The Care & Feeding
of a Compliance
Newbie
Health Care Compliance Association Managed Care Compliance Conference February 1, 2016
Presentation by
Kevin Gillogly
Regulatory Compliance Manager - Marketing Medicare Mandated & Benefits Communications Anthem, Inc.
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About Anthem, Inc.
Anthem is working to transform health care with trusted and caring solutions. Anthem health plan companies deliver quality products and services that give their members access to the care they need.
With over 72 million people served by its affiliated companies, including more than 38 million enrolled in its family of health plans, Anthem is one of the nation’s leading health benefits companies.
Objectives
•For whom is this session intended?
̶ Compliance Newbies
̶ Compliance Managers
̶ Ethics/Compliance Officers
•Identify Newbie Challenges, Explore
Opportunities
•Introduce Inventory Compliance Tools & Survivor Guide
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The Accidental Compliance Newbie
Or how one individual transitioned a 35-year career in … Advertising Copywriting Sales Promotion Marketing Communications Employment Branding Corporate Communications
into the role of a Regulatory Compliance Manager
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De-Myth-ifying Perceptions of Compliance Folks Bossy Know-It-Alls
Mistrustful Picky, Picky, Picky
Above Everyone Else
OCD to the nth Degree Nay Sayers
Relentless Nags
De-Myth-ifying –The Shift Is On
Bunch of Know-It-Alls (Must Be Highly Informed)
Mistrustful (Trusts, but Verifies)
Picky, Picky, Picky (Devil’s in the Details)
Above Everyone (Holds All to the Highest Standards)
OCD to the nth Degree (Honors the Seven Elements)
Nay Sayers (Anchors of Reality)
Lacking Compassion (Emotional Intelligence a Must)
Nervous Nellies (Understands Risks and Human Error)
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Notable and Quotable #1
“A foolish consistency is
the hobgoblin of little
minds.”
Ralph Waldo Emerson – from Self-Reliance
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Compliance – An Essential Business Best Practice Consider the following:
In the USA, $3.8 trillion is spent on health care annually.
Of that, $70-260 billion is lost to fraud, waste and abuse
(FWA).
Health plans, particularly those administrating federal
and state programs, have an increasing role in the prevention of FWA and the recovery of dollars lost.
Recent high court rulings are demanding accountability
The ROI of Compliance Programs
Cost of Non-Compliance in Data Privacy Protection*
• 2.65 x what compliance costs, or in other words …
• Average cost with compliance: $3.5 million
• Average cost without compliance: $9.4 million
Penalties/fines Business disruptions Lost productivity
Legal and non‐legal settlement fees
* Ponemon Institute LLC Study, January 2011.
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The $1,215,780 Photocopier
• CBS News buys a copier
previously leased by non-profit NY Affinity Health Plan. Discovers PHI on hard drive. Notifies Plan.
• Affinity files breach report
with HHS.
• August 14, 2013, HHS and
Affinity settle violation for $1.2+ million fine.
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Real World of Rock & Roll Compliance Article 126 Rider Clause
No Brown M&Ms!
Absurd and finicky demand of an ego-driven rock star?or
-Brilliant strategy to assure promoters adhere to strict safety precautions for Van Halen concerts?
Even Our Favorite Games Rely on Compliance
• The Current USGA Rules
of Golf has 208 pages of
general and detailed situational rules.
• Professionals can lose
strokes, holes, matches, titles and $$$$ for the slightest infractions.
• Even weekend duffers are
expected to abide by the same rules.
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Notable and Quotable #2
“Do the best you can until
you know better.
Then when you know
better, do better.”
Maya Angelou
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Top 10 Challenges to the Compliance Newbie 1. Information Overload
2. Steep Learning Curves 3. Managing Time, Tasks and Temperaments 4. Unrealistic Expectations (self-imposed or otherwise) 5. Adapting to Compliance Culture and Team Norms
6. Multi-generational Workplace; Virtual Teams 7. Multiple Roles and Responsibilities
8. Disruptions/Distractions 9. Rapidly Changing Technology, Social Media 10. Stress/Burnout
Survey Sez Question #1
Think back to the time when you
were a compliance Newbie.
What did you wish you knew
then that you know today?
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Why Successful Onboarding is Critical to The Care & Feeding of the Compliance Newbie Onboarding can help mitigate many of the “Top Ten Challenges”
Cost of recruitment, training and turnover is considerable. In general, to 30% of new employees don’t make it past their first year.
Studies have shown 70% of successful onboarding programs increases retention by at least three years.
Effective onboarding can significantly shorten the time your Newbie reaches that break-even point in his/her value to the organization.
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Notable and Quotable #3
“People don’t care how
much you know until they
know how much you care.”
The 90-Day Compliance Wonder
Successful Onboarding Should be a Collaborative Plan that: Manages Expectations
Promotes Sustainable Growth Builds Trust and Credibility
Leveraging Potential, Building Competencies Assess Strengths, Weaknesses, Opportunities, Threats (SWOT) Prioritize Goals, Steps, Resources – Objective: Series of quick wins Establish a Mentoring Programs – Formal or informal
Identify Key Stakeholders and Ensure Your Newbie Gets to Know Them Model the Culture of Compliance and Shared Values of the Organization
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Survey Sez Question #2
In terms of “onboarding,” in
your own time as a Newbie,
what were the more useful
resources that promoted your
“compliance acumen”?
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Keys to Managing Information Overload
1. Portion Control – “Bite size” makes for easier ingestion 2. Understand adult learning styles
3. Emphasize the value of “teaching back”
4. Understanding the “Curse of Knowledge*” dynamics 5. Simplify Newbie learning to these three questions:
What? So What? Now What?
* Coined by Chip and Dan Heath in their book Made to Stickto mean the
Notable and Quotable #4
“If you cannot explain it
simply, you don’t
understand it well enough.”
Albert Einstein
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Team
Compliance-Why We Rock and How We Roll Traits of High-Performance Compliance Teams
Purpose and belief in their value to the organization Mutually support team members, especially Newbies Regard knowledge sharing as mission critical Know how to leverage diversity and behavioral styles Possess significant degree of Emotion Intelligence (EQ) Earn the trust of team members and those they serve 23
Remember, Compliance Folks are Human Too Challenges that come with the job (think risks)
Perfectionism – There is a dark side
Indispensable? Ideally. Irreplaceable? Hardly.
Managing conflicts with stakeholders
Losing one’s sense of humor
Survey Question #3
As a Compliance Newbie,
what were some of your more
significant challenges and
how did you manage to
overcome them?
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The Compliance Newbie’s Survival Kit 1. Starts with 7 Elements of an Effective Compliance Program per Federal Sentencing Guidelines for clues 2. Requires both analytic and holistic capacities
3. Innate Curiosity – Essential for stimulating learning and development and promoting Emotional Intelligence 4. Solid written and verbal communication skills – And the ability to transfer that knowledge to others
5. Chaos is no friend to Compliance. Organizational skills (e.g., checklists, filing systems, etc.) are keenly employed
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The Compliance Newbie’s Survival Kit, Cont’d. 6. Auditing & Monitoring skills are critical; knowing how data “tells the story” is key to communicating results 7. Be brave enough to “betray your ignorance” rather than to feign understanding. Remember, you are human, too 8. Leverage your “Pre-Compliance” role(s) for skills, aptitudes, interests and competencies that served you well 9. Compile your own Compliance Glossary/Acronym Log 10. Honesty and Trust aren’t just good for compliance. They’re good for business.
Notable Quotable #5 & #6
“Honesty is a very expensive gift. Do not
expect it from cheap people.”
Warren Buffet
“The most valuable business
commodity is trust.”
Richard Branson
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Summary and Parting Thoughts
Growing a Career in Ethics & Compliance Requires
Patience and persistence Curiosity and communication skills Understanding the nature of behavior and “human error” Complement of analytic and holistic aptitudes Ongoing education and certification opportunities Taking advantage of the immense resources available 29
Keep the Conversation Going
