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Healthcare Compliance in the New Normal: Part 3

How are compliance officers at healthcare organizations meeting the challenges of compliance through the COVID-19 pandemic? An industry panel discussion that I moderated shed light on this topic and how the pandemic’s impact is shaping future plans.

Our speakers were Tina Tolliver, Chief Compliance, Ethics & Risk Officer/Privacy Officer at Millennium Healthcare and Mark Nue, Compliance & Privacy Officer at Alta Hospitals Systems.

Here is part 3 of our 3-part series showcasing excerpts from the webinar discussion.


Our fifth audience polling question: What work model are you currently using?

What work model are you currently using?


Sixth polling question: How much of your team is back in the office?

How much of your team is back in the office?


Marcy: We have discussed going back to basics and having the compliance team remain focused on doing the work they are skilled in that needs to be done to protect the organization. Let’s transition that conversation to what do things in our department look like going forward as we start talking about the issues coming in, and what adjustments should be made to our programs and to our work plans?

Tina:  One of the things I thought was very important was that when we were having virtual meetings, you still have to position yourself in this Compliance role.  And so, one webinar that I was in [had us to think about] the triangle, to make sure you got your head and your shoulders on-screen. We’ve seen people who have their face clear up to the screen or they’re way in the back and you can hardly see them. We have to be professional, which was important to me because I think that compliance comes with a persona that we have to make sure that we’re maintaining ourselves.

And then conducting virtual interviews, these investigations we’re going to be doing virtually –how do you prepare for that? Think about the landscape of what you’re not going to be able to see, the body language. You’re not going to be able to see some of those hidden cues that people give you when you’re doing investigations. Are there any other people in the room? Even if you ask, is there anybody else in the room while you’re doing some of these things. So, make sure you’re thinking about it as though you’re attending meetings if you’re conducting investigations. You have to think about all of these things that you could potentially throw you off, throw them off, not get good information.

Another piece that I want to talk a little bit about is Compliance campaigning – just making sure that people know where you are and that you’re there and you’re available. When we had our Compliance Audit Committee meeting, one of the things I asked for was a risk assessment, a matter of just a few questions: How are you keeping up with the demands given short staffing and the number of reports that are coming in, have you developed new processes with those demands? Are you able to sustain those processes for the remainder of the year?

So, some of those things, redesigning, making sure that you’re covering these pieces, knowing what you are, who your audiences are, and then your presentation to that audience. I think those are huge and are key to maintaining that compliance persona throughout this period of time.


Seventh polling question: Can compliance management software that automates processes be a workforce multiplier and help to offset reductions?

Healthcare compliance webinar polling question 7


Eighth polling question: How have you had to change the way you report compliance updates to the board and senior management?

How have you had to change compliance updates to the board?


Marcy: Mark, do you want to share, as we go through this process, how that changed or are impacted your program, going forward, and if you have a special nugget of information that could help others out there.

Mark: We saw an example of this using the software and leveraging it when it comes down to the detailed stark waivers that we’ve put in place. We’re fully documented in the solution to ensure that this is what we did, when, our thoughts at the time, who we spoke to and looping in all the details into that space and place.

And we’ve been able to categorize by location and the parties involved. Things are going fast and furious, and people will try and remember, but not be able to say – well, did we do this for somebody, and did we provide an extension or an exemption or something to a doctor or a group? We’re using our software to the extent that we can and even learning how to use it better. So that’s for sure been a workforce multiplier.

And as I alluded to before, my board and leadership reporting is not in-person, as I prefer. It’s more dial-in and calls in, but I have switched up a bit to kind of call-out to individuals for validation and engagement, you need to have that personal touch. We haven’t gone, and I know some organizations have gone this way, where they have cameras on for all meetings in addition to dialing-in and calling-in.

This is very interesting for the kind of things that Tina talked about, that you need to be prepared and mindful of noise and things in the background. It’s very much a new paradigm, and I’ve been getting away from overthinking to just adjusting to how things are now.  I’m not waiting for, if we hold our breath long enough, it will go back to the way it was. I don’t think we’re going to go back.

Marcy: Tina, do you have thoughts to share about changes you’re putting in place for the future?

Tina: Some of the things I’ve seen are where our department has changed quite a bit, and we’re needing a different kind of skill set where we need that cross-training now. As the experience has been heightened, I know that will be an expectation for me and others. We’ve done a lot of creative design and framework, so now that will be an expectation going forward for leadership to us, for me, and for my team. How can we refine that? How can it look better? How can we get in and improve upon that? With the new DOJ guidance coming out, they’re looking for these data-driven, operational, cross-functional reviews, how that is going to play out in our compliance programs?

How are we tracking and trending things and a lot of those changes that came through with the DOJ? They want to know, do you have good policy management? Do you have good incident tracking? Do you have good training? What did you learn from this?

And the other piece, that is kind of a no-brainer and very easy, is they want to see your compliance program’s evolution over time. This year we can show that big time, right! We can show how we’ve incorporated different risks, quality, privacy, security, and financial piece with CARES. It’s right there at our fingertips.

And how we’ve changed it in the design and tailored it to what has been going on in our world. So, I think with automation, with technology, with what is happening. When I say going back to the basics, going back to our work plan, and thinking about what didn’t happen, just like exit conferences. Who’s not here? Who wasn’t interviewed during this time? If people were furloughed or put into the remote world. Let’s do some of those risk assessments. Let’s do some of those interviews and talking with people when seeing, again, what we need to do from here on out.

One of the things with my Board Report is that it did change from what I was normally reporting, from a seven-element kind of situation to more about how the risk of those seven elements is being impacted. I would try to highlight each one of the areas where we now have risk from a compliance program seven-elements standpoint. And that was something I felt very highly about, as far as making sure that the board was apprised of those things affecting the compliance program and the organization.

Marcy: That’s great. I want to thank both Mark and Tina for taking time out of their very busy day to share some best practices and things they’re seeing and experiencing. Those participating today can use the data as we’ve talked about in the polls and the poll results to better understand how others are responding and adjusting their compliance programs.

I want to thank both Mark and Tina and all of those who are working to protect us, and taking care to ensure that those that are on the front line have the resources available for them to do their job. It certainly takes a village to make all this work.



Replay the full webinar on-demand to hear the rest of the conversationRoundtable: Return to Office, Healthcare Compliance Edition


See additional resources and insights from SAI Global for managing healthcare compliance during the pandemic.

Learn more about our risk and compliance solutions for healthcare and health insurance organizations.

Or, contact us to see how SAI Global has helped organizations like yours.