The answer to this question may be of interest to compliance officers seeking assistance with their program, or desiring a compliance program effectiveness evaluation. Others may find interest in the answer as a possible pathway in their own career development. For the past 25 years, our firm has produced many nationally recognized expert compliance consultants. To develop individuals to reach this level requires a variety of hands-on experiences, including participation in a number of compliance program effectiveness evaluations under the leadership of experts. This part of development involves learning from observing a variety of programs operating in different settings to see there are many ways to get the job done.
Compliance Consultants Go Beyond the Checklist
Obtaining compliance certifications, having a law degree, and serving as a compliance officer for an organization do not create a compliance expert. Any and all of these experiences may place someone on the right track, but it takes a lot more before a true expert emerges. The real development is applying what has been learned in a classroom to the real world of compliance, which is anything but neat and tidy. Those with only “armchair” experience or checklists on the seven standard elements of a compliance program are not experts; what they find will be of little value to a program. Using a checklist approach provides little help in determining how effectively a program is functioning. Unlike auditing, where there are set measurable standards that result in neatly tied down results, compliance deals in a world of grays set against many conflicting pressures that do not lend themselves to checkboxes. It is a world of making the best decision with available resources and leadership support. Those engaged in observing the practical side of compliance quickly learn why the OIG says that there is no set standard for how a compliance program should be built and operated, provides only general guidance, and leaves the means of developing an effective program for an organization to figure out.
Extensive Experience is Necessary
No matter how many compliance program evaluations in which a consultant participates, while it may not create an expert status, it can provide a lot of experience and knowledge as to “real world” compliance challenges. It can help lay a foundation for the next challenging steps that can only come from applying what one has learned by acting in the role of a compliance officer. This provides the real appreciation as to dealing with difficult decisions involving conflicting issues and demands. In his or her capacity as compliance officer, one has to learn how to sell compliance day in and day out at all levels of the organization to gain the confidence and trust of leadership and staff, which are necessary to be successful. They must learn to deal routinely with “off the wall” regulatory problems, find solutions, make difficult decisions—and be prepared to make mistakes, often against stiff resistance from executive leadership, program managers, legal counsel, and others.
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The combination of both participating as experts in the evaluation of compliance programs and acting in the capacity of a compliance officer is the true pathway to becoming an expert compliance consultant. Our firm also has taken people who have served as compliance officers and trained them on being consultants. This is often a difficult transition. The person’s experience may be limited to one type of organization in a particular sector of health care. This does not mean that the person necessarily has the tools or experience to apply what he or she knows to an entirely different setting and set of high risk areas. Also, each organization has its own culture and way of doing things that extends to how it involves compliance. As a result, what is truly needed is a lot of experience in many different settings in order to bring real value to a client. Our firm therefore follows the same training protocol of involving newly hired consultants to work on compliance evaluation teams and to perform specialized advisory services. After many such engagements, the consultant is ready to take the next step of acting as an interim compliance officer for organizations that have a gap in their compliance programs. This provides additional compliance experience in dealing with real day to day issues and problems.
A key factor in seasoning someone to become a true expert is working on and resolving specific high risk area issues, such as claims processing problems, physician arrangements, and investigating potential violations of laws, regulations, codes of conduct, and policies. The objective is for the consultant to have so much varied experience, that nothing he or she encounters is completely new. After a few years of combination work in evaluating compliance programs, addressing client needs for specialized services, and acting as interim compliance officers, we find the true compliance program expert emerge at the end of the long road.
Talk to a Compliance Consultant Expert
With over decades of experience, compliance consultants at Strategic Management can assist you in improving your organization’s compliance processes. If you’d like assistance with your current compliance program, contact our experts online or call (703) 683-9600.Subscribe to blog