I was recently listening to a webinar when someone asked a question that I often ask: “how do I get business executives to care as much about compliance as I do?” I expected the answer to be the same one I have heard a hundred times, “you have to make them understand the risks… you have to make sure they understand the potential for personal liability.. you have to explain the government’s expectations… etc.” The answer the speaker gave was more insightful; she said, “you can’t”. She went on to explain that if you, as the compliance officer, are not the individual in your company who cares most about compliance, who is the most excited about your compliance program, then you are probably in the wrong position.
I think rather than asking how to get business executives excited about compliance, we should ask how we can frame our compliance metrics in a way that supports the things that make the business executives really excited about the work compliance does.
Metrics: What’s Important to Executives?
Many of us in the compliance field produce benchmarking data for the board and executive management teams. A small sampling of typical metrics include:
- Number of hotline calls received (by location, business unit, anonymous/identified, allegation, etc.)
- Length of time to respond to hotline call
- Source of hotline awareness
- Number and type of privacy violations
- Number of active compliance investigations (by type, location, allegation, etc.)
- Length of time to close investigation
- Number of training programs delivered
- Training completion rates
- Policy dissemination acknowledgements
While these metrics can give important information about the performance of the compliance program, they don’t really convey meaning to the executive team and its impact on the business. I would argue that it is often difficult to engage executive management in your compliance program because you are not providing them with any information that is framed in a manner that helps them mange their critical strategic and operational priorities.
So, let’s think about some of those business priorities. In my experience, healthcare executives are focused on quality, revenue, costs, growth, patient, employee and physician satisfaction, and reputational, financial and operational risk. How do you use these priorities to effectively show executives what is going well in your compliance program and what requires their attention? How can your metrics help executives understand their risk position? How do you help executives establish a meaningful risk tolerance level?
To answer these questions, you first need to determine the types of data you will provide. Generally, there are two types of metrics: process metrics and outcome metrics.
Process Metrics and Outcome Metrics
Process metrics are those data that show program effectiveness (hotline reports received, number responded to timely, trainings completed, policies distributed, etc.). Process metrics should include an indication of how the measure is trending over time and some indication of criticality to help your executives understand those data that require their attention, those that don’t, and those that should be celebrated.
Outcome metrics are those data that show the results of your auditing, monitoring, and investigation programs which address specific risk areas (new physician coding audit, focused claim coding audits, employee access audit, etc.). Outcome measures should be tied to your risk assessment priorities and are often easier to align with strategic priorities.
Gather and Connect Metrics
Your metrics should derive from the seven elements of an effective compliance program , your risk assessment priorities, and specific risk areas. It is important, however, that you don’t try to use data to develop metrics for every aspect of your compliance program. Remember, your executives are getting data from various departments across the organization, and data fatigue is a very real problem. Copious amounts of data will cause your executive’s eyes to glaze over and the messaging you are trying to convey will be lost.
Consider aggregating some of your department data into a few key metrics that can drive a story aligned with the organizational strategy. For example, you may want to take all of your compliance program effectiveness measures and provide a single effectiveness score which can be trended over time. Similarly, you can take specific risk area measures that affect one of the key strategic priorities and aggregate them into a single strategy score (i.e. provide a Readiness for Growth measure that combines your auditing results that affect Growth).
Keep in mind that not every audience requires the same data. Your compliance Committee may need significantly more information about specific reporting elements than other members of your executive management team. Know what actions, decisions, or discussion you want to elicit from the group and tailor your data and metrics specific to the audience charter.
Finally, consider how to connect your information with other information gathered by the organization. For example, if Quality is collecting information specific to patient satisfaction, think about how your data may inform the quality data. Are you seeing more hotline calls coming in from units that are reporting poor patient satisfaction? Are you seeing more data breaches from units that are reporting poor patient satisfaction? When you can integrate your data with other data collected in the organization executives can better understand what the data means on an overall scale.
To engage your executive management in your compliance program you need to provide them with information that can help inform their strategic priorities. This approach requires a different mindset by compliance officers. Most compliance data provided to the executive team is designed to express potential compliance risk without being tied more closely to the organization’s strategic priorities. However, the data your provide should include both process measures as well as outcome measures and should be tailored to the audience you are presenting the information to. By aligning your compliance metrics with the organization’s strategic priorities, you are seen as a partner in achieving organizational goals rather than just managing goals separate from the rest of your organization.
As your organization’s compliance professional, you have a lot of data available to you. Your challenge is taking all that data and leveraging it into meaningful and actionable information for your executives that aligns with the organization’s strategic, financial, and operational objectives. This engagement will form the partnership you need to minimize risk and grow your program’s visibility.
Margaret has over twenty years of experience in healthcare compliance, including roles as Cheif Compliance officer for large integrated health systems providing services in multi-state geographies. She is recognized as an industry thought leader and speaker, including addressing the US Senate Finance Committee and other government agencies. Margaret is also the past President and current member of the Board of Directors of the Society of Corporate Compliance and Ethics (SCCE) and the Health Care Compliance Association (HCCA) supporting and promoting integrity programs nationally and internationally.