Making Compliance a Seamless Part of an Organization

Ann Chaglassian, CCO & Regulatory Counsel, Athena Health
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Ann Chaglassian, CCO & Regulatory Counsel, Athena Health

Ann Chaglassian, CCO & Regulatory Counsel, Athena Health

Coordination and Collaboration among Functional Departments

Creating a critical link between the compliance department and business partners at all levels of our organization is an integral component of maintaining an effective and vibrant compliance program. Our compliance team is intentionally closely tied into the operation of the business so we can adequately assess and advise our colleagues about compliance risks that need to be addressed.  Employees in our organization identify compliance as a standard part of the business rather than an obstacle or barrier to their work.  They understand that everyone has a responsibility to contribute to the compliance program to ensure that our company adheres to all applicable laws and regulations, so we can continue to be the most trusted business partner to our clients. In addition to encouraging compliance reporting for day-to-day compliance issues, our team administers regular training for new hires and annual online refresher training to maintain compliance awareness throughout the organization.

Sophisticated compliance programs that administer regular training demonstrate a company’s commitment to employing professionals that understand and appreciate the dynamics of healthcare delivery in diverse and highly regulated healthcare environments.

We are also focused on coordinating and collaborating with functional departments throughout the company to create business processes that fulfill the multitude of compliance requirements we are subject to in the healthcare industry.  Rather than creating disparate responses to individual inquiries, we focus on maintaining a coordinated and holistic strategy in how we embed compliance throughout our company.

This includes processes such as evaluating overall enterprise risks by identifying systemically reported issues to Compliance, integrating job specific compliance content into role-based training, and recognizing that the compliance program needs to constantly evolve to meet the changing needs of the business. Our co-sourcing model defines our client relationships, but is also a model of communication we strive for internally. As a team, our success is dependent on the engagement of all employees. Accordingly, we welcome and encourage open dialogue regarding not only escalated issues, but also client trends, ideas for functionality innovation, and any questions employees may have.

Creating a strong connection with the employee base can be difficult if employees are fearful of retaliation for reporting issues to Compliance. Compliance Officers need the support of upper level management to convey the message that retaliation for reporting issues will not be tolerated and assure employees that issue reporting is both encouraged and necessary to protect the business interests of the organization. This strong support system is fundamental to making compliance a seamless part of any organization and one that is valued and trusted by all employees.

Advice to Fellow Compliance Officers

A good Compliance Officer has the difficult task of aligning an organization’s compliance program with the business of the company which may sometimes result in conflicts. Compliance Officers should strive to become deeply embedded with the business and ensure that effective connections are created and maintained with fellow employees. The key to being effective in this role is to have both visibility throughout the organization and buy-in from employees that your role is a necessary component of helping the company function as it should.

Compliance Officers must regularly coordinate with departments and divisions throughout an organization. This work requires ongoing cooperation and coordination with Operations, Human Resources, Finance, Investor Relations, Technology and other groups within a company.

Maintaining a deep-seeded understanding of how the business functions and creating meaningful connections with fellow employees allows a Compliance Officer to have more insight into the wide breadth of compliance risks.  The more compliance is baked into the culture of the organization, the easier it is to protect against threats created by potentially problematic business initiatives.

For organizations that have multiple geographic locations, Compliance Officers should make regular visits to different sites to ensure that employees have both familiarity and comfort with the Compliance department.  This will ultimately make them more inclined to reach out when they have any regulatory questions or concerns that may impact the organization.

“The more compliance is baked into the culture of the organization, the easier it is to protect against threats created by potentially problematic business initiatives”

Understanding and appreciating the ever changing regulatory environment must also be taken into account in order to be successful in the role.  Having the flexibility to adapt the company’s business needs to these changes requires a fundamental understanding of how to integrate regulatory requirements within the culture of the business environment at each organization. 

Overseeing compliance given both the number and variety of regulations can be a daunting task.  Compliance Officers should use all of the tools they have at their disposal to effectively manage their programs, including enlisting the assistance ofgroups such as Audit, Legal, Human Resources, Operations and other departments as necessary.

Compliance Officers are also increasingly being asked to provide evidence of the return on compliance investments to their organizations, to prove that they are reducing risks and affecting outcomes that provide tangible benefits.  There are creative ways Compliance Officers can provide this data by using case examples of situations that have the potential to impact the organization in a negative manner but for risk mitigation controls and processes that are adding value to the business by reducing risk and liability. The support of the Board is especially important in these situations to highlight both the value and necessity of compliance efforts from the highest levels of an organization’s management structure. An effective Compliance Officer should have a direct relationship with the Board and report regularly on compliance matters to apprise them of the risks to the organization.  This in turn allows for appropriate attention to be focused on high level compliance risks and allows for expedited resolutions that are supported and addressed by both the Board and upper level management on a consistent basis.

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