Monday, June 4, 2012

What is compliance? Internal Oversight

I ended my last post about internal oversight so I'm going continue with that. Who owns compliance? The reality is that it is everyone. However if you ask 10 employees nobody will say they have a part in it.  Usually they'd say legal owns it or the compliance dept or maybe their manager. It's sad but its the situation for most companies.  When looking at internal compliance it really gets worse.  Most companies really don't have the time or budget to review all internal policies let alone spend the effort to make sure they are enforced.  It's a thankless job. Nobody likes to be scrutinized and even worse being told they aren't doing their job. It's like being in Internal Affairs police officer. You gotta have them but nobody wants to hang out with them. 
The mindset in Health care really should be how the FDA does their process and oversight. That's really the model that its going to.  Products that are developed need to trace to the business specifications traced to the business requirements to functional requirements, etc.  Policies will all need to trace up and trace down.  This also means the administrative workload will increase to ensure compliance(adherence).  Most Health Care companies are going to need to build out their compliance departments from just usually legal to having members with clinical and IT background also. Auditors aren't just going to accounting guys anymore. Companies are going to have to defend how they do business from the top to the bottom level.  Companies need to take a proactive approach to internal compliance.  You need to make folks realize that they do process as a way being more efficient. On the flip side you also need to be open and receptive that if process isn't working you need to fix it. It's a two way street and managers need to understand that.  It's a way to help promote reliable and consistent service to the members that use your health services.  Think of it as eliminating unwarranted variation at the corporate level :)

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