Jay Anstine is a compliance professional and consultant in Colorado. He is writing a series of articles on compliance culture for the YouCompli blog. This post looks at the power of staying neutral in the organization to maintain support for your compliance program.
“Commerce with all Nations, alliance with none should be our motto.” – Thomas Jefferson
It’s tempting to get sucked into interdepartmental disagreements and personal drama when you’re investigating reports or navigating regulatory changes. But don’t do it.
Your best course of action is to “do commerce” with everyone but without the attachments or ties that suggest you’re on someone’s side. Remaining neutral helps you build trust that you have the best interests of the organization at heart rather than that you’re playing politics or taking sides. The compliance officer must work with everyone while functioning like a neutral party in the organization.
So what does neutrality look like in the context of a healthcare compliance officer?
Generally speaking, it means being independent and objective in how you approach your work. That is, the way you show up is being nonjudgmental. It also means treating everyone you interact with in the organization with the same level of respect as you perform your duties. So how do you maintain a neutral position within the organization? Below are three approaches that have helped me over the years.
1. Always Approach Your Role as Independent and Objective
If you want to be viewed as a neutral party in the organization, then you must approach your role as being independent and objective, regardless of what you are working on. If you are conducting an investigation, being independent and objective means you are giving all parties involved an equal opportunity to be heard. You’re allowing each side the chance to explain their version of events, free from judgment. In the context of investigations, it also means clearly communicating to all parties involved that no decision will be made about the investigation until all the facts have been gathered.
Being independent and objective also means you are assuming neutral intent with others until your facts establish otherwise. That is true whether you are working on an investigation, an audit, or consulting to a healthcare leader about a proposed business venture. When you take this approach, you are maintaining a neutral position by not judging others or jumping to a conclusion.
2. Engage in Productive Politics, Not Destructive Politics
There are office politics all around us. Hospitals and physicians in conflict, department staff at odds with other one another, and even patients unhappy with their providers. If you want to be viewed as a neutral party in the organization, then you have to avoid playing destructive politics.
Destructive politics are actions and words intended to solely promote oneself.
Productive politics, on the other hand, are actions and words intended to promote the organization, regardless of who personally benefits.
What does productive politics look like for a healthcare compliance officer?
- Investigations: Investigate or audit when it is in the best interest of the organization, and not to make an example of an employee or a department.
- Accountability: If you are holding staff accountable for completing training or following a policy, practice productive politics by holding those discussions confidentially with the employee and his or her supervisor, and not in front of the employee’s co-workers.
- Recognition: If someone has put work into a process improvement, openly and loudly recognize that person rather than taking credit for their work.
It’s appropriate to play politics productively when it helps you stay aligned with the seven elements or deliver a Compliance goal.
3. Avoid “Us vs. Them” Communication
If you want to be viewed as a neutral party in the healthcare organization, avoid an “us vs. them” mentality when communicating with others. While a competitive mindset helps in professional sports (think Yankees vs. Red Sox), in organizational communication, it can damage the organization’s culture of compliance.
Several years ago, I had an issue surface with ensuring physician orders were in place for billing out high dollar imaging procedures.
We discovered through an audit that there were missing physician orders for the services provided. We refunded payments from the claims we were paid on. Then we needed to implement process changes to ensure the documentation was in place. The scheduling department argued it should be the responsibility of the registration staff. You guessed it: the registration staff argued it should be the responsibility of the scheduling staff.
As the compliance officer, my goal is to ensure the organization has processes in place to meet the regulatory requirement. As such, it would not be in my best interest to “pick a side” in this battle. (e.g., “The scheduling department is always trying to get out of taking on more work.”) Instead, my communication had to be independent and objective. I need to understand the concerns of each side without judgment and identify a solution that both departments can accept. In the end, we were able to resolve the disagreement by requiring both sides to play a role. The scheduling department had to implement a verification process before the exam was scheduled, and the registration staff agreed to verify that the process was completed. This provided one last security measure before the patient went back for the exam.
Commerce With All Nations
When it comes to how you approach your work, it will be in your best interest not to play favorites with any particular individual or department. Remember, “Commerce with all Nations, alliance with none should be our motto.” When you maintain a neutral position in the organization, you remove the potential for others to question your independence and objectivity. You are working toward a culture of compliance – where you have commitment throughout all levels of the organization to do the right thing and doing things right. If you want to have a healthy culture of compliance, then you have to reciprocate a commitment in how you treat others—at all levels of the organization.