The Georgia Scroll
October 1998
Sustainable Compliance: What Will It Take?
Jan C. Heller, Ph.D.
Because the introduction of formal compliance programs in healthcare is a relatively novel phenomenon, we are just beginning to get a realistic sense of what it’s going to take to plan and implement an effective program in our organizations. It is a truly daunting task. But precisely because compliance is so daunting, we may be tempted to turn too quickly to other pressing concerns. Before we do, however, we ought to think ahead about the "next step" in compliance: how to sustain it. After the planning and initial implementation steps are complete, after the consultants are paid and out the door, and after the roll-out hype wears off, how will we sustain our compliance programs?
In short, if we are concerned about what I call "sustainable compliance," we will need to institutionalize compliance in our organizations. This requires that we realize at least two goals: 1) the overall orientation of our compliance program must be explicitly directed toward the creation and maintenance of an ethical organizational culture; and 2) there must be explicit linkage between our compliance program and our organization’s bottom-line. Here’s why these goals are key to sustainable compliance.
First, other industries have taught us that sustainable compliance aspires to more than regulatory minimalism. Rather, it creates and nurtures an ethical organizational culture that rewards ethical conduct and decisions at all levels. This not only reduces the likelihood of being fined for regulatory violations, it leads to greater "buy-in" from employees and, over time, enhances morale, trust and the organization’s reputation among its customers. This leads us to the second goal.
Reducing the chance of wrong-doing, and enhancing morale, trust and the organization’s reputation should have positive financial implications. But conscientious compliance costs money, a lot of money, and thus to be sustainable we must find ways to use compliance to gain greater efficiencies in the way we do business and serve our customers. For example, the auditing processes embedded in compliance will uncover areas where we can improve our internal controls and operations; then, using the communication channels and educational forums created within our compliance programs, we should utilize such findings not only to bring the organization into formal compliance, but also to discuss ways to do our jobs better and more efficiently. In these ways, then, compliance can be organizationally transformational.
Achieving sustainable compliance will not be easy, but it can be done and done well. It requires us to institutionalize our compliance programs and this, in turn, means that we must explicitly link compliance to the creation of an ethical organizational culture and to improving our organization’s bottom-line.
Jan C. Heller, Ph.D. is Director of the Center for Ethics in Health Care at Saint Joseph’s Health System in Atlanta. He regularly consults with health care organizations on ethics and compliance and is currently helping to establish Region 4 of the Health Care Compliance Association.
Last modified: June 22, 2001