Welcome to a new feature at CCI: We’re calling it “New Voices,” and it’s a way to showcase the fresh perspectives offered by those who are new to careers in compliance.
Margarita Derelanko shares the wisdom she’s found on succeeding in compliance, albeit from an unlikely source: her experience with motherhood. Here, Margarita offers guidance relevant to parents and compliance pros alike, from offering choices to handling pushback.
I have a confession to make. About five years ago, I thought to myself: get a health care compliance graduate certificate, obtain CHC and employment in a compliance role (preferably, before the certificate program is finished) and boom, I can do health care compliance. The same thinking developed when my husband and I decided to start a family in 2016. We read parenting blogs, books, attended baby classes and seminars, bought a baby app (actually, a series of baby apps) and were content in all of our efforts toward becoming perfect, well-prepared parents. That was just the beginning of our journeys.
Looking back, I am convinced that our family and I needed the awakening that life “by the book” is not achievable and that a compliance profession “by the book” may not be realistic, effective or rewarding. Today, I want to share some of my observations from the perspective of a 30-year-old mom whose experiences as a parent shaped her into a better compliance practitioner (and vice versa) and from the perspective that life is not outlined on the pages of an expensive textbook; the answers are not right there in black and white.
When you begin your first compliance role, everything you learned or acquired from a book or a classroom may be spinning in your head. Much like a brand new parent, you are faced with a human who needs you. Is it time to feed them, sleep them or change their diaper? When should I do what? Am I doing a good job? Am I making mistakes?
Similarly, at work, you may think to yourself, “I remember from one of my health care compliance classes that this has to be done differently. Are we out of compliance in this particular area?” As a brand new compliance practitioner or at a new job, we may be considering everything we want to do and accomplish; we may want to tackle all of the seven elements of an effective compliance program and more.
Learn the Baby, Learn the Business
Wait. Take the time to learn your baby, his or her signs and moods; take the time to learn the business, where you work now – and no, I am not comparing a baby to a business. What is important to your company? What does the organization need most in terms of compliance? Build relationships, and do not rush into making too many changes at the outset. Do not begin creating more projects for yourself and take it all on. Compliance work will find you!
It will take time to start feeling comfortable in your role or at a new company, but it is important to observe. In my first health care compliance role, I did not get to observe as much as I wanted. I was building momentum until my supervisor departed from the organization, and I was made an Interim Compliance Officer after only six months in an entry-level compliance position in addition to becoming a lead on an agency-wide re-accreditation. Could I do this? Timing was not ideal, but I rolled up my sleeves and got to work. After the successful re-accreditation, I was able to look back on the work accomplished and changes made and justify the rationale behind them; but those changes could have been more effective had I had the chance to implement them in a more steady and purposeful fashion. I thought, “Now, I can work on building that proactive culture of compliance.” Soon after the accreditation debut, my husband and I became pregnant…
During my pregnancy, a highly motivational female leader supervised me. As a compliance professional, I knew we needed to expand email encryption and we needed a secure, HIPAA-compliant text messaging platform. Luckily, our laptops were already encrypted (phew!). The supervisor and I worked well together to find solutions. It seemed I was riding a compliance wave during the time of high investment into compliance. It felt great, knowing that the company was protected and that many checkboxes were ticked.
After that period, I went on maternity leave, during which I learned all about “regressions.” There is a lot of literature on baby regressions (of course, I read almost everything available online). After an exhausting, sleepless, trying four months (my daughter had milk/soy allergies and reflux), I came back to work, thinking I could just pick up where I left off.
One word: postpartum… This is when intentional relationship building became the remedy in my personal and professional life. As a brand new mom, I understood challenges, that not everything is black and white. If it were, then why didn’t I know how to make my daughter go to sleep at night, for example? Pediatricians do not give you an outline of what to do (nor should they), but at first, it frustrated me.
Then it dawned on me: I cannot be a perfect “by the book” mom. By the same token, I cannot be a perfect “by the book” compliance practitioner either. Instead, I am going to work on being the best version of myself at home and at work; I am going to build relationships, learn from others, be attentive to others and be gracious and kind while promoting the proactive culture of compliance at work and while educating others on the right thing to do and what compliance means (at least in my own eyes).
One thing I thought was helpful after reading countless parenting articles and books was the idea of providing two acceptable choices to your child – for example, an option between two weather-appropriate outfits, or two toys or two activities. It gives a toddler or a bigger kid (I hope) a feeling of control over his or her life. Even as kids, we crave power to choose. As adults, this craving is more prevalent, and we tend to wish to control how we work, how we operate, our work style, etc. Knowing that, navigating compliance may become easier for younger or even seasoned compliance professionals.
As I became more sophisticated in my role and listened to my intuition to engage employees more and to learn about their challenges, I started listening to the goals of a team or a department and understanding what they are trying to accomplish, the barriers they face and what it will take for them to be more compliant. Most often, this would occur during face-to-face time, when we could have deeper conversations, think as a team and come up with a practical compliance solution together.
Of course, sometimes, as a compliance practitioner, you may face a level of resistance. Under those circumstances, my goal would become creating rapport with the stakeholders, reiterating to them that they already do activities on a daily basis that promote compliance (e.g., locking their computer to step away from the desk, checking expiration date on the authorization to release information before sharing with a third party, etc.). We would discuss that their team or department could achieve even greater compliance if they were to follow enhanced procedures or guidelines. Additionally, when faced with a compliance “tantrum,” giving two acceptable options would become a method to promote the proactive culture of compliance: One option may be more complicated than another and may take time and team work, but either path may lead to a new level of compliance.
It does take time to instill that sense of confidence that employees themselves already exhibit compliant behavior and can incorporate better practices and be even more compliant. Once you are able to do that, it is one of the most rewarding feelings you can have as a compliance professional. Add the relationships that you built as a result and the compliance advocates you cultivated in your organization, and it all becomes worthwhile and satisfying.
Engagement and Care
Along the way through the “infant” and “toddler” stages of my health care compliance career, I recognized that engagement is critical to the success of the compliance program. Plus, I always love to have a little fun and explore my creativity.
First year’s compliance week was a success. We barely had a budget for prizes (in fact, we used the entire budget on prizes), but we were wealthy in terms of our enthusiasm and belief in the effort we were putting forward. My colleague put together final compliance communications for daily emails; I learned how to create and edit clips in iMovie. We researched, found free resources on the HCCA website, created games and visuals and launched our company’s first annual compliance week. On the final day, we convinced everybody (well, almost everybody) that compliance can be fun!
Several years later, during our third compliance week event, we had the support of the development and marketing teams, who designed beautiful, brand-forward promotional materials. We had it all: games, one-page tips, internal and external training, resource tables, stickers with catchy compliance reminder rhymes, face cut-outs of their favorite compliance people (right?), diagrams, photo hunts, short videos with peers educating one another on compliance, etc. The end-of-week survey demonstrated that through this engaging, fun and unconventional way of thinking about compliance, employees had rated training and tips among the most-liked activities of the week. We discovered that when you present information in this manner (even compliance topics), people learn, because they want to learn and enjoy the process.
Read the Signs
Engagement and care are just as important in parenthood. If you care to pay attention to the signs, if you care to engage your child, you will see what they need, when they need it and how they need it. My daughter (so far) has shown my husband and I when she was ready, for example, to be un-swaddled, to sleep in the crib, to take a bottle and a pacifier, to try going potty, to sleep in a toddler bed, etc. The signs were there; mommy and daddy just paid attention and engaged her to read them.
Celebrating compliance week events and practicing engagement in my compliance role shaped my professional philosophy of “CARE” (Compliance Awareness, Reinforcement and Engagement). This philosophy goes beyond compliance and beyond health care; it can be applied to any industry.
Proactive Parenthood and a Proactive Culture of Compliance
One day, after my daughter was moved to another day care room, I contacted the owner to determine how I may be able to learn how my toddler is doing in the classroom since the reports were no longer provided to the parents. After asking whether I would be notified about my daughter’s dietary, sleeping, potty training or behavioral issues, I was questioned, “do you have behavioral concerns about your daughter?” My answer was no, but as parents, my husband and I prefer to take a proactive approach – to anticipate, prevent or work on any toddlerhood tendencies as early as possible.
It is the same with compliance. Why should we wait until there is a concern? Why should we solely rely on our reporting mechanisms to find out when something is potentially out of compliance? Instead, we should ask questions from stakeholders, seek out information, hear from others, go in person and get in there before you receive that call or that report. We may not be able to avoid every compliance “tantrum” or “regression,” but we will know that we are being proactive and making the best effort to prevent, mitigate and resolve. Read the signs.
Tomorrow is Another Day
Compliance is not about doing the right thing. It is about trying to do the right thing, and if something goes wrong, correcting it and taking measures to prevent it from happening in the future (the best you can). Compliance may be about second chances, but it is also about trying to get it right and recognizing that we just need to put some effort, awareness and care into it.
If you are not the best version of yourself as a parent today, if the company is not the best version of itself today, try to do better tomorrow, because tomorrow is another day.