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Post By: Adam Turteltaub
“How should my compliance program be designed?”
It’s a question many are now asking in the wake of the pandemic, and it’s a question Donna Abbondandolo, Chief Compliance Officer of Bon Secours Mercy Health asked even before it.
In her case the compliance team was divided functionally. One team was focused on revenue cycle. The other for general compliance.
While that likely made sense at one point, it no longer did, and, adding to the need for a change was the fact that compliance was moving out from enterprise risk management and was about to report to the CEO and the audit & compliance committee of the board.
Bottom line: it was time for something new.
When setting goals for redesigning your program she recommends first understand the strategy of your organization, where it is going and how you can align compliance best to support the strategy.
Also, be sure to have a good handle on the risk profile. What are the high-risk areas? How do you identify what is high risk? How do you support leadership in managing risks? The latter can be a very difficult question in a geographically- dispersed organizations.
Even with these considerations in mind and the best intentions, she warns that there will be bumps along the way. That’s when it’s important to have already cultivated relationships with operational leaders to help smooth things over, dispel the notion that compliance is a roadblock, and build trust.
In terms of structure, she took a functional approach to the redesigned program as a way to address compliance concerns both by function and across the enterprise. She developed key leads for various areas to help support the operating units.
Within the compliance team, she met with staff, took the time to understand their skillsets and then leveraged their strengths to help create a strong, functional model. She also worked with HR to leverage the organization redesign principles they had, including developing a purpose statement for the compliance team.
Listen in to benefit from her experience. It could help you when it’s time to redesign your compliance program, or just to kick the tires a bit on your current one.