By Jan Elezian, Director at SunHawk Consulting, LLC in Denver, CO, and Gerry Roy, Vice-President, Chief Compliance and Privacy Officer at Phoenix Children’s Hospital in Phoenix, AZ.
In today’s highly regulated healthcare market, a chief compliance officer (CCO) seldom has time to rest. This is clearly the case with a seasoned CCO who has been in place for some time, but even more so for one who is new to an organization. The first few months can be overwhelming—as if someone dumped a puzzle with missing pieces on your desk. This is true whether you are joining an existing compliance program or creating a new one. This article will provide a framework to help you prioritize the first 100 days in your new role.
Step 1: Sorting your pieces with an onboarding road map
Within the construction industry, there is well-known principle: Measure twice and cut once. The same principle can be applied here as it relates to your onboarding as the CCO. Regardless of the state of the compliance program, your very first step should be one of assessment and planning, not action. Take time to create a road map for methodically analyzing the organization and developing and executing a new program. To help capture fleeting thoughts as they pour in, consider focusing on another five primary areas:
Orienting to the organization
Orienting to the compliance program
Conducting an initial risk assessment
Developing resources and tools
Introducing yourself to the organization
Consider these areas the five. . . click for Full Article.
1 “Compliance Guidance,” U.S. Department of Health & Human Services Office of Inspector General (OIG), accessed January 8, 2020, https://bit.ly/2ZWMgL8. 2 OIG Supplemental Compliance Program Guidance for Hospitals, 70 Fed. Reg. 4858 (January 31, 2005) , https://bit.ly/2QToQ5b
3 HCCA-OIG Compliance Effectiveness Roundtable, Measuring Compliance Program Effectiveness: A Resource Guide, March 27, 2017, https://bit.ly/2FskEE9. 4 Department of Justice, Criminal Division, Evaluation of Corporate Compliance Programs (Updated April 2019), http://bit.ly/2Z2Dp8R.
Copyright 2020 Compliance Today Magazine, a publication of the Health Care Compliance Association (HCCA)
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