Podcast: The Unique Qualifications Of A Skilled Compliance Officer

Back in the 1980’s, Larry Plutko started his career in Healthcare and by the 90’s found himself fascinated by compliance. In 2008, he accepted a position of compliance officer in Austin, Texas, where he became an important career mentor to me. Now, Plutko is a compliance consultant who currently sees clients across the country and I couldn’t be happier to have him on my show.

In this episode of Compliance Conversations, I interviewed Plutko on his compliance career path and the types of careers that are the best for becoming a compliance officer. “I believe in diversity and organizations benefit from having Compliance Officers from a number of different backgrounds. Compliance Officers come from all sorts of fields from legal to clinical, ethics and auditing,” said Plutko.

We also chatted about the ways in which compliance is rapidly growing and why it was named one of the hottest career tracks in the Wall Street Journal in 2014. Then, we dove into what it means to be a good compliance officer and how to develop the unique skills necessary to excel.

This podcast episode is perfect for compliance officers who want some invaluable tips and tricks for succeeding in the field and for anyone who wants to learn more about the exciting field of healthcare compliance (especially those interested in becoming a compliance officer in the future).

Tune into, The Unique Qualifications Of A Skilled Compliance Officer, where you’ll learn how to prepare for the future of compliance, become a compliance officer, and excel in a compliance career.

Episode 4 Transcript:

CJ WOLF: Welcome everybody to another episode of Compliance Conversations. I’m CJ Wolf, Senior Compliance Executive at Healthicity, and today we have a wonderful guest Larry Plutko. He is a dear friend and somebody with a rich experience of compliance in a variety of areas and he is using all that expertise now to assist organizations as a consultant. But he is a real practitioner in compliance, so welcome Larry.

Larry Plutko: Well thank you very much CJ. I’m here in Seattle, hopefully not sleepless since I’ve had a few cups of coffee by now.

CJ WOLF: OK, very good, “Sleepless in Seattle.” Larry I want you to take a minute and just explain and share with us a little bit of your background and your experience in compliance. I think just hearing where you’ve been and what you’ve done is a real treat.

Larry Plutko: Well OK, thank you very much. I got started in healthcare in Pittsburgh, Pennsylvania, actually. Back in the 80’s I was the vice-president of a hospital system, Pittsburgh Mercy, which is a part of the University resources these days, and I was there as their corporate advocacy, since I have a background in healthcare ethics and while I was there we began to hear about the new field of compliance. So I kept that in mind and eventually moved with my family to Seattle, Washington and became a part of the Providence Health System, which is now the Providence Health and Service, and I continued in my role there in the 90’s as their corporate compliance officer. And then around ’93, I believe it was, and this is just after the federal sentencing guidelines were published in ‘91, so I was approached by our CEO about my interest in heading up a new area, which was then called Compliance. And I was saying, “What in the world is called ‘Compliance?’” So after going to the dictionary, which I first did, I found it was very little in the literature, except for maybe banks and all financial institutions. But at the same time in the Clinton’s administration operation restored trust which was rolled out in 1995 and my organization along with some others were interested in setting up the very first Compliance shops, if you will. Back then, we were dealing, CJ, with the 72 hours, 3-days window.

CJ WOLF: Yes! That’s right.

Larry Plutko: Compliance was the hot topic of the day and also ABMs.

CJ WOLF: Oh Yes, ABMs!

Larry Plutko: And we had Miners’ insurance that didn’t and all those kinds of prompts that we had our persons ask patients as they enroll. So back then I moved on eventually, between 2000 and 2003, I moved to Yale, Head of Ethics and Compliance program for Yale New Haven. I got more experience with dealing with physician groups academic medicine of course and I really thought that I probably stay there through to retirement but, lo and behold, I was approached by the University of Texas System in Austin, Texas—it has 14 Universities it’s a very large operation—and I was asked to take on the role as their very first compliance officer, So I moved in 2008 to Austin and eventually you, CJ, came into my staff from the Cancer Center and it was a beautiful time, great time working together and dealing with compliance issues. Not only on the academic side of the house, as they say, but also with medical schools, ethic schools and research centers, and so I think I sort of dipped my toes, as they say, in a lot of different areas of compliance in the course of my career. And then today I retire in 2014 and have a pretty active compliance consulting business and I certainly enjoy that and do as much as I want, so to speak, and that's what brought us together again after some years apart and I’m just thrilled to be here this morning.

CJ WOLF: Yes, thanks Larry. And you know, for the audience, just to give you a little background of my thinking, as I was looking for new guests, as we always are, so please contact us if contact us if you got guests you would like us to speak with, but Larry came to mind because he’s a real mentor to me, personally, and I thought it would be really neat to talk to him. And I know he's got this rich experience and he is still heavily involved and he is now involved to a point where we have seen a lot of different clients across the country and that sort of thing so we’re going to talk a little bit about that in a minute. But because one of the first words that comes to my mind about Larry is “mentor,” I wanted to ask a little bit more about compliance as a profession and get his thoughts because he’s seeing where compliance is seen as a formal profession right, Larry it would be interesting in hearing your thoughts on what you think of compliance as a profession and it’s growth and where it is going in future, is it plateauing as a profession, is it increasing in importance give me your thoughts on where you think the professions moving.

LARRY PLUTKO : Well I know I don't think it is disappearing, far from it, because we know that compliance as a profession has expanded by leaps and bound and last evening I happened to be looking at the Wall Street Journal article from 2014 which indicated that compliance was one of the hottest career tracks available for anyone these particular days and I think that is the case because you know we even have more professional compliance programs that are attached to some of our finest universities and that is something which started probably maybe about 10 years ago but over the last three or four years we’re seeing more and more of those programs opening up. Because the talent search is a difficult one for organizations CJ, and quite regularly I get inquiries either through phone calls or emails from organizations looking for a compliance officers or associate compliance officers because they have difficulties filling those positions and case in point. Now if you go to the Healthcare Compliance Association where they list the job openings or those referred to as SCCE or even the American Health Association [8:05] is just incredible how many openings there are at all levels of the organization. So I just made my case on that, that the area of compliance is certainly one that has a great future e who would like to throw their hat in the mix so to speak.

CJ WOLF: I see a lot of that as well and so that is what I was anticipating you would say but it's good to hear that you're seeing that as well from different perspectives you know it's interesting a lot of people in compliance come from different backgrounds I mean your formal training is as an ethicist but I worked for people that in a hospital system where the compliance officer came from a RN background I have worked in others where they came from a legal background, so some clinical, some legal, some ethics, some auditing. Do you have any thoughts on kind of the next best way to enter the fields? Or all of those types of folks are welcome and what unique about the skill set that they would bring … [9:13]. I think there are various accolades I mean I believe in diversity and even professionally speaking, I tell my son who happens to be a lawyer CJ that some of the finest people I know are lawyers.

CJ WOLF: laughing

Larry Plutko: So when I look at the very, very rich association and relationships I have with professionals in compliance it brought the gamut from tremendous internal auditors, lawyers here and there are few persons who actually have been on operations I think I have a great respect to provide, so I think it’s important for organizations to have that mix of backgrounds and be intentional in their staffing. CJ WOLF: Right! Larry Plutko: for organizations that perhaps have that advantage, so I think to this day I find the more interesting programs of those that sort of capture that makeup.

CJ WOLF: Yeah you and I talked a lot about working together, about the concept of operationalizing compliance as you mentioned people with strong backgrounds and operations can be a real skill set, especially healthcare because it's not the compliance office that are solely responsible for compliance right they’re responsible for running the day-to-day programs but everyone on the front-line operations that's where compliance happens right.

Larry Plutko: Absolutely! There is sort of a mantra that we use to use CJ, the operation operationalize compliance or otherwise lawyers and compliance officers and others who really are in the consultation role in an organization are crossing over a line that is really not theirs, we give advice, we prompt, we remind, we educate, but really operations has to be able to bring a compliance program to their organizations as much as his responsibility for financial indicators so I think that has really moved further into the fabric of American Healthcare management.

CJ WOLF: Yeah, good point. Let’s shift gear a little bit, I want to capitalize on your current experience because you have seen a lot over the last few years as a consultant in practices, and a lot of compliance programs across the country, so you’re seeing trends and needs and gaps and those sorts of things from a unique perspective, because you’re seeing all these different organizations. And I also know that you work a lot with the compliance in the higher education industry but what would you see as kind of the top 1 or 2 compliance trends that you are noticing from your clients or from other organizations that you are dealing with right now?

Larry Plutko : I would say, and I don’t think this would surprise people, that the number one issue that comes up would be that of information security, and more specifically cyber security, and how that is affecting compliance these days. When I think back on when I got involved in the healthcare field, gosh back even in the late 70s the paper record at the nurses’ station was quite ……….Unclear audio ……..[13:14.5] And so that brings a whole other dimension these days to how the compliance officers needs to do what they do.

CJ WOLF: Yeah and that’s true not only for healthcare right but also for other industries like higher education. We were seeing breaches and we know in our education there is an overlap a lot of time between their healthcare system and the educational system but is that true in both of those?

Larry Plutko: oh, absolutely and what I find people dealing with, whether my client might be an academic university that doesn’t have a health component or one that does, you know is the whole specter of the “dark side” as it’s called the “backside” of the security. The hackers going about their work for ill-gotten-gain and identity theft and even things that might seem quite harmless. Somebody swipes a card in the gift shop of a hospital on a PCI reader. How secure is that? Or individuals who are working in patient’s accounts, for example, how much, what was the security with regards to malware, and all order strict protocols? With regard, CJ, of individuals using personal email that can be embedded with malware or even downloading apps on the desktop, which is desktop management. Going back to our clients together, with the University of Texas system, when we inherited the whole information security structure, the information security officer for example reported to me, and I struggled a great deal over this specific area but I found that to be a gift [15:41]. I found that to be a gift because I think these days I can be of assistance to organizations who are struggling with how to handle an area that is extremely costly. First, we’re using compliance in ways we never ever dreamt of and it is ultimately connected to privacy because privacy and security are jointly related per the regulations. So I think that is just something I think percolates to the top.

CJ WOLF: Yea you know what I think, I don't know if you think this is unique but I think historically a lot of chief information security officers, or CISO, have reported to the Chief Information Security Officer. I’m interested here, do you think this is true for other organizations that it may be more appropriate to have that CISO report outside of that line of the Chief Information Security Officer? Because there could be potential conflicts if the CISO is reporting on, and auditing in, and evaluating areas under their direction. That direct reporting relationship. What are your thoughts on that and the reporting relationship of the CISO and how it might be best designed in a compliance program?

Larry Plutko : Well I do favor that the information security program and the information security officers be within house, within the compliance area. You know when I first dealt with this first hand, I started with the information security status at the University. Gosh, we had about, in our scope of authority, we had over three hundred people involved and I found very early on that we had individuals who were just brilliant with regards to explaining the technology and dealing with the technology but they didn't quite understand that they were also compliance officers. Because the whole structural of information security is based on the head of security role. Everything from oversight policies, education and so on, so forth, so what we did earlier on, we actually conducted a workshop on how an information security officer can also be a compliance officer, they’re one in the same. So that's just my view, chances are there are CIOs who will strongly disagree but I see more and more ……. [18:29] in the industry that information security is indeed a unique area.

CJ WOLF: Excellent point, now if we can shift gears again, I would like to talk a little about the kind of your things that I've observed in you, I hope I’m not going to embarrass you. The one thing that I appreciate about you, and I think it's apparent for those who’ve listened so far in the podcast, is your tone and approach to compliance is very thoughtful. It's not, I’ve met a lot of compliance folks who get a little nervous and they tried to be overbearing but your approach, I think, is unique. And I see you practice your tone in your approach and in very complex organizations, especially ones that have very political cultures with individuals who might have very strong personalities. And it's, I think it's a delicate skill that you possess and I don't know if you were born with it, or you developed that. How would you mentor someone like me or someone newer in the compliance field and developing those kinds of skills that aren’t necessary learnt from a book?

Larry Plutko : Well that’s a good question, you know what I’ve found entering into healthcare and dealing with a lot of very, very bright people CJ, PhD, MBA and so forth, people with just incredible backgrounds were very rewarding. I would go about sit down with perhaps a professor in medical school or the department and ask them to explain to me what they did and what was new in their area, how they treated their patients and so forth. I found that you develop a tremendous rapport because you are humbling yourself to the strengths of others.

CJ WOLF: Yea I used to hear you say that a lot.

Larry Plutko : Individuals love to share their passion and I think that this is so that we’re at a crossroad for doing compliance where that opens up a dialogue where you can be of assistance to all the various departments and divisions business units with regard to helping them do the right thing whether that's the ethical portion of it or the billing portion of it. So, I think that that's where the trust comes. And you know, there are obviously very strong people and organizations at times, and I know I, like others, find myself cowering from individuals with very strong personalities. So, in projects that I’ve done, or projects perhaps CJ that you and I have sponsored from the central or system offices, I feel you must finds champions and channel that energy that they have, and give them the opportunity to help other colleagues. I find nearly 100% of the time people do enjoy having that role. That's where you begin to get the opening co-operation and collaboration.

CJ WOLF: Yeah, I do, and as you’re talking I was remembering with your leadership rolling out the guiding principles in Texas for clinical trial billing, I see that's kind of what you're talking about. Rather than I say, “these are the rules,” we collaborated with experts at the health institutions who have expertise. And we helped them collectively, we arrived at these guiding principles which is where we wanted to end up anyway, but I think if you asked them about the journey they would have said…came up with a lot of these thoughts and ideas.

Larry Plutko : You’re absolutely right and thank you for reminding me of that, you can't rule by fear, you really have to be persuasive, you really have to be collaborative. And I know one of our great health science centers they were just doing marvelous things with regard to clinical trial enrollment and introduction software. I thought that was their lost and have you know we went there and gosh they spent the entire day with us demonstrating even the physicians where there demonstrating what they found and eventually we had invited other compliance staffs from the other organizations and eventually the University of California sent individuals to learn from them. So, I think that the harmonization, I think there's sort of cross fertilization, if I can use the term, that occurs whenever individuals have the opportunity to share breakthrough thinking and bright new systems.

CJ WOLF: Yea, that is another thing I learnt from you just by watching this at the higher education Consortium, so to speak, where we try to collaborate with partners in compliance and other institutions, not that we’re competing against them, right, you're using the strength of others to benefit everyone.

Larry Plutko : That’s correct, you know there’s another thing, too, something that I found very, very important we have a lot of compliance officers. I believe we had 17, we were the chief compliance officers of the institutions and we had a couple more organizations that were not universities themselves but they were portfolio management companies and what have you and you will see backgrounds and development of individuals greatly. And I think every now and then we get a call from somebody supervisory that they were a little with upset with this person and they needed to sharpen their skills. So I think that the compliance officer really has to be the mentor, very carefully, and very respectfully, you work with individuals that are new to the professions and do some simple scenario planning with regard to how to approach complicated issues. How are those matrix, how will we get buy in, what will work and what will not? So, what I found when you extend that type of assistance to individuals, they really do appreciate that. I had a bid for a company two years ago, they asked if I could do a long distance, which I did via a conference call ,and nurturing of the new compliance officer in the southern state and it just worked out fantastically, so I think the whole thing of mentoring is very important is the next generation of compliance officers steps up.

CJ WOLF: Well I can’t think of a better mentor than yourself, so I personally can testify that I appreciate your strengths there you mentioned. Sharing with our listeners who might be interested, you have open sessions with the board that are recorded at those if you are interested you might want to go to utsystem.edu to look up the Board of Regents. They'll have archives videos and power points and minutes in all sorts of things and you can look back in the years that Larry Plutko was there you'll see some great examples of him presenting and other colleagues presenting compliance topics. I think there are really good examples of how they work. The other thing Larry that I want to just if you could touch on this because you use to say it and I saw you do it, so occasionally you would have this conflict with an individual and you've tried all these proactive measures. But sometimes it's not going to work and you use the phrase to teach me once, you hold up a mirror and you just had a great way without coming off as combative, of holding up the mirror and I think what you meant by this is you are able for people so you're able to help reflect to people what they were saying, and what they were doing, and sometimes they could come to their own conclusions, you ever use that phrase?

Larry Plutko : Yeah, I do, and I think I still do it up to this day. I think that's important and I had a mentor many, many, many, years ago saying the same thing to me. I was just blowing up, going off on a tangent, just very upset, very angry and he said, “Larry let me just hold up the mirror this is not about you, but I want you to sort of look at the mirror here let’s pretend there is one, how do you think you're being perceived, how do you think people are looking at this,” and gosh you know, I stopped in my tracks. It was like a light bulb, a preverbal light bulb, going off and but again I think you know we have all these forces all this particular dynamics. And for heaven sakes, we know that people just have bad days. I think that's another thing to consider, that you know, we sort of climb the mountain so to speak…[29:43] and it roll down back on us it may very well be that we can do with a timeout and say, well let’s get back to this particular difficult topic next week, we can resume and maybe we can both think about it and I think invariably people do come around. And so I think compliance officers these days really have to have those specific skills. So one thing that I see occurring, if you let me, if I may say, is just how compliance officers are structuring for the future. You know more and more business units are taking on more accountability for compliance, okay whereas the compliance officers themselves are focusing on the enterprise wide compliance initiatives, so that is going to require a great deal of co-ordination. Budget and staffs are squeeze to the gills so how do we come up with ways of deploying a system of accountability across the organization so I think that demands from us an understanding that we’re moving from generally so to speak to individuals who are involve in compliance who are very comfortable with risk content for risk specific expertise, so that refinement and that complexity of the healthcare and healthcare delivery well compliance offices are also on that movement forward and I think that could be scary at the same time it's important type of skill and it takes tremendous planning for the future as the delivery system changes invariable, so that’s the bottom line.

CJ WOLF: Yeah, thank you for sharing, and I’m going to ask if you have any kind of last-minute are parting comments, but it's something that I take away from our time together, is humble yourselves to the strengths of others, as a really great principal and hold up the mirror. And it's like you said, the light bulb on for me, and then I try to use those phrases, I remember, and I try to use that as I go about my daily work, I really appreciate your expertise Larry Plutko it's great to connect again with wonderful friend and mentor. Any last-minute thoughts or comments before we close our podcast today?

Larry Plutko : I do you know we’re using incredible technology to have this morning chat CJ, when you think about it, we’re using to Internet, we’re using Skype for recording, we’re located in three different locations which is actually incredible. So you think, that is the future, that is the future of healthcare, compliance professionals are going to need to understand and I'll talk with the early doctors [33:02] of the new technologies that we have to be on point as far upstream as possible with new the technologies that obviously have compliance applications, otherwise, we’re going to be too late. So, you see what I’m saying, so I think that whole thing dealing with the compliance implications and doing that very early on and the sort of education that we need as well as sitting down with individuals who are persons in the technologies. We’re able to have compliance departments to be the very cutting edge where the healthcare system is going, and how the healthcare delivery system moving all future so I think that that inclusiveness that design in turn must be part and parcel of how compliance officer does his/her work today.

CJ WOLF: Great! Excellent, excellent parting comment, and very forward looking, and I think we all know in healthcare, even today, who knows what going to happen tomorrow with certain laws and regulations so we always have to be forward looking and you can't rest on what we've done in compliance twenty years ago or even two months ago necessarily. So Larry thanks again for your time your expertise in and really are grateful for your time.

Larry Plutko : Oh you’re welcome, I’m going to go off and have another cup of coffee, CJ.

CJ WOLF: That’s very good, enjoy! Our listeners, thank you for listening to this episode of compliance conversations, please tune in for our next episode. And as always, if you have suggestions of topics and speakers, I would love to hear them, thanks for listening have a great day!