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Some Thoughts on Tone at the Top

Posted By: Bret S. Bissey, MBA, FACHE, CHC, CMPE / July 21, 2015

HCCA LogoIn 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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Bret S. Bissey, MBA, FACHE, CHC, CMPE

Prior to joining MediTract, Mr. Bissey was the SVP, chief ethics and compliance officer at UMDNJ, where he successfully led the compliance program to adherence with a rigorous five-year Corporate Integrity Agreement with the DHHS/OIG that occurred following a Deferred Prosecution Agreement. Prior to UMDNJ, Bissey served as the director of the Regulatory Compliance Practice at IMA Consulting, the chief compliance and privacy officer at Deborah Heart and Lung Center (operating under a CIA) and the VP of compliance at Cabot Marsh/QuadraMed. Mr. Bissey earned a Bachelor of Science in business administration and marketing from Shippensburg University of Pennsylvania and an MBA in marketing and healthcare administration from Wilkes University. Mr. Bissey is a frequent national speaker on healthcare compliance and is the author of The Compliance Officer’s Handbook. He is a Fellow of the American College of Healthcare Executives and a member of the Health Care Compliance Association (CHC), American College of Medical Practice Executives and the Healthcare Financial Management Association.