CCO: Keep Board Focused on Effectiveness; Scorecard With Metrics Shows Progress

When compliance officers ask board members about their goals for the compliance program, they might hear something like “to keep us out of jail” or “I don’t look good in an orange jumpsuit.”

That’s like fingernails on a chalkboard to Darrell Contreras, chief compliance officer of Millennium Health. “I would say, ‘I’m not sure I have that skill.’” But he uses those remarks to bring board members back around to how he is building an effective compliance program. “Without the commitment from them that they support the compliance program, all the efforts I can do are window dressing because it won’t help us get to effectiveness,” Contreras said. And if their concern really is staying out of prison, no matter how far-fetched, an effective compliance program will help with that too.

Another thing board members often say is, “I don’t want any surprises,” but there’s no avoiding surprises in the compliance world. “That’s an opportunity to say, how do we make sure we are in the best position to respond to those surprises? Have an effective compliance program,” Contreras said. “Flippant statements can be turned around.”

The buy-in of the board and senior leaders can make or break the compliance program. “Without the commitment of the board and leadership, your effectiveness efforts will be frustrating,” Contreras said at the Health Care Compliance Association’s Compliance Institute April 19.[1] “You have to get that commitment. Otherwise you will be walking through the motions.” The board and senior leaders should convey they believe the compliance program is “a value differentiator.” Compliance officers can demonstrate that partly with metrics.[2]

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