Compliance Training by Pinocchio

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By J. Veronica Xu, Esq., CHC, CHPC, CCEP, Chief Compliance Officer for Saber Healthcare Group headquartered in Cleveland, Ohio

The Story Behind The Story

The story below is inspired by Director Guillermo del Toro’s 2022 movie Pinocchio that I recently watched. I was deeply touched by it. Unlike the traditional animated movies for kids, this version is more profound than a fable. It is, among other things, about our relationship with others and about humanity, kindness, and love that connect us all. The songs, dialogue, and sentiment conveyed by the characters brought tears to my eyes multiple times throughout the movie. My friends say I am sometimes very sentimental. Well, I guess it’s okay because I am a woman.  😛

All joking aside, this heartwarming movie not only reminded me of how precious and valuable life is and has led me to cherish my family, friends, colleagues and team members even more, but also prompted me to re-think my compliance work, messaging, and communication with all of our teams. Compliance is not a cold or abstract word. It is closely related to the residents we serve and the organization we love. Everything we do is centered on the things we care about the most – our profession, our residents, our families, our friends, our teammates, and ourselves. Doing the right thing is not only protecting our residents and our organization, but it also protects our families as well as ourselves.

I hope that you had fun reading the story. Feel free to use it in your compliance efforts. Consider it a late holiday gift.

Truly, Veronica – Your Compliance Partner

Pinocchio and Compliance

He is a beloved figure. Everyone knows him. He is Pinocchio, the immortal wooden boy. To continue exploring the world, he left his hometown and has now come to work in a long-term care facility where the old and the sick are taken care of. The residents remind him of his Papa who created him. Thanks to Pinocchio’s famous (not willingly developed) nose-growing ability which somewhat refrains him from lying, he was assigned to work in the compliance department, because honesty and integrity are two of the key values that the compliance team has always emphasized. As part of his compliance responsibility, Pinocchio reads all the government publications and enforcement actions, including the press releases regarding (i) the indictment of a former LPN for abusing a resident and of a former DON for failing to report the alleged abuse and falsifying records for covering up[i], (ii) the arrest of a South Carolina woman who stole $309,747.90 from an assisted living facility resident[ii], and (iii) the sentencing of a former staff member who pleaded guilty to neglect in the death of a resident[iii].

During a recent training session, Pinocchio shared with the teams, “I was once a boy, innocent, naïve and young. Not knowing much about the world, I did naughty things and I paid a hefty price. The Goddess of Death told me that because I am made of wood, I am immortal and that while I have eternal life, my loved ones do not. You never know how much time you have with them until they are gone. While I can get a second chance, humans may not. Although we all make mistakes and to err is human, there are things that we should never do, such as abusing/neglecting a resident, falsifying documents, and stealing residents’ funds. Life is short and precious. Make every minute of your life count, instead of spending time behind bars. Do the right thing always, even when no one is watching. Do it for our residents, for yourself, for your loved ones, and for all the people that care about you.”

Years passed. Pinocchio is still a wooden boy. One day, he may become a real boy. But regardless of what he is, we can all find something precious and something in common – that is, telling right from wrong, upholding honesty and integrity, and being kind to others.

In our life, we are constantly making all kinds of decisions – big or small (e.g., what to cook for dinner, which shirt to wear, what presents to buy for parents, whether to accept a vendor’s gifts, whether to take a resident’s money, whether to report wrongdoing, etc.). While some decisions may be trivial, others may change our lives forever. Whenever in doubt, please don’t hesitate to contact our compliance team or call the 24/7 compliance hotline (which provides anonymity protection).

Key takeaways:

  • If you have doubts about something, don’t do it. Talk with your compliance team. Any unlawful conduct or unethical behavior will lead to severe consequences.
  • The holidays are a time for celebration and joy, but don’t let your guard down. If you see something that is not right, please promptly report it to your compliance team.
  • Compliance is just one call/email away. We are here to protect, help, support and guide.

Questions to ponder:

  • Have you and your teams completed all the required trainings?
  • Are you and your teams familiar with the abuse reporting requirements and our policies pertaining to resident abuse, neglect, misappropriation, and resident rights?
  • Do your teams know where to seek assistance and whom to contact when they have a question?

[i] Attorney General James Sues Long Island Nursing Home for Repeated Financial Fraud and Resident Neglect (https://ag.ny.gov/press-release/2022/attorney-general-james-sues-long-island-nursing-home-repeated-financial-fraud-and)

[ii] Attorney General Alan Wilson Announces Oconee Co. Woman Arrested For Alleged Fraud And Exploitation Of Assisted Living Patient (https://oig.hhs.gov/fraud/enforcement/attorney-general-alan-wilson-announces-oconee-co-woman-arrested-for-alleged-fraud-and-exploitation-of-assisted-living-patient/#:~:text=Announces%20Oconee%20Co.-,Woman%20Arrested%20For%20Alleged%20Fraud%20And%20Exploitation%20Of%20Assisted%20Living,SCMFCU)%20has%20arrested%20Chanda%20L.)

[iii] Attorney General Phil Weiser announces woman sentenced in death of 86-year-old (https://coag.gov/press-releases/12-9-22/)