more. As a result, executives tend to spend most of their time and energy on disciplines and other “squeaky wheels” that are directly tied to revenue production. Compliance, unfortunately for us, tends to be deprioritized in favor of other pressing business issues.   

Ways to Prove Compliance’s Value  

Compliance pros and departments can prove their value to their colleagues and leaders in a variety of ways. They include:  

• Educating leaders and colleagues about the OIG’s Seven Fundamental Elements of an Effective Compliance Program. These have guided compliance pros for years, but they usually don’t mean much to others around the organization – especially executives. Compliance pros can show how these elements manifest in everyday operations and describe the consequences that could result if organizations neglect them.  
• Aligning more closely with revenue cycle colleagues. In the same way compliance pros educate others around the organization, they especially need to ensure revenue cycle understands the importance of compliance – and the tangible value it creates. Organizations are better off when these two functions work together to create positive compliance cultures.  
• Tie compliance’s work to non-revenue metrics that executives care deeply about – such as time and risk. Show how much time (and money) a compliance team saves the entire staff – and the executive team – because they handle issues and solve problems for them. Also, cite examples of similar organizations that might be having regulatory trouble. Add up the expenses and cycles they incur to resolve those situations and use that data to quantify the downside risk that exists. This also shows the competitive advantage you’re creating for your organization by operating properly from the beginning.  

The most successful compliance professionals find ways to prove the value they create. This is how they receive the mindshare and resources they need to do their work well and continue to deliver value to their organizations.  

An Example of Establishing Value  

Take Lisa Herota and her team at Vail Health in Colorado, for example. In 2019, Vail’s CEO challenged the compliance team to find and implement a solution to manage and ease the administrative burden of regulatory change management. More specifically, he wanted the team to more proactively stay compliant with the many regulatory changes it experienced without adding labor or burning out the staff it already had.   

Since implementing that solution, Lisa and team have seen a massive impact in a short time. The first time she presented reports that demonstrate and quantify her team’s handling of regulatory change to her board, they grasped the significance of what the department does and the impact it has. They credit the compliance team’s success as being a significant driver in the organization’s exponential growth in new service areas. They also are about to launch a board-level Audit and Compliance Committee to oversee and support the work that Lisa and her team do.   

Compliance’s value in a healthcare organization, just like any other operational function, derives from others understanding what it does. Executives and boards usually only hear about compliance when things go bad – which is exactly why they should invest in the proper compliance team and resources in the first place.   

Let’s use the tools of our trade to initiate a different discussion with our colleagues and show them what we really bring to the table. Let’s help them do what we do best: solve problems and mitigate risk.   

Jerry Shafran

Jerry Shafran is the founder and CEO of YouCompli. He is a serial entrepreneur who builds on a solid foundation of information technology and network solutions. Jerry launches, manages, and sells software and content solutions that simplify complex work. His innovations enable professionals to focus on their core business priorities.  

YouCompli can streamline your regulatory change management efforts to give you time back to collaborate with colleagues, connect with front-line staff, and help free you from reading and monitoring regulations. Take a look at our regulatory change management solution today.    

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27 Ungated Resources for Compliance Leaders and Teams 

Compliance professionals sometimes feel undervalued in comparison to other functions in their organization. They think leaders and colleagues don’t really understand what they do.  

These resources will help. Packed with ideas, tips and recommendations, these pieces were written by professionals with many years of compliance experience. 

You can quickly skim for articles that relate to your needs and interests. Bookmark this page as a reference for future questions or projects.

Visit Now

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Schedule a quick overview

The post Reversing Conventional Thinking About Compliance   first appeared on YouCompli.

Emphasize Education for Healthcare Cybersecurity Compliance  

Privacy can make or break an organization. For healthcare systems in particular, it’s essential to lock down data.   

Margaret Scavotto explains the two sides to privacy: the penalty side and the positive side.   

“On the penalty side, we have issues like ransomware, which is rampant,” Scavotto says.   

“In healthcare, we have to conduct a HIPAA security risk analysis as well as invest in cybersecurity so that we don’t lose access to data or have a breach. It’s the cost of doing business.” 

She says investing in cybersecurity is similar to the challenges of quantifying how Compliance reduces fines.   

“Yet the likelihood of getting hit by a ransomware attack is much higher than getting hit with an OIG settlement or fine,” Scavotto says.   

Beyond the penalty side, Scavotto says privacy can be a tool for elevating patient care.   

“It’s a huge opportunity for providers to focus on customer service and patient retention for two reasons,” Scavotto says. “Patients’ expectations of privacy exceed what HIPAA requires. And patients are complaining to the OCR – the Office for Civil Rights, the federal agency that enforces HIPAA – about their privacy rights being violated by providers much more frequently than they were 10 years ago.”   

She says that thinking about HIPAA only as a burdensome regulation is a missed opportunity.   

“HIPAA and privacy regulations are opportunities to focus on dignity in patient care,” Scavotto says. 

“Privacy issues are at the heart of customer service and patient retention. And it’s a meaningful topic for employees because every employee is a patient somewhere. Being part of an organization that elevates the patient privacy element is impactful.”   

Scavotto advises making education around HIPAA and privacy issues pervasive. She shares an example of a compliance officer who was contacted for guidance after a hospital system purchased 1,500 iPads for field staff without securing funds to encrypt the devices.   

While the compliance officer was able to help resolve the issue, the example highlights why compliance professionals must be visible and be at the table when decisions are made. It also underscores the value of liaison programs and operational compliance committees.   

As Ken Zeko notes, operational compliance committee meetings are the perfect venue for asking questions such as, who’s going to buy something new? Who’s looking at new vendors?   

Lisa Herota adds that privacy issues also highlight the need for ongoing education. She believes employees genuinely want to protect patients’ privacy and that the best privacy policies are the ones employees hear about on a regular basis. 

Emphasize Education  

“We engage employees via a Privacy & Compliance Corner in our organization’s weekly Monday Messages newsletter, for example,” Herota says. “And we partner with IT Security to email biweekly tips on keeping the organization safe – from cyberattacks and phishing – and protecting patient information.”  

She says providing tangible privacy tips that employees can implement in their daily workflows is most useful. And she encourages making educational campaigns fun. “Part of our HIPAA educational campaign was awarding Starbucks gift cards to the first employees who called the compliance hotline and correctly shared what the acronym stands for,” she says. “It raised awareness of HIPAA and of our compliance hotline.”  

“Cybersecurity is a never-ending battle in healthcare,” Herota adds. “It only takes one employee to click a link and let bad actors into our system, creating a domino effect of chaos.” 

She shares how her team responded to a cyber issue by creating a simulated phishing email platform as an educational tool. When she presented the platform for approval to executives, it included increasingly punitive sanctions if employees clicked a link, responded to an email, or opened an attachment.   

Executives asked for more aggressive sanctions, including immediate termination. They likened it to not allowing an employee to set a fire in the operating room more than once.   

Herota pushed back, explaining that employees first need education – whether it’s on preventing a fire or avoiding a phishing scam. They compromised on starting with a four-step escalation program.   

“After six months of having this policy in place, nobody has made it past the second ‘failure’ of clicking a link, responding to an email, or opening an attachment,” Herota reports. “It proves my point that education and training are effective.”  

Ken Zeko agrees with Herota’s approach. He advises compliance officers to avoid using “draconian must-terminate language” and to focus, instead, on having conversations. “There are often plausible reasons why an employee commits a compliance infraction,” Zeko says.   

In these situations, Zeko recommends explaining the extraneous circumstances and giving an employee a warning instead of terminating him or her.   

“If you’re able to coach an employee after the infraction, you may make that person your number-one compliance liaison for life,” Zeko says.  

Content for this article was reprinted from a YouCompli white paper published in February of 2023. In “The Opportunity for Compliance to Create Value for Healthcare Organizations,” compliance experts shared ways to earn recognition across your stakeholders as a value creator. 

The Opportunity for Compliance to Create Value for Healthcare Organizations – White Paper Download

Jerry Shafran

Jerry Shafran is the founder and CEO of YouCompli. He is a serial entrepreneur who builds on a solid foundation of information technology and network solutions. Jerry launches, manages, and sells software and content solutions that simplify complex work. His innovations enable professionals to focus on their core business priorities.  

Download our Latest Whitepaper

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• One Compliance Pro’s Regulatory Change Management Process    by Amy Laufmann, MBA
• Five ways to show how healthcare Compliance delivers value by Jerry Shafran
• Revenue Cycle Management Compliance: Ensuring… by Maya Turner, CPMA, CPCO, CFPC, CPC, CPC-I, AAPC
• Three Strategies to Align Compliance with Revenue Cycle  by CJ Wolf, MD
• 12 key metrics for compliance officers looking to… by Kenneth Zeko, JD, CHC
• Mitigating Conflicts of Interest that Drive Profit… by Susan Thomas
• How the Three Lines Model Strengthens Healthcare Compliance by Kenneth Zeko, JD, CHC
• New Regulation– Now What? Step-by-Step Guide to… by Amy Laufmann, MBA
• Transforming Compliance to a Department of Yes  by Lisa Herota, RHIA, CHC, CHPS, CCS Compliance & Privacy Officer
• Navigating Compliance Responsibility: A Foundation… by Amy Laufmann, MBA

The post Ensuring Private Information Stays Private   first appeared on YouCompli.

How to create a strong culture and make a valuable impact

Compliance officers in healthcare organizations are responsible for building or strengthening culture. It’s a daunting task, especially if you lack support from the top or are new to the organization.   

The tips below explore how you can convince leaders that a strong compliance culture adds value to the organization. These best practices can help you establish a healthy compliance culture with effective training and measurement and, in turn, enable your organization to better manage and control risk.  

What is a strong culture of compliance in healthcare? 

A positive compliance culture enables healthcare organizations to effectively manage and control risk. Yet it may not look the same across every healthcare organization. 

It’s partly because compliance officers do different things in different settings, such as a cancer hospital versus a behavioral health organization. Defining culture may be more art than science, yet healthy cultures share several characteristics.  

Positive cultures that help organizations manage and control risk are created when compliance officers embrace metrics, build relationships, emphasize education, and connect their work to better patient care. As Jay Anstine often tells us, a culture of compliance is a commitment throughout all levels of an organization to do the right thing and do things right.   

10 Tips for Healthcare Compliance Leaders   

Prioritizing these activities can empower you to build a healthy compliance culture and help your whole organization more effectively manage and control risk. 

1. Build relationships 

Cultivating solid relationships across the organization is crucial to building a culture of compliance and to helping manage and control risk. It involves building relationships with executives and operational leaders as well as front-line staff. 

“One person doesn’t make or break the culture,” says Donnetta Horseman, chief compliance officer, Moffitt Cancer Center. “The CEO definitely has a huge impact on what the culture is but if you’ve cultivated relationships with leaders across the organization, you can still build a culture even without CEO support.” 

Invest in relationships with leaders by having regular touchpoints, so you’re not just reaching out if there’s an issue. For example, reach out to leaders when you have positive audit results, or ask what challenges they’re facing and how you can help.  

2. Lead with empathy  

Maeve O’Neill, national compliance, Circa Behavioral Healthcare Solutions, emphasizes the importance of leading with empathy. Her approach stems from her belief that people want to be compliant and do the right thing.  

“Assume that employees are doing their best with what they have, and lead with that,” says O’Neill. “If there’s an issue, it’s often because employees have not been given the right information, resources, or skills. Our job in compliance is to give employees the information, resources, skills, and support they need – not to assume they’re bad or lazy.” 

3. Anticipate resistance  

Resistance is to be expected when you change existing processes or policies to build culture. Recognize that the change management process is an ongoing effort; it takes time to get everyone’s buy-in.  

“To overcome resistance, communicate the why behind what you’re doing,” O’Neill advises. “Communicating and doing a lot of listening builds trust. If you’re changing policies or processes, explain why you have a better way to do it. Emphasize the importance of following the OIG’s seven elements and integrating them into daily workflows.”  

4. Know the business side 

To influence and shape culture, it’s critical to understand the organization’s strategic direction and serve as a business partner. Know how the business generates revenue and where risk resides, so you can help operational leaders to do the same. 

“If you want to connect with leadership or anybody in operations, you have to be engaged in their work,” explains Jay Anstine, compliance program director, Western Division, Banner Health. “And that means understanding how the organization makes money and how each department contributes. It’s about getting to know the business side of the environment, not just the compliance side. You need to be able to climb in the head of a business or operational leader and understand things from their perspective as you try to shape culture and find resolutions to issues. Shadowing staff and doing department walk-throughs can help show employees that compliance officers understand operations.” 

5. Engage front-line workers 

Embedding yourself into each operational area is a helpful way to influence front-line employees. Be part of each area’s initial orientation with staff, go to trainings, do mock surveys, and attend team meetings.  

The more visible you are, the more that colleagues see you and trust you as a partner. They’ll appreciate what you bring, and in turn, they’re more likely to bring issues to you.  

Also, rounding can be helpful for engaging front-line employees and for measuring their compliance awareness. 

“You can talk about compliance messaging if there’s a particular point you need to hit on – maybe a reminder to complete staff training or something HIPAA related,” Anstine says. “But spend the time being curious about their operations and getting to know them. Taking this approach is a sign of engagement and helps you connect with employees on a personal level.” 

“You can talk about compliance messaging if there’s a particular point you need to hit on – maybe a reminder to complete staff training or something HIPAA related, but spend the time being curious about their operations and getting to know them. Taking this approach is a sign of engagement and helps you connect with employees on a personal level.” – Jay Anstine, Compliance Program Director, Western Division, Banner Health

6. Emphasize education   

An example of ongoing training is Horseman’s manager-level training for Compliance. Her meetings involve sharing compliance resources and outlining which policies are most relevant to managers in their respective operational area.  

They discuss what it would look like if there’s an investigation involving one of their departments. It’s educational, plus it cultivates relationships and builds awareness of how Compliance partners with operational areas.

7. Establish a liaison program  

Implementing a compliance ambassador program, often called a liaison program, enables Compliance to partner with individuals outside the department to promote compliance organization-wide.    

In an earlier role, Horseman ran a 10-month liaison program, where managers nominated front-line employees. They met monthly with groups of 10-20 employees and talked about compliance topics, provided education, and explained various requirements. When the program concluded, participants were certified compliance champions.  

“They took the information they learned back to their departments, and functioned as liaisons for folks in their areas, if they had questions about compliance or issues to report,” Horseman says.  

It was a meaningful way to both amplify Compliance’s messaging and to identify compliance issues.  

8. Participate in Compliance Week 

Participating in Compliance Week engages the entire organization. Being part of a national event gives credibility to the compliance field, and it’s an opportunity to interact with employees outside of their day-to-day work.  

“We always have an in-person event at our bigger locations. It’s probably the most popular thing we do. We plan lots of activities, play games with prizes, and offer snacks.”  – Donetta Horseman

9. Use the OIG’s seven elements 

Building financial and other metrics – such as revenue reclaimed because of audits – into the culture helps the organization better manage and control risk. Prioritizing metrics is important even if you aren’t demonstrating a hard financial impact. 

O’Neill recommends using the OIG’s seven-elements framework as a checklist, particularly in behavioral health settings.  

“Start by assessing which of the elements you already have,” O’Neill advises. “Most behavioral health organizations find that they have the seven elements in some iteration. If you have all seven elements met – even if it’s minimally, as long as you have something in place for each of them – you have a good foundation for a compliance program. With the seven elements in place, you can build over time to create a strong compliance culture.”  

10. Connect Compliance to patient care 

Emphasizing how culture is interconnected with better patient care helps show Compliance’s impact on managing and controlling risk.  

O’Neill emphasizes with operational colleagues that her job isn’t to make them simply check off boxes on forms; it’s to help them streamline their operations and more effectively control risk.  

“The goal is giving everyone more time to focus on patient care and better serving patients,” O’Neill says. “In the end, it makes the organization more money and more profitable.”  

Manage and Control Risk

Earning recognition as a value creator and establishing a healthy culture can be challenging. Yet as these 10 tips show, you can successfully shape culture to help the larger organization better manage and control risk. 

For in-depth insights on how to establish a culture that helps the organization minimize risk and demonstrates how Compliance adds value, download our white paper.  

Jerry Shafran is the founder and CEO of YouCompli. He is a serial entrepreneur who builds on a solid foundation of information technology and network solutions. Jerry launches, manages, and sells software and content solutions that simplify complex work. His innovations enable professionals to focus on their core business priorities.

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27 Ungated Resources for Compliance Leaders and Teams 

Compliance professionals sometimes feel undervalued in comparison to other functions in their organization. They think leaders and colleagues don’t really understand what they do.  

These resources will help. Packed with ideas, tips and recommendations, these pieces were written by professionals with many years of compliance experience. 

You can quickly skim for articles that relate to your needs and interests. Bookmark this page as a reference for future questions or projects.

Visit Now

---

Download our Latest Whitepaper

Sign-up for our Weekly Newsletter

Schedule a quick overview

The post 10 Tips for Building a Compliance Culture in Healthcare first appeared on YouCompli.

How to use the SBAR Framework

The same tool nurses use to communicate about health emergencies – can help you secure investment in your compliance department.  

Healthcare compliance professionals who want to make a case for investing in a healthcare regulatory change management solution like YouCompli are using the SBAR framework: 

• Concisely explain the situation 
• Give pertinent background details 
• Explain your assessment 
• Make a recommendation  

When you’re competing for resources along with every other department in the organization, it’s critical to make a clear, concise and compelling case for investment in your work. That way people understand what you need and what value it adds to the organization. 

The SBAR framework helps the provider understand what is happening and what the team needs them to do. The framework was developed by Michael Leonard, MD, Physician Leader for Patient Safety, along with colleagues Doug Bonacum and Suzanne Graham at Kaiser Permanente of Colorado. While its primary use is in clinical cases, healthcare professionals across the organization are finding it useful for communicating with clinical leaders.  

Over the past few years, I’ve helped many of our clients demonstrate the value of investing in compliance with an SBAR. Maybe our application of the framework could help you. Here’s a brief summary of our approach: 

1. Situation 

Due to the nature and number of regulatory changes in healthcare, managing regulatory changes creates significant operational, financial, and reputational risks. 

Name your regulators  

Our system is regulated at the federal and state levels. Additionally, we are subject to regulatory guidance from our Medicare Administrative Contractor. 

Briefly describe your manual process  

This creates a scenario where regulations are changing almost continuously. These changes flow into our organization in a completely unstructured manner. 

2. Background  

Our organization is subject to regulation from more than ___ number of regulators.   

One of them, the U.S. Department of Health and Human Services (HHS) Office of the Inspector General (OIG), has mandated that all Providers must establish seven (7) elements of an effective compliance program.   

Currently, we do not have the ability to: 

• Name any of the seven elements your current compliance function is challenged to address. 

Not having a scalable, repeatable regulatory change management process puts us at risk of being unable to correctly perform all but __ number of the required elements. We can have a designated compliance officer and have open lines of communication. 

3. Assessment  

To effectively assess the issue, we need to review two different but equally important concepts. 

1. What is the cost associated with doing this work (properly) today? 

2. What are the risks/costs associated with not doing this work effectively today?  

The cost associated with doing this work (properly) today 

List the steps to complete this work today.  

Insert a worksheet of costs by a specified period, for example, quarterly. In this example we provided the number of regulatory changes the system dealt with in Q1 of 2022.  

Based on this assessment, the quarterly cost of completing the work is _$40,847.25_   

The risks and costs associated with not completing this work are more subjective.  They fall into three different types.  

1. Fines  
   Provide examples of fines that are similar to your organization’s size and scope 

2. Corporate Integrity Agreements 
   CIAs create significant costs and distractions for all parties of the organization involved.  
   For example: 
   Reporting requirements increase significantly  
   Required to hire an Independent Review Organization (IRO)  

3. Reputational 
   A good reputation is hard to build and easy to lose. For hospitals, the way the reputation is perceived by its stakeholders is important because the subject of the service is human health. 
   Within the populations we serve adherence to existing regulatory requirements is a forgone conclusion, we are expected to act with a consciousness of social responsibility.  

Based on the factors above it is my conclusion that our organization must focus on creating a more effective, more efficient means for managing compliance with regulatory changes.  

4. Recommendation  

To address this issue, we need to complete the following:  

Bullet out your recommendations for consulting, employees, and / or software  

Some examples:  

• Institute a standardized regulatory compliance process  
• Gain visibility into enterprise-wide regulatory compliance   
• Ensure that activities being undertaken to comply are what the law requires (accuracy) 
• Track compliance activities with regulations at the departmental level 
• Create the ability to demonstrate what we have done  

Include competitive research for solving your challenges a couple of ways 

Some examples 

• To avoid the need for additional FTEs an evaluation of existing technical solutions was undertaken   
• We engaged resources from various parts of our organization to undertake this assessment  
• There are three major vendors providing solutions in this area   
• Below is a competitive matrix of each companies offering   

Present a solution that is more competitive than the current risks combined with the current costs. 

For example 

Based on our analysis we recommend selecting _______ as our vendor of choice for this project. The major reasons for this choice are: 

Here are some of supporting bullets our clients use 

• YouCompli does the work for us. Their Expert Compliance Professionals read, analyze, and translate new regulations into business requirements. This operationalizes the regulation for us.  
• We can rely on what they send us. Before sending us the requirements, they are all reviewed by legal experts with an excellent reputation in healthcare regulation.
• The system is easy to use and learn.  

The Situation – Background-Assessment-Recommendation approach can help you clearly and precisely make the case for new investment in the compliance function. 

Creating your own SBAR   

The SBAR framework can help you position and sell solutions to your regulatory change management challenge and many other challenges. Our clients find that our one-two punch of regulatory analysis and a workflow tool that manages the implementation of regulatory changes helps them reduce risk in their organization, feel more confident, and partner more effectively with clinical and operational leaders.  The SBAR framework can help you make the case for a tool like YouCompli. 

We would love to help you learn more about how to adapt this tool to your department’s needs. We’re offering an SBAR workshop in early 2023. Please sign up for our updates to be notified when registration opens. 

The post Show the benefits of investing in your healthcare regulatory compliance program first appeared on YouCompli.