Why Managing Compliance Risk Is Like Eating Spinach 

The overwhelming pace and complexity of healthcare regulatory change have become so routine that the constant grind now poses a distinct compliance risk to the organization it’s intended to protect. 

Yet, many hospitals still treat regulatory change as a routine monitoring activity, failing to adopt the systems thinking and discipline necessary to truly mitigate the risk.  

This article by a top healthcare compliance expert explains what it takes to make that transformation. (She also explains what spinach has in common with compliance risk assessment.) 

Beyond Spinach: A Systems Thinking View of Regulatory Change  

’Tis the season! Compliance risk assessment season, that is.  

Many healthcare organizations are in the middle of this annual “eat your spinach” preventative exercise, with compliance folks wandering the halls asking executives what keeps them up at night.  

This year, a CFO for one of my hospital clients raised a significant risk that is so ever-present it’s often treated as a constant rather than a risk. The pace and complexity of regulatory change in healthcare are so familiar that they’re easy to overlook as a distinct risk.  

Regulatory Change Complexity as Permanent Risk  

For those who do recognize and record risk, this one almost certainly hits near the top of the scoring index. Regulatory change in healthcare isn’t an occasional disruption. It’s a permanent condition of the operating environment.  

Despite recognizing it as a top risk year after year, many organizations still manage regulatory change as a monitoring activity rather than applying systems thinking. Updates are tracked. Summaries are circulated.  

But when change actually occurs, the organization is left to work out (often manually and inconsistently) what the change means and what to do next.  

Systems Thinking Brings Structure to Reducing Compliance Risk 

From a systems-thinking perspective, this is a structural failure, not an execution problem.  

A persistent, high-scoring risk should not rely on individual effort, institutional memory, or ad hoc judgment calls to be managed effectively. It should be supported by infrastructure that reliably converts inputs into outputs.  

In this case, the input is regulatory change. The needed outputs are: 

• Applicability analysis 
• Operational decisions 
• Documented rationale 
• Accountable follow-through 

Failing to Operationalize Compliance Leaves You Open to Risk 

That’s where many regulatory compliance programs feel the strain. The risk isn’t failing to notice regulatory change. The risk is failing to operationalize it in a consistent, defensible way, especially across multiple departments, leaders, and decision points.  

From Effort-Based Compliance to System-Based Compliance 

Coming out of risk assessment season, this creates an opportunity to ask a more fundamental question: Do we actually have a system for managing regulatory change, or do we just know it’s a problem?  

Seen this way, the value isn’t the technology itself. It’s the shift from effort-based compliance to system-based compliance. And with systems and technology, you can do all this in a way that is repeatable and reviewable.  

In short, “eating your spinach” and doing annual assessments is good discipline. Relying on systems is how you stay healthy the rest of the time.  

About the Author 

As principal for AlloImpact LLC, Lisa Estrada provides Strategic Interim Compliance Leadership to hospitals, health systems, health industry vendors, and other healthcare organizations when a leadership vacancy or transition creates an inflection point—turning the moment into an opportunity to pivot, strengthen, and systematize.  

Whether bridging a CCO gap, stabilizing during mergers or growth, responding to heightened regulatory scrutiny, or modernizing a program that’s outgrown its practices, she helps teams build frameworks and cultures that endure. 

Lisa’s work centers on building systems that make compliance durable. By designing and helping teams implement repeatable, resilient processes that scale and stand under scrutiny, Lisa helps organizations move beyond heroics, so compliance keeps working even when key people change. 

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The post From Manual to Scalable: How to Manage Healthcare Compliance Risk  first appeared on YouCompli.

It amazes us how many healthcare facilities don’t always store records appropriately. Check that. People don’t store records properly.  

Just this week, I was in a colleague’s office. Literally, it looked like Staples puked up aisle 3. I asked her what everything was, because you couldn’t make heads or tails of any of it. She explained that it was patient records that she didn’t know what to do with.  

I asked her, “Well, what does the process say to do?”  

“Process?” she said. Nice girl, means well, greener than a pepper tree.  

After helping her re-organize everything, I was motivated to put together some ideas to help others in her situation. Here are some record retention best practices in the event you have hoarded up some claptrap and now have to figure out what to do with it.  

What Records Do You Have? Archival or Data? 

First step, take an assessment of everything you have. Samples? Materials? Records?  

Archival storage should be for all original records, including source data and metadata, which are generated, recorded, calculated or transcribed at the time of an activity. This data allows full and complete reconstruction and evaluation of the activity.  

Data storage may be written, printed electronically, scanned image, photographic, or other form for later reference. Raw data obtained from measurement, testing, processing, direct observation or computer, and instrument printouts should be represented exactly as captured at its source without transformation, aggregation or calculation.  

Responsible Parties and Retention Periods 

All personnel should be responsible for handling, submitting or returning records to the archive in the same conditions in which they were found.  

Keep in mind that different items are governed by different regulations, so you need to check retention periods. The retention period begins when all work with samples or records is complete. Specified retention periods supersede any other retention requirements unless explicitly noted. 

Factors Influencing Retention Period Requirements 

• State and federal laws: State laws are the primary source for retention periods, which can range from three to over ten years. Federal laws, like those from CMS for Medicare, may also have specific requirements.  
• Patient age: Records for minors often require longer retention periods, usually extending past the age of majority.  
• Type of record: Different types of records can have different retention requirements. For instance, some states require longer retention for certain records like mammography images.  
• Legal and regulatory changes: Laws and regulations can change, so it’s important to stay updated on current requirements. 

Scope of Work in Healthcare Records Retention Process 

Generally, quality or project management takes the lead on records retention. The scope of work involves: 

• Archiving, filing, retaining, organizing and retrieving records 
• Maintaining security and integrity of records in archives if stored on-site 
• Collecting and cataloging records, including: 
• Assigning archival numbers 
• Preparing archive labels, updates to archival forms 
• Making copies of any supporting electronic data  
• Handling off-site storage as applicable.  

On-Site and Off-Site Record Storage Locations 

For healthcare records, you have two storage choices: on-site or off-site.  

If you store records on-site, storage must be access-controlled, and all records must be stored appropriately to ensure integrity and preservation, minimize deterioration and facilitate timely retrieval. All original paper records should be stored in secure, fireproof filing cabinets or appropriate containers, like folders, binders, weather-proof envelopes, cases or boxes. 

If you decide to store records off-site, make sure to use a qualified contractor specializing in off-site medical records storage. Quality should be involved in sending records off-site. All records should be assigned a unique number or other appropriate identifiers which your site must maintain.  

Records should be sent off-site appropriately grouped by record type. This is important because at some point, you might need to retrieve them. And you generally don’t have much notice to retrieve something. It’s generally an immediate need or within 24-48 hours, so if you don’t know where the records are or how they are organized, you won’t be able to produce them as you need to. That’s a problem.  

General Guidelines to Reduce Risk in Records Retention 

Healthcare record retention is governed by federal and state laws, requiring that records be kept for a specific period for patient access, legal protection, and compliance.  

Your organization should operate under the basic requirements for retaining records unless otherwise specified. Use these general guidelines to ensure your processes are set up for retention compliance: 

• Without a specified retention period, a minimum period of 10 years should be used.  
• Once the defined retention period is reached, samples and records may continue to be maintained, returned, transferred to the appropriate owner, or destroyed.  
• Do not destroy anything without appropriate approval from the functional owner.  
• Record destruction must be appropriately documented to denote the end of the life cycle. 

What’s Your Next Step? 

When you have these processes and practices in place, records retention will be a lot more efficient and a lot less stressful.  

Want more ideas for optimizing compliance and quality? You’ll find guidance in these popular articles. 

• Four Ways to Integrate Compliance with Safety/Quality Efforts 
• Best Practices for Better Training in Healthcare Compliance
• Integrate Self-Awareness into Healthcare Compliance Programs: 18 Tips  

Andrea has taught first grade in Willoughby, Ohio for 27 years in the same classroom that she attended school as a child. She earned a Bachelor of Science in elementary education with a minor in language arts from John Carroll University and a Master’s Degree in the Art of Teaching and Education from Marygrove College. 

John builds and fixes quality departments, while currently thriving as the Administrator & Director of Quality, Risk Management and Compliance at River Vista, a behavioral hospital in Columbus, Ohio.

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The Q-Kids – John R Nocero and Andrea L Bordonaro – are experts at everything quality, regulatory, education training and compliance and love sharing their knowledge on YouCompli.

Follow them on LinkedIn – for more quality content or send them a message – they’d love to hear from you.

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The post Hoarders Need Borders: Quality’s Role in Healthcare Record Storage  first appeared on YouCompli.

You Can’t Manage What You Can’t See 

I get into the hospital about 5am every day. I go to intake and get the daily census sheet and report it out to the providers. I walk upstairs and I get my census sheets for all four units. I call in a fourth provider if needed. I review my e-mails.  

But at 7:30 am every day, I round. No exceptions. Weekday. Weekends. Holidays when I am supposed to be off. Doesn’t matter. I round. It has to be done, because I can’t manage what I can’t see.  

You Need to Manage Healthcare Risk 

So many times, compliance administrators and quality leaders sit in their office and manage through e-mail. Say they are too busy. Too many things to do. Yeah, too many meetings. But the truth is, you need to manage risk. 

Risk comes in many forms . Financial. Patient-related. But the biggest unforeseen risk to me is reputational. If you don’t have a reputation for offering the best patient care while keeping people safe and patients receiving benefits from treatment, you won’t be successful. You won’t make money. You won’t care for patients. You need to see it. Firsthand.  

You can’t manage what you can’t see. Here’s how I round.  

What We Look for During Compliance Rounding 

I walk onto the units through the front entrance and immediately talk to the charge nurse.  

• Do you have enough staff?  
• Is everyone listening to you?  
• How is your census?  
• Do you have any events to report?  
• What is the “temperature” of the unit?  

I then walk down the hall and look in everyone’s room. Are the doors locked? Any ligature risks? Any contraband – things like cups, extra linens, things that someone could harm themselves with? You can’t manage what you can’t see. I walk into each room and just look.  

• What is its condition?  
• Are there any screws loose?  
• What does the milieu look like? Is it calm?  
• Are patients interacting with each other?  
• Are they respectful?  

Then up to all the techs. Same questions, plus ones like these: 

• Have patients gotten showers?  
• Are you tired? Do you need to break?  
• What do observations look like? Are they up to date?  

I then walk through the nurse’s station to the sister units and do the same thing. Same questions. Then downstairs to the other two units. Same thing. Same questions.  

You can’t manage what you can’t see. It takes about 45 minutes total, and it’s the most important part of the day. We have cameras, and I could look at the cameras and do this. But so much would be missed. You need to get onto the units. Why? Because you can’t manage what you can’t see.  

Why In-Person Observation Is Valuable Compliance Practice 

There are three main reasons why I do rounding and in-person observation:  

1. Presence: I have to have a presence on the units. Staff need to see me and see me holding them accountable. They know I’m going to come by every day. Same time. They need to be ready. No questions. No excuses. Plus, it shows I care. I do care about every member of the staff. I want them to get used to seeing me on the floor. Pull me aside. Tell me things. That’s important.  
2. Safety: No one should feel unsafe here, so I’m always looking around for contraband or things that patients can use to harm themselves. Cups and linens as I said but there are things that sometimes make it up to the units. Like shoelaces for example. Now, you take it for granted. Loop, swoop, pull and tie your shoes. A self-harming patient can see that as something more. I look at the environment, too. A loose light or a loose screw can be thrown or even swallowed. You need to stay on top of it. If I see something, I tell my Plant Operations Director and put in a work order to have it fixed immediately.  
3. You can’t manage what you can’t see: This is the most important reason and the one I keep bolding. The only way to know what is going on is to be present. Management by walking around is a thing. When I changed a process a couple months ago, the staff was outraged. We can’t do this, that or the other. Then I walked the units. People on phones. Laughing. Looking calm. You ain’t stressed. That changed fast. Funny how that happened.  

Get Real-Time View of What’s Happening in Your Organization 

Only by being present can you get a real-time view of what’s done, what’s stuck and what is slipping through the cracks. Visibility is power. And I finished this round at 7:28. Two minutes to get upstairs, where they’re also expecting me.  

More Resources About Compliance and Risk 

Ready, Set, Go! Identifying Emerging Risks in Your Annual Compliance Workplan 

Before moving on from this year, it’s important to take time and get feedback from business partners to ensure an “outside-in” perspective is included in your 2026 plan. Compliance expert Jenny O’Brien, JD, MCHDS, CHC shares proven practices.  

The Why, What, Who, and When of Healthcare Risk Assessments   

Sharon Parsley, JD, MBA, CHC, CHRC discusses risk assessment from a “why, what who, and when” perspective. She also looks at ways that you, as an effective compliance officer, can lead this process with your colleagues. 

Andrea has taught first grade in Willoughby, Ohio for 27 years in the same classroom that she attended school as a child. She earned a Bachelor of Science in elementary education with a minor in language arts from John Carroll University and a Master’s Degree in the Art of Teaching and Education from Marygrove College. 

John builds and fixes quality departments, while currently thriving as the Administrator & Director of Quality, Risk Management and Compliance at River Vista, a behavioral hospital in Columbus, Ohio.

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The Q-Kids – John R Nocero and Andrea L Bordonaro – are experts at everything quality, regulatory, education training and compliance and love sharing their knowledge on YouCompli.

Follow them on LinkedIn – for more quality content or send them a message – they’d love to hear from you.

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Download our Latest Whitepaper

Sign-up for our Weekly Newsletter

Schedule a quick overview

The post Risk Visibility Isn’t Optional in Healthcare Compliance  first appeared on YouCompli.

In every organization there is a moment where the quality department becomes either the trusted operational partner or the operational roadblock. The difference tween the two comes from how you communicate, assign responsibility and how you follow through. This blog explains how to adopt the OG style for more effective quality programs in healthcare. 

Comparing Two Styles of Quality Performance 

There are two guys – let’s call them Young Buck and OG. The Young Buck is probably 30, limitless energy, the one-man wrecking machine. You know that guy. Full of passion or some other nonsense. All gas and no brakes. Runs through the facility on a crusade to save the world. All alone. Takes on all the tasks but somehow, really accomplishes nothing except annoying everyone else on the team with his constant question of “Need anything?” 

OG is a bit different. Older. Works like he is 30 with the wisdom that comes from being 20 years older. Shaved head, salt-and-pepper beard. Dresses as he wants because he has the street cred and knowledge to back it up, so no one cares. Works as an individual contributor but has a connection to everyone on the leadership team. Can tell you about all their strengths. Kills every audit, understands the entire operation. Has paid his dues, knows who he is and does not chase anyone’s validation except his own. 

Operational Partner or Quality Roadblock? 

The OG knows a thing or two about operational improvements that matter. He goes beyond simple efficiency improvements such as how units are staffed or cost-cutting initiatives like slashing overtime because the team is over hours.  

The OG embraces the philosophy that all aspects of the organization work harmoniously to deliver maximum value to customers, while minimizing waste and variation in processes (Six Sigma, 2025). It’s simple execution like this, isn’t it?  

• The organization develops systems that promote problem-solving at all levels. 
• Best practices are the norm not the exception  
• Cultivate culture where improvement is habitual, not exceptional.  
• Discipline and consistency are staples that override passion and enthusiasm. 

The operational roadblock is not always the guy who says no, at least not in this scenario. What we are describing is far too common. This roadblock doesn’t know what he doesn’t know and is too focused on short-term results (his own) than on long-term gains (the team’s). He’s in favor of acting but instead of evolving his processes thoughtfully, he wants to make significant changes to the way an organization operates. What this does is create bottlenecks, upset the status quo and build employee resistance. 

OG or bottleneck? Take your choice:  

• Long-term investment or short-term expense?  
• Streamlined processes or maximized rework? 
• Improved quality control or weakened inventory management?  

Us, too. The difference is how you communicate, how you assign responsibility and how you follow through. 

Three Ways to Partner like a Pro 

Want to be more like the OG? Here are some tips for more effective quality operations: 

1 – Communication: Be clear. Be direct. Know what you want to say before you actually say it. Think it out and then say it. Don’t be monologuing at people like Carson on The Tonight Show. You don’t need people to necessarily like you. It helps but it helps more if they respect you. The only way to get that is to tell them what needs to be said, say it and then follow up when needed. 

2 – Responsibility: Assign tasks to people for things they can be responsible for and actually succeed in. Read that again. It is selected delegation. Holding people responsible for things that they cannot perform is a recipe for disaster. In cliched terms, hold your people accountable. 

3 – Follow Through: So simple it only takes one sentence. Do what you say you are going to do, how you said you’d do it, when you said, over and over again. Period. That’s it. All you need to do. 

OG Your Way to Effective Quality and Compliance 

You don’t need to “young buck” your way through quality and compliance. The only way to be the OG is to become respected, highly regarded, skilled and authentic in what you do. Your team and organization will thank you. 

Ready to Learn More? 

We’ve got more resources on quality and compliance in healthcare. Have a look at these three selections: 

White Paper: How Compliance Drives Healthcare Quality and Safety 

Effective compliance management directly supports quality care, operational efficiency, and financial stability. Read the white paper for practical ways to leverage compliance as a strategic asset, transforming regulatory obligations into opportunities for excellence in patient care and organizational success. 

Blog: Four Ways to Integrate Compliance with Safety/Quality Efforts 

How can your compliance program answer the OIG’s call and include patient safety and quality in your oversight efforts? This blog explores four practices to integrate safety/quality concerns into compliance practices. 

Blog: Building a Quality Education Program That’s Good Enough 

It’s essential that you build a quality education program that works. Doing that right means covering the basics well, not adding fancy bells and whistles. This blog explains what will lead to training sustainability for you and the organization.   

Download Tip Sheet Below

Andrea has taught first grade in Willoughby, Ohio for 27 years in the same classroom that she attended school as a child. She earned a Bachelor of Science in elementary education with a minor in language arts from John Carroll University and a Master’s Degree in the Art of Teaching and Education from Marygrove College. 

John builds and fixes quality departments, while currently thriving as the Administrator & Director of Quality, Risk Management and Compliance at River Vista, a behavioral hospital in Columbus, Ohio.

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The Q-Kids – John R Nocero and Andrea L Bordonaro – are experts at everything quality, regulatory, education training and compliance and love sharing their knowledge on YouCompli.

Follow them on LinkedIn – for more quality content or send them a message – they’d love to hear from you.

---

Download our Latest Whitepaper

Sign-up for our Weekly Newsletter

Schedule a quick overview

• 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
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• Three Strategies to Align Compliance with Revenue Cycle  by CJ Wolf, MD
• How the Three Lines Model Strengthens Healthcare Compliance by Kenneth Zeko, JD, CHC
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The post Healthcare Quality Leadership: How to Be an Operational Partner, Not a Roadblock first appeared on YouCompli.

This blog goes deep into regulatory intelligence for healthcare, guided by the expert commentary of longtime compliance veteran, Bethanne K. VanderMolen. [See bio at end.] It covers everything from reg intel basics to how the overall process works to AI’s potential contribution. 

Question – What does regulatory intelligence in healthcare mean, and what do expert compliance professionals do? 

Bethanne VanderMolen – Regulatory intelligence is an organized process that keeps healthcare systems in line with the copious regulatory agencies and legislative bodies directing healthcare. The full regulatory change management process supports operational decision making, compliance program updates, risk mitigation, policy maintenance, and strategic planning. 

As Expert Compliance Professionals (ECPs), we gather, analyze and apply information about new and revised regulations, guidelines and enforcement trends to help organizations maintain compliance and guide strategic decisions.  

While we do a lot of systematic monitoring, the work goes beyond that. The regulatory intelligence life cycle isn’t complete unless you turn that information into action.  Know what’s changing, understand the effect on your organization, and respond! 

Q – What do you think is important for clients to know about regulatory intelligence work? What is something most people might not realize? 

BV – Regulatory intelligence is dynamic and requires vigilance when reviewing changes. Google alerts are not a regulatory strategy or risk management program. Yes, we use tools and tech, but real regulatory intelligence takes interpretation. AI cannot do this work. I spend a lot of time reading between the lines to know not just what a rule says, but what it means.  

What people might not realize is that we review a lot of material that never goes anywhere. That’s just as much a part of this job. 

Q – What does a regulatory intelligence expert or ECP do? What kind of background do you need?  

BV – An ECP is part detective, part translator and part strategist. We constantly scan federal and state laws, guidance, enforcement trends and policy, and review and analyze regulatory updates.  

There isn’t a single path to becoming a compliance intelligence professional. A background in healthcare is very helpful, along with certification in healthcare compliance. You must have a strong regulatory background, meaning you have had to personally review, interpret and act on regulatory updates (not simply be subject to such changes). You really need that hands-on involvement in policy monitoring, regulatory change management, procedure updates, etc. 

Q – What skills and strengths are needed to do well in this role? 

BV – A regulatory intelligence professional must be detail-oriented and self-motivated. You must be an analytical thinker with strong reading comprehension. You see the big picture, and you’re tech-friendly. 

About the Regulatory Intelligence Process 

Q – Tell me about the process used to review and extract regulatory requirements.  

BV – These are the steps in our regulatory intelligence process: 

• First, log the item in the tickler file. Then I conduct my “first read” so I know what I’m reviewing and can identify if these are updates, new information, etc. I figure out who issued the reg, their authority, and if the update is proposed, final or advisory. I might also flag some items that may require a deep review. 
• Develop an “Extras sheet” that I can use to develop my screening questions, categories and tasks. This usually involves identifying some key words that will help me build these pieces. I also identify who it affects and check the enforcement dates. 
• Find any other relevant documents. Sometimes you need to locate older versions or comparison documents from the state, various boards or federal government. 
• Second read: Highlight changes and identify items with operational impact. Eliminate unnecessary information. Note items that may be “of interest” to a provider. 
• Develop the customer’s compliance tool using the highlighted changes. This will focus on the updates or new information that they need to know.   
• Review for standardization items. We try very hard to keep every tool’s format and language consistent between the various compliance professionals developing the tools. The group agrees to a set of guidelines that keep style, language, and grammar consistent.  
• Check my work. 
• Create in the YouCompli system using all the above. 
• Submit to validator and revise as necessary. (A validator checks our work and provides support and a sounding board.) 
• Track through tickler. 

Q – What’s the hardest part of regulatory intelligence services as a job? What do you like most? 

BV – There are times when regulatory agencies write conflicting things or make mistakes in their text. Then you must do a lot of research to figure out what is “right.” That’s the hard part. It can also be challenging at times to figure out what is really being communicated and then appropriately simplifying for the customer and making sure you’re not leaving anything on the table. 

I love this job. It’s very flexible. When I’m stuck on something, I can move to a different task or assignment. That helps a ton when you’ve been working on a large reg that requires a lot of review. Knowing you can leave it and sleep on it is a great benefit to the job.  

I also like the people. I can honestly say this is one of the few jobs where people are genuinely pleasant to work with and supportive of one another.  

Benefits and Outcomes 

Q – What do regulatory intelligence services offload from compliance teams?  

BV – I have been a compliance “department of one” with little to no support or resources. The responsibility for managing every regulatory update from every agency affecting our organization was overwhelming.  

What these regulatory intelligence services offload are the tasks of scanning all agencies for updates. You feel like someone is supporting you. What you do with the information is up to you, but not having to search for it or worry that you may have “missed” something is amazing. 

There was nothing worse in my previous lives than feeling like my days and nights had to be spent checking for changes. Or hearing a “rumor” that something was changing that you had no idea about. It was difficult to carry the stress of having to seek out all regulatory updates on my own, and no single association or board provides everything. You don’t want to let down your organization. YouCompli has your back, so you don’t have to have that stress anymore. 

I was never lucky enough to have YouCompli outside of the pandemic in my other roles. YouCompli was generous during Covid and provided their resources for free during that time. It helped me stay afloat when I was working 16-hour days, six to seven days a week. I will always be grateful. 

Evaluating Regulatory Intelligence Services 

Q – What’s important for compliance leaders to know about regulatory intelligence services? 

BV – Our regulatory intelligence services don’t just help you keep up; they put you ahead if you choose to carry the process through the entire compliance life cycle. The life cycle approach allows you to collect crucial information, then target policy changes, take action, and manage organizational risk if you use the information. In the current regulatory environment these services are becoming increasingly essential. 

The services also provide a great way to show compliance program effectiveness. If you’re utilizing YouCompli software and incorporating it into your risk management and compliance reporting processes, you can demonstrate proactive risk mitigation and value. It really helps mature your compliance department and will be valuable in any audit process. 

Good regulatory intelligence will also help operations leaders make good decisions, so it creates a great team dynamic for organizations when they use our regulatory intelligence resources. 

Q – What functionality should a compliance leader look for in a regulatory intelligence partner? 

They should look for more than just access to laws and updates. Compliance leaders should assess how well the service contributes to timely, relevant and actionable compliance decisions. 

Required functionality checkpoints for compliance partner: 

• Jurisdictional coverage 
• Timeliness 
• Context/analysis 
• Customization 
• Integration into workflow 

Q – What should health systems look for when a regulatory intel vendor says they offer these capabilities?  

• Proactive monitoring – Be certain they are monitoring what affects YOU. Also look for source transparency.  
• Impact assessment – Offers tailored results and prioritization for action. 
• Strategic plan – Look for collaboration tools. 
• Expert analysis – Check qualifications. 

Q – How do you feel about AI and regulatory intelligence? Any potential there? 

BV – Absolutely. As with all healthcare, AI is going to be a great partner for compliance. We just need to figure out how to incorporate it in a responsible and human way.  There is nothing that replaces the human experience. AI value really depends on how it is implemented. 

When I look at a reg that affects nursing homes, clinical services or therapy, there’s a personal connection that can’t be duplicated by AI. I know what the operator in the nursing home would want to know, even if it’s not highlighted by AI. I know what surveyors use and how they interpret regulatory language. I have been part of clinical action, training and policies, and understand what the clinicians need to know to do their jobs. 

But AI can provide real-time monitoring and scanning faster than humans. It can process language effectively and summarize key information such as dates, entities, etc. There’s a ton of potential for AI in this space. It’s not entirely trustworthy just yet, but it’s getting there fast! AI is going to be a powerful tool in healthcare compliance, but it needs to be well-validated and always used with human oversight.  

Want to learn more about compliance without chaos? Reach out for a look at our regulatory compliance services and software. 

About Our Expert 

Bethanne VanderMolen is a veteran compliance professional with more than 20 years of experience in the healthcare space, including compliance and regulatory intelligence. Her career path started as a clinician, where she cut her teeth as a Speech Language Pathologist. With commitment and skill, Bethanne rose from Rehab Director to Regional Director, VP of Rehab and Corporate Director of Rehab. 

In these roles, Bethanne found herself conducting surveys and writing policies, which inevitably drew her to the roles of Chief Compliance Officer and Director of Risk Management. Her subject matter expertise and hands-on experience have assisted departments and facilities through federal, state and local regulatory audits and surveys.  

Bethanne’s dedication to staying on top of these regulations and providing real-time updates and actionable guidance is second to none. Armed with extensive experience in developing and maintaining clinical, administrative and regulatory policies, she’s an excellent source of insight and advice about healthcare compliance.  

Bethanne’s expertise and commitment to the industry make her an invaluable resource for leaders navigating the complex world of regulatory compliance. Her advice is rooted in practical experience and a thorough understanding of the regulatory environment that shapes healthcare today. 

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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
• 12 key metrics for compliance officers looking to… by Kenneth Zeko, JD, CHC
• Transforming Compliance to a Department of Yes  by Lisa Herota, RHIA, CHC, CHPS, CCS Compliance & Privacy Officer
• Three Strategies to Align Compliance with Revenue Cycle  by CJ Wolf, MD
• How the Three Lines Model Strengthens Healthcare Compliance by Kenneth Zeko, JD, CHC
• Mitigating Conflicts of Interest that Drive Profit… by Susan Thomas
• Navigating Compliance Responsibility: A Foundation… by Amy Laufmann, MBA
• New Regulation– Now What? Step-by-Step Guide to… by Amy Laufmann, MBA

The post Q&A: Regulatory Intelligence with a Healthcare Compliance Expert  first appeared on YouCompli.

In this blog, experts offer the real scoop on audit readiness in healthcare. Learn the unfiltered truth about compliance audits and what audit etiquette means. Get essential tips on preparing for audits, the role of healthcare compliance auditors, and what to do (and what not do) during an audit.  

What Does Audit Readiness Mean? 

Let’s say a regulator shows up at your door tomorrow. What’s the first thing your team scrambles to find? Is it evidence of task completion? Maybe a list of applicable regs? Updated policies? How about proof of communication to stakeholders? We saw a post this week asking for a current audit preparedness playbook because so many organizations think they’re ready, until they aren’t. 

Raw Truth about Compliance Audits 

Here’s the raw, unfiltered truth; no organization is ever ready for an external auditor or inspector. Ever. If you were, no one would panic when the FDA shows up at the door unannounced, or the state shows up in your lobby. “The state showed up the other day, and I knew why they were coming so I wasn’t unprepared.”  

The truth is you do your best, and you also expect the worst because they’re an auditor or inspector. Duh. It’s what they do.  

It’s like when you hear a funny rattle in your car. You take it to the mechanic. You know he’s gonna find SOMETHING. That’s his job. If you didn’t hear the rattle, you wouldn’t have taken it to him. You’re just hoping it is a minor repair rather than a total overhaul. Same with your audit, your auditor, and the rattle in your compliance practices. 

What to Know About the Healthcare Compliance Auditor 

Auditing is a formal, independent way to investigate regulatory compliance of a system or process within an organization. In accordance with regulations or industry best practices, an auditor assesses the adherence, adequacy and absence of certain processes.  

What a Healthcare Compliance Auditor Does 

• Identifies errors, omissions and irregularities.  
• Investigates the intent of possible wrongdoings. 
• Provides information regarding auditing procedures.  
• Submits reports to investigating authorities. 

Okay, A Compliance Audit Is Scheduled – What to Do? 

Once you know an audit is coming, use these five steps to prepare your organization. 

1. Make sure you can have as many of your team members available for the audit as possible, in case the auditor wants to schedule interviews with them.  
2. Provide a few date options for the auditor to choose from. A regulatory body like CAP, CLIA or FDA does not have to give warning of an audit and can arrive unannounced, but most audits are not unannounced. You have time to prep. Use it.  
3. Ask for an audit agenda as soon as you can. Review it.  
4. Alert the team that an audit will occur. This allows time to prepare any project-specific documents that may not be complete.  
5. About a week out from the audit, do a facility walkthrough to make sure there is nothing out of place. Do it two days out and then the day before. Yes, this much. You have people in your office. They move things.  

Once you have these steps under control, preparation becomes a case of do’s and don’ts. In other words, audit etiquette. 

What Is Audit Etiquette? Best Practices for Compliance Behavior 

Audit etiquette covers all the best practices required to facilitate smooth external audits. These vary slightly based on the health system’s existing compliance processes and experience facilitating them.  

In most cases though, following these techniques for what to do and what to avoid will drive positive, less stressful outcomes.  

What to Do in a Compliance Audit 

• Do listen to an auditor’s question and think before responding.  
• Do answer only the question that is asked. Stop talking.  
• Do ask for clarification if you don’t understand the question.  
• Do answer only those questions relative to your job.  
• Do be honest and pleasant. 
• Do treat the auditor with respect and courtesy at all times.  
• Do dress in business casual attire. 
• Do prepare to talk to the auditor and anticipate questions. 
• Do have quality obtain copies of taped conversations. 
• Do provide well-ordered, clear documents. 
• Do understand your policies and procedures. 
• Do keep computers locked when away. 
• Do close security-controlled doors. 
• Do keep paperwork organized and out of sight when possible. 
• Do escort the auditor at all times while on the premises. 

What Not to Do in a Compliance Audit 

Don’t guess. Say you don’t know or that you need to consult an SOP or defer to someone who is more suitable to answer the question. If you want to consult an SOP, describe the procedure in general terms with the auditor and then walk them through the details. Just saying “I have to consult my SOP” gives the impression that you aren’t trained. 

Here are other things NOT to do in an audit:  

• Don’t try to answer for someone else. 
• Don’t answer for another department or specialty. 
• Don’t offer additional information. Again, stop talking.  
• Don’t elaborate – answer only what is asked. 
• Don’t use hedge words (examples: I think, usually, normally). 
• Don’t guess when asked a question. 
• Don’t sign anything without legal approval.  
• Don’t argue with the auditor or inspection. Clarify anything the auditor misunderstood.  
• Don’t be rude or disrespectful to the auditor. 
• Don’t huddle. 
• Don’t panic. 
• Don’t lie. 

Practice Compliance Audit Etiquette with Confidence 

Regulatory bodies will give a report prior to leaving the audit. Ensure you engage with the necessary teams to give sufficient responses and have a plan for any noted observations. The observations and responses in a report will generally be the first items looked at in the next audit. Make sure you stay on top of these action plans and complete the items you have committed to. 

Also remember that auditors may be experts or novices based on the type and scope of the audit being performed. Do not assume you are the smartest person in the room when communicating with an auditor. Understand that the inherent authority of the auditor is dictated by the interested party they are advising. Their ability to influence a decision (that may have a significant impact on your organization) is the foundation of a desired outcome for you. That’s one reason why we recommend practicing good audit etiquette. 

More Resources about Compliance and Audit Readiness 

• Three Strategies to Align Compliance with Revenue Cycle 
• Audit Expectations and Challenges 
• Healthcare Audit? Stay Ready. Don’t Get Ready. 
• How to Use TPE Plans for Compliance Auditing and Monitoring 

John R. Nocero, Ph.D., and Andrea L. Bordonaro, MAT, blog on LinkedIn as “The Q-Kids,” discussing everything related to clinical research education, inspiration, and professional connection. 

Andrea has taught first grade in Willoughby, Ohio for 27 years in the same classroom that she attended school as a child. She earned a Bachelor of Science in elementary education with a minor in language arts from John Carroll University and a Master’s Degree in the Art of Teaching and Education from Marygrove College. 

John builds and fixes quality departments, while currently thriving as the Administrator & Director of Quality, Risk Management and Compliance at River Vista, a behavioral hospital in Columbus, Ohio.

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The Q-Kids – John R Nocero and Andrea L Bordonaro – are experts at everything quality, regulatory, education training and compliance and love sharing their knowledge on YouCompli.

Follow them on LinkedIn – for more quality content or send them a message – they’d love to hear from you.

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The post Audit Readiness? How about Audit Etiquette?  first appeared on YouCompli.

On a daily basis, compliance officers are asked to find solutions to a variety of operational requirements. For example, consider a regulatory change requiring the organization to adjust an operational process in order to bill for a particular service. In this case, the solution must be compliant and operational-friendly, but who’s responsible for making that happen? 

While supporting operations in finding compliant solutions is part of our role, becoming the de facto fixer of what constitutes “operationally friendly” is beyond our scope. That piece must be owned by operations.  

The challenge then becomes how to get operational leaders to take ownership for resolving their own compliance challenges. 

Five Strategies to Help Operational Leaders Take Responsibility 

These five strategies will help your operational leaders take responsibility for their particular compliance issues, while preserving your role as a trusted advisor. 

#1 Use a “Coach” Mindset, Not a “Gotcha” One 

If you want your leaders to take more ownership of their own compliance challenges, then position yourself as a coach who helps them think through problems and find solutions—not as a person who catches mistakes. 

To pull this off, you need to be intentional about the types of questions you ask. More specifically, you want to ask curiosity-based questions, not judgmental ones. Here are some examples of guiding questions you can ask as you’re helping them find a solution:  

• What challenges are you facing right now? 
• Is there a part of this new regulatory change that feels uncertain to you? 
• What steps do you think you need to take to address this issue? 
• What’s one small step you could take today to move forward? 
• What options or solutions have you considered? 

Know When to Step In and When Not To 

Having a coach mindset also means knowing when to step in—and when not to. For example, your role is to escalate compliance risk when appropriate (e.g. a deadline looks like it’s going to get missed), but it’s not to do the operational work for them (e.g., following up with a subject matter expert for their input).  

If a leader doesn’t take action despite your support, then resist the urge to fix it yourself. Instead, document it and elevate appropriately within your organizational structure to bring about resolution. 

Having a coach mindset encourages operational leaders to own their compliance challenges because when leaders feel heard and supported, they’re more motivated and invested in their work to find a solution. Also, by supporting those closest to the work in addressing issues, it leads to more practical (and often) faster solutions. 

#2 Frame Risk as Operational Risk, Not a Compliance Burden 

In my experience, operational leaders are more likely to engage when compliance is framed in business terms and not compliance jargon. For example, instead of reading or citing regulations, explain the operational impact of the requirement to them. Talk about things like billing delays, lost revenue, patient safety, or reputational damage.  

Additional topics to consider when framing risk as operational risk include: 

• Patient care 
• Staffing 
• Operational costs 
• Budget variances 
• Workflow 

Framing risk as operational and not as a compliance burden helps promote ownership in solving compliance challenges for a couple of reasons. First, this approach speaks their language. When you frame risk in terms that operations understand, they’re more likely to grasp the urgency and relevance of the ask.  

Second, it makes the problem theirs—not yours. If the risk is shown to impact their budget, performance metrics, or reputation, they’re more likely to feel responsible for addressing it.  

Finally, presenting risk in this way increases engagement and accountability. When compliance risks are reframed as disruptions to their performance goals—employees naturally step into problem-solving mode and take accountability.   

 
#3 Stay Curious, Not Critical 

In my experience, the most effective way to approach communications with operational leaders when it comes to compliance is one rooted in a curious mindset, not a judgmental one.  

For example, let’s assume a leader did not follow through on something they said they would do. A judgmental way to respond would be: “You said you would do this, but clearly that meant nothing.” On the other hand, if you said, “Tell me what challenges you’re facing in moving this forward?” that comes across less adversarial, and more likely to produce a collaborative discussion.   

To help compare and contrast the two approaches, consider these additional examples: 

Taking a curiosity-based approach helps support leaders in solving their own compliance challenges because it builds psychological safety by inviting open dialogue and new perspectives. In my experience, operational leaders are more likely to think creatively when they don’t feel scrutinized.  

#4 Make It Easy for Leaders to Act 

Like compliance officers, operational leaders face constant pressure, decision fatigue, and competing priorities—all of which leads to cognitive overload. Relatedly, if the problem-solving process feels overly complex or burdensome, leaders are likely to disengage or defer responsibility.  

To that end, making compliance easier for your leaders doesn’t mean dumbing it down—it means removing friction. (YouCompli Software is designed for this.) 

When you need support, free up mental bandwidth demands by simplifying the work. Clearly communicating expectations or removing unnecessary steps frees up their mental bandwidth. In my experience, when leaders feel less overwhelmed, they are more likely to engage with issues and take initiative.  

So how can you make the work easier for them? Here are some examples that may help: 

• Explain compliance language in terms they can understand. 
• Take the initiative to set up and facilitate root cause analysis discussions. 
• Coordinate and facilitate stakeholder calls to discuss solutions. 
• If they’re feeling stuck, suggest a series of smaller goals to achieve the work. 
• Provide templates, decision trees, checklists, or other tools to make compliance easier. 
• Offer potential solutions (but as pointed out above, don’t take on the work involved.) 

Making the work easier for your operational leaders encourages them to solve their own compliance challenges because it makes the process more approachable and less threatening. That, in turn, increases their willingness to participate and take ownership. When leaders feel less overwhelmed, they are more likely to engage with issues and take initiative.  

#5 Recognize and Reward Ownership 

Finally, another way to foster operational ownership is to call out your leaders (publicly or privately)—in a good way of course—when they take the initiative to solve their own compliance issues.  

For example, let’s assume an audit was conducted in a clinical department related to medical necessity documentation. As part of a corrective action plan, monitoring is needed to ensure the documentation is in the patient’s medical record. If the department director proactively develops a tool for monitoring and vets it with you, then in response, you might say:  

“I really appreciate how you took ownership to proactively develop this tool. That kind of initiative supports us in maintaining a strong culture of compliance in the organization.” 

If leaders only get attention when their problems are escalated to you, they learn to seek approval through dependence. Recognizing effective problem-solving flips the script. It signals that ownership and resolution—not escalation—are what gets rewarded. 

Here are some ways you can recognize and reward your leaders:  

• An unexpected handwritten thank you note directly to the leader, or better yet, the leader’s supervisor  
• One-on-one verbal recognition 
• A note sent from the Chief Compliance Officer (if that’s not you) to the leader 
• Public recognition in a department or team meeting 
• Nomination for a leadership award 
• Feature in a compliance or organizational newsletter 

Recognizing and rewarding great work is helpful for motivating leaders to solve their own compliance challenges. It creates a positive feedback loop where those behaviors become self-reinforcing and then contagious to others on the team. 

Compliance work is complex, and compliance work requires human interaction. That is especially true when it comes to getting your operational leaders to find solutions to their own compliance challenges.  

By following the strategies outlined above, you empower operational leaders to manage their own compliance risks. Just keep in mind that it is a process that takes time, but in the long run, an empowering leadership style will improve buy-in to your program and create a more cohesive culture of compliance.

Download a free PDF Tip Sheet Version of this blog below.

Jay is a compliance professional and consultant in Colorado. He is a healthcare lawyer with significant industry knowledge of the U.S. healthcare market. Over the past 20 years, he has worked for large for-profit and non-profit health systems and small physician-owned entities. In tackling the countless regulatory and operational issues for these diverse organization types, he has developed a deep understanding of the business of healthcare and the regulations governing the industry. 

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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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• 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
• 12 key metrics for compliance officers looking to… by Kenneth Zeko, JD, CHC
• Transforming Compliance to a Department of Yes  by Lisa Herota, RHIA, CHC, CHPS, CCS Compliance & Privacy Officer
• Three Strategies to Align Compliance with Revenue Cycle  by CJ Wolf, MD
• How the Three Lines Model Strengthens Healthcare Compliance by Kenneth Zeko, JD, CHC
• Mitigating Conflicts of Interest that Drive Profit… by Susan Thomas
• Navigating Compliance Responsibility: A Foundation… by Amy Laufmann, MBA
• New Regulation– Now What? Step-by-Step Guide to… by Amy Laufmann, MBA

The post 5 Strategies for Compliance Accountability Across the Organization  first appeared on YouCompli.

Aligning healthcare regulatory compliance with revenue cycle management is critical to mitigating risks and preserving business integrity. This blog explores three effective strategies to foster collaboration between compliance teams and revenue cycle management.  

Some of the most significant compliance risks faced by healthcare organizations today are found in the revenue cycle. The HHS OIG has stated, “One of the best ways to identify fraud and abuse risks is to follow the money.” 

For many healthcare organizations, this means having a good working relationship with the entity’s revenue cycle team.  

The revenue cycle is the process that starts with a patient’s initial appointment and ends with full payment for services. It encompasses all the administrative and clinical functions that contribute to collecting patient service revenue.  For healthcare organizations that provide services to patients, the revenue cycle is the organization’s financial lifeblood. 

3 Ways Compliance Can Stay Connected with RCM 

If compliance has a good working relationship with revenue cycle management, the two functions can enjoy a fruitful outcome.  

Compliance professionals should consider the following three ways to interact with the revenue cycle team. 

1. Regular Collaboration 

We know from OIG guidance documents that, to be effective, the compliance officer should maintain a degree of separation from the entity’s delivery of healthcare items, services, and related operations.  

Even though this means the compliance officer should not be responsible, either directly or indirectly, for the delivery of healthcare items and services or billing, coding, or claim submission, it does not mean the compliance officer should not be well-versed in these functions through regular communication and collaboration. 

Take Advantage of Compliance Committee Connections 

Regularly collaborating with the revenue cycle team will inform compliance professionals of the specific risks and potential compliance red flags the revenue cycle may be facing.  Many organizations ensure this collaboration by having revenue cycle leadership serve on the organization’s compliance committee.  

In fact, the OIG states the compliance committee “…should be comprised of the relevant leaders of both operational and supporting departments, which could include Billing and Coding, Clinical and Medical, Finance, Internal Audit, IT, HIM, Human Resources, Legal, Quality, Risk Management, Sales and Marketing, and other operational managers.”  Most of the departments suggested by the OIG play a role in the revenue cycle. 

In addition to revenue cycle personnel participating in the compliance committee, collaboration between compliance and revenue cycle can occur on a weekly basis through meetings and sharing of revenue cycle data such as denial rates, reports from electronic claims editors, communications from third party payors and any internal coding and billing monitoring the revenue cycle is performing. 

2. Proactive Claims Auditing  

The OIG tells healthcare providers that they “…should take proactive measures to ensure compliance with program rules, including regular reviews to keep billing and coding practices up to date as well as regular internal billing and coding audits.” 

In organizations that submit claims for services, a sizable number of resources should be dedicated to ensuring the claims they are submitting for reimbursement meet all program requirements.  

The revenue cycle team should have monitoring efforts in place for correct coding and billing.  Also, compliance departments should ensure that independent claims audits are also occurring regularly. 

Assisting Revenue with 60-Day Repayment Rule Requirements  

Even if an entity makes innocent billing mistakes, they have an obligation to repay the money to government third-party payers such as Medicare and Medicaid. The Affordable Care Act included a requirement that entities must report and repay overpayments by the later of: “(A) the date which is 60 days after the date on which the overpayment was identified; or (B) the date any corresponding cost report is due, if applicable.”  Sometimes this is referred to as the 60-day repayment rule. 

If a revenue cycle team’s internal monitoring identifies overpayments, it is critical for compliance departments to know the date of discovery, so the organization does not run afoul of the 60-day repayment rule. If the entity does not monitor the repayment requirements, they could be subject to liability under the Federal False Claims Act. 

3. Training and Education Geared to Job Roles 

Coding and billing rules are regularly updated and can change frequently, and it’s often difficult for busy clinicians to stay on top of the changing regulations. Compliance and revenue cycle teams should work together to ensure those involved in revenue cycle functions are educated on the most current rules. 

The OIG recommends targeting training depending on an individual’s role. Thus, those involved in revenue cycle operations need to provide training and education specific to the nuances of the revenue cycle. The training sessions should cover any compliance risks specific to the learners’ roles and responsibilities.  

Depending on the learners’ roles, these may include: 

• Billing 
• Coding 
• Documentation 
• Medical necessity 
• Beneficiary inducements 
• Gifts 
• Interactions with physicians  
• Other sources or recipients of referrals of federal healthcare program business 

Three Ways to Show You Follow the Money

If healthcare organizations are going to address their biggest compliance risks, they must include the revenue cycle. Compliance professionals can lead in addressing revenue cycle risks by: 

• Driving effective collaboration between compliance and revenue cycle teams 
• Verifying that proper auditing and monitoring of claims are occurring  
• Ensuring those involved in revenue cycle receive targeted training based on their specific role.  

Doing these three things helps show your compliance program is indeed “following the money” as suggested by enforcement agencies such as the OIG. 

About Solutions for Compliance Management and Operations 

Need help keeping track of everything going on in regulatory management? When multiple people and departments are involved, the last thing stretched compliance teams need is more manual work.  

YouCompli compliance solutions keep cross-functional engagement organized, verified and on schedule.  

• Identify and assign specific individuals responsible for completing regulatory requirements. 
• Track progress and on-time completion of all regulatory requirements. 
• Verify that regulatory requirements have been acted upon within the organization. 
• Gauge and quantify potential areas of risk related to incomplete regulatory requirement assignments. 

Detailed reports equip compliance teams with oversight information they need to effectively communicate, act on, monitor, and focus organizational compliance efforts. 

Combine YouCompli solutions with the three best practices in this blog to build productive connections with Revenue and other departments.  

More Resources About Revenue Cycle Management and Compliance 

If you’re interested in learning more about the Revenue angle of healthcare compliance, here are a few additional resources: 

White Paper: Exploring the Four Hot Spots Of the Healthcare Revenue Cycle 

Case Study: Getting It Right: Minimizing Self-identified Overpayments & Maximizing Accurate Billing 

Tips and Tactics: Revenue Cycle Management Compliance: Ensuring Financial Health in Healthcare 

CJ Wolf, MD, M.Ed. is a healthcare compliance professional with over 22 years of experience in healthcare economics, revenue cycle, coding, billing, and healthcare compliance. He has worked for Intermountain Healthcare, the University of Texas MD Anderson Cancer Center, the University of Texas System, an international medical device company and a healthcare compliance software start up. Currently, Dr. Wolf teaches and provides private healthcare compliance and coding consulting services as well as training.   

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

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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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The post Three Strategies to Align Compliance with Revenue Cycle  first appeared on YouCompli.

Assertive Communication Skills for Compliance Officers | 8 Steps 

A career in healthcare compliance can be both exciting and overwhelming. You’re tasked with ensuring regulations are followed; risks are managed, and ethical standards are upheld—all while working with clinical and administrative leaders who may have vastly different priorities. 

When it comes to the compliance program, effective communication is essential for building strong relationships, resolving conflicts and gaining buy-in. One of the most valuable interpersonal tools to help you achieve these goals is assertive communication. It allows you to express your thoughts, needs and boundaries in a clear and respectful manner.  

But here’s the challenge—it’s easy to confuse being assertive with being aggressive.  

Understanding the difference between these styles can help you avoid unnecessary conflict and communicate more effectively when it comes to compliance-related needs.  

In this article, I cover: 

• Key differences between the two communication styles 
• How assertive communication benefits the compliance program 
• Strategies to help you master this skillset 

What Is Assertive Communication? 

Assertiveness is a positive form of communication that uses a balanced approach. You express your opinion about something that you want (which is placing value in yourself), while respecting the opinions of the other people involved (which is placing value in others). 

For example, let’s assume your audit plan includes a review of medical necessity documentation for your cardiac rehab program. Let’s further assume the program’s director insists her unit doesn’t need to complete the audit, nor does she have available staff to complete the work.  

Assertive communication might look like you saying:  

“I understand your team is extremely busy right now. However, cardiac rehab billing has been the subject of a number of government settlements lately, and we want to make sure our practices can withstand a government investigation or audit. What if we work together to find the least disruptive approach for your team to complete the work?” 

This response is assertive because it acknowledges the program director’s concerns while communicating a compliance need.  

An assertive approach has several benefits:  

• First, it shows respect for yourself, which can help build confidence and self-esteem as you are expressing your needs in a positive manner.  
• Second, it’s an effective way to resolve conflict because you place equal value on everyone’s opinions.  
• Finally, it strengthens the relationship because you demonstrate respect for others.  

What Is Aggressive Communication? 

Aggressiveness is a negative form of communication. When you communicate aggressively, you offset the above-noted balance by sending a message to others that your opinion has a higher value than their opinion. It tends to be forceful, disrespectful, and often disregards the needs or perspectives of others.  

Let’s circle back to the scenario involving the cardiac rehab audit for a moment. The following might look like aggressive communication when responding back to the program director:  

“This is completely unacceptable. If your team doesn’t care about complying with the regulations, I’ll escalate this to your supervisor and let them know you’re putting the organization at risk.” 

Yikes.  

Such a response is aggressive because it uses blame, sarcasm, threats and an authoritarian tone.  

An aggressive approach can create several risks for the compliance program.  

• While it may produce short-term results, it damages trust and long-term relationships, reducing your chances of buy-in.  
• Taking such an approach demonstrates an intent to shut down dialogue at a time when you need it most for your compliance program activities.  
• It creates an environment where operational leaders feel reluctant to seek your advice. This can result in little messes becoming big ones because leaders are not reaching out to you proactively.  

Key Differences between Aggressive and Assertive Communication 

Generally speaking, assertive communication focuses on standing up for yourself. Aggressive communication focuses on attacking others. To help distinguish the difference, consider the following comparison and ask yourself—which feels more respectful?  

3 Ways Assertive Communication Drives Compliance Success 

Healthcare compliance officers often deal with sensitive topics like billing errors, patient privacy breaches or improper medical record documentation, all of which, by their very nature, can be emotionally charged situations. This makes good communication more important than ever. 

Assertive communication helps when it comes to carrying out sensitive compliance work for three main reasons.  

1. It nurtures your professional relationships.  

Assertive individuals communicate openly (i.e., sharing the good and bad news), which leads to trust and mutual respect while preventing resentment and misunderstandings. Open communication also fosters collaboration, productivity and teamwork. These traits are important when it comes to things like finding a compliant solution to a business proposal or carrying out corrective action plans. 

2. It improves self-confidence and decision-making.  

When individuals advocate for their needs and opinions, they feel more empowered. This confidence leads to better decision-making and problem-solving skills. Assertive communicators are willing to ask questions, clarify expectations, and negotiate effectively. This benefits work such as investigations, internal consulting and auditing.  

3. It encourages respect and professionalism.  

Assertive communication promotes a culture of mutual respect. When you communicate in a way that sets clear expectations and provides constructive feedback, you create an environment where ideas are valued.  

When it comes to things like implementing a new operational process to meet a requirement, or handling a government payer refund, compliance officers must communicate expectations, provide guidance and handle conflicts professionally. These are characteristics of an assertive style that will improve your results. 

Jay is a compliance professional and consultant in Colorado. He is a healthcare lawyer with significant industry knowledge of the U.S. healthcare market. Over the past 20 years, he has worked for large for-profit and non-profit health systems and small physician-owned entities. In tackling the countless regulatory and operational issues for these diverse organization types, he has developed a deep understanding of the business of healthcare and the regulations governing the industry. 

Take Free RL3M Assessment (Regulatory Lifecycle Management Maturity Model)

RL3M Assessment

Download our Latest Whitepaper

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

The post Aggressive vs Assertive Communication: What New Healthcare Compliance Officers Need to Know  first appeared on YouCompli.