Some Thoughts on Tone at the Top
In the January 2014 issue of Compliance Today, Bret S. Bissey, MBA, FACHE, CHC, Senior Vice President, Compliance Services with MediTract authored an article about engaging a healthcare organization’s top leadership with the compliance program.
One of the questions frequently asked when analyzing the effectiveness of compliance program is “What is the tone at the top of the organization?” This question broadly speaks to how engaged an organization’s top leadership are with the compliance program. Is compliance part of the real culture of an organization or is the program just in place because it is a requirement?
I believe to answer the question about whether you have the proper compliance tone at the top requires some detailed analysis prior to providing an answer. I would also mention that I am a strong proponent that governance and board oversight of a compliance program is critical to organizational success. Some (especially those in non-compliance roles) would suggest that because you have in place policies and procedures that say leadership is engaged, it must be so. I maintain that to answer the question accurately requires a deeper dive into the topic.
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