“When our organization needed interim compliance department leadership, the first thought of both management and the board’s audit and compliance committee members was of our partner, Protiviti. Protiviti was not only able to quickly evaluate the scope and effectiveness of our compliance department’s oversight, but was also able to very quickly fill identified gaps with appropriately experienced compliance personnel. The best practices and methodical approach to compliance risk identification and management implemented by Protiviti have continued to be a hallmark of our program, long after the end of the engagement.”
-Chief Administrative Officer
A mature compliance function is crucial to the success of healthcare organizations, which operate in a highly-regulated environment. For large organizations, creating a centralized compliance program that also responds to the unique compliance requirements of each region in which they operate can be a real challenge, often complicated by the need for experienced and knowledgeable staff.
When one of Protiviti’s clients — a healthcare organization with significant hospital, physician group, post-acute and joint venture operations — detected the need for a stronger regulatory compliance program, it took swift and resolute action. This action was a bold effort that entrusted leadership and management of the firm’s compliance department to a Protiviti team of experts and resulted in a broad range of tangible talent, procedural and technological improvements — changes that together amounted to an invigorated and robust compliance program capable of scaling with the company.
To solve its compliance challenges, the healthcare organization called on Protiviti as a familiar and trusted resource. Protiviti had previously conducted several process improvement initiatives for the company and currently serves as its co-sourced internal audit partner. In the latter role, Protiviti has performed compliance-related audits, and two Protiviti leaders report quarterly to the audit and compliance committee. That familiarity and trust enabled the healthcare organization to give Protiviti a substantial, two-pronged mandate:
Protiviti leveraged its partnership with its parent company Robert Half, a global staffing firm, to address the healthcare organization’s most-specialized compliance talent needs.
The healthcare organization sensed that its compliance function was struggling with distinguishing major compliance risks from minor compliance issues. Management requested a comprehensive evaluation of the function to discover the root cause of the difficulties.
With a Protiviti compliance expert as the interim CCO, the Protiviti team initiated a top-to-bottom compliance program effectiveness evaluation, calling on a number of subject-matter experts to assist with specific aspects of the analysis and to fill gaps in staffing positions identified by the evaluation. Among the resources deployed were compliance professionals selected for their deep expertise in specific healthcare environments such as acute care facilities, physician groups and health plans.
The assessment consisted of dozens of interviews of facility presidents, the compliance personnel in the corporate office and in field locations, board members and others. It also included analyses of compliance issues identified and work plans executed over the last several years. A member of Protiviti’s evaluation team attended many of the compliance committee meetings of the provider’s regional boards to gain an understanding of the compliance challenges in each region.
Protiviti identified approximately a half-dozen high-priority improvement recommendations. To the healthcare organization’s credit, management took action on all of those high-priority issues, enlisting Protiviti to implement the following:
These improvements, nearly all of which were completed in less than a year, generated numerous tangible benefits for the organization. For example, improvements in the monitoring of compliance with relevant rules and regulations helped identify and eliminate gaps more quickly. Improvements in communication protocols helped strengthen the relationship between the compliance and legal functions, bringing them on the same page about issues that create compliance risk.
Shortly after the bulk of the improvements were instituted, one operation within the healthcare organization was informed of a looming audit by an external regulatory agency. The audit was completed quickly, without a single corrective action required by the regulator.
More important, the compliance function’s overall improvements equipped the entire organization with a clear understanding of what rises to the level of a compliance priority. This clarity continues to help optimize the organization’s ongoing investment in compliance resources and activities.
The benefits from the work Protiviti performed would not have been realized without the willingness and commitment of the healthcare organization’s leaders to fund the improvements that the assessment identified. Several important actions drove a successful outcome, including:
By supporting Protiviti’s compliance management, evaluation and improvement work in this manner, the healthcare organization was able to re-energize its compliance function and align its multiple components, resulting in a reduced regulatory compliance risk. The function is led by a new permanent CCO, who has a clear road map by which to direct the organization’s compliance efforts.