Podcast: What it’s Like to be a New Compliance Professional

I recently spoke with Brooklyn Trumpy on what it’s like to be new to compliance. Trumpy graduated in 2009 with a degree in Operations Management and ended up in compliance five years ago when she took a role at Community Health Systems and worked her way into a compliance role.

Trumpy found that being new to compliance was a challenge. She explained how it can be intimidating to learn all of the new rules and regulations and how to piece together the puzzle that is compliance. She initially struggled to make connections and find her tribe within Compliance and it took some time to learn how to stay organized. Trumpy had some expert advice for new compliance professionals that will help them have an easier transition into the world of compliance.

Tune into my newest episode of Compliance Conversations, Tips for When You’re the New Kid on the Compliance Block, to learn which personality types are drawn to compliance in the first place, how to set expectations as a new compliance professional, and why it's okay not to know everything right out of the gate.

Episode Transcript

Hello everybody, this is CJ Wolf from Healthicity. I am Healthicity’s Sr. Compliance Executive, and welcome to another episode of Compliance Conversations. I am live from Anaheim, California. I’m at the AAPC’s regional conference where I’ll be speaking and we’re going to be recording a broadcast for you, I hope you enjoy this broadcast, we think it’s a good broadcast and a timely one. Today our guest is Brooklyn Trumpy. Welcome, Brooklyn.

Brooklyn: Hi, thank you, glad to be here.

CJ: Thanks for taking some time. When I was speaking with Brooklyn and communicating with her, maybe a month or two ago, we talked about what it’s like to be new in compliance. That’s what we’re going to talk a little bit about today, but before we get into that discussion I wanted to give Brooklyn a chance to give a little bit of her background, where she is coming from professionally. Brooklyn, would you mind taking a minute to share a little bit about yourself?

Brooklyn: Sure. I graduated from college as an adult in 2009 with a degree in Operations Management. So, I’m still not sure what got me into compliance, it’s been kind of an interesting ride. I’ve worked in healthcare since graduating. I worked in a lab for 10 years before graduating from school. I jumped from mostly careers or jobs as an analyst. I worked with EPIC with UW hospital, and I also worked with EPIC at Rockford Health Systems and did a stint in project management for a dairy company that I worked for. So, I had kind of been all over the place, and then five years ago took a role with Community Health Systems, working with their systems. Somehow jumped into that role, then made my way up into the Compliance Officer role a year and a half to two years ago.

CJ: Thank you. You mentioned this, that squiggly line of how you get to, I don’t think any of us really planned a career in compliance. I grew up thinking I was going to be a fireman or policeman or something, wanting to grow up and be a Compliance Officer is kind of a strange thing. I think what’s interesting in compliance is that I meet people from a lot of different backgrounds. So, I am always interested in what brought people on their path to compliance, what interests them and that sort of thing. You have a great background with being an analyst and project management, those are all great skills for a Compliance Officer. What do you think what attracts professions from all different backgrounds? I’ve seen people from clinical, from legal, from a financial and auditing background. You’ve got operations and project management. So, all these different backgrounds, what do you think attracts people to compliance from all different backgrounds?

Brooklyn: I think there is more so than their background, it’s more of a personality type that brings people to compliance. I mean, we’re the rule followers, right? We see things in black and white, we want to find clarity where there are muddled borders. We’re the kind of people that like those lines, that want all the ducks in a row. Those Type A personalities get very attracted to compliance because it’s more organized chaos; we have those lines we place. I was the oldest of five kids, so I’m used to bossing people around already.

CJ: That’s a good point, it’s more personality. I think I agree with you. We all come from these different backgrounds. Obviously it’s not a background that makes it work. It could be many different backgrounds that make it work. I think you’re right, it’s personality type. There is a lot of compliance that is not always clear, I wonder if that frustrates some of the personality types that like those black and white lines. You mentioned organized chaos, because it is a little bit of that. How do you take these personality types and reconcile the order and clarity but some of this chaotic?

Brooklyn: I think it becomes our role to provide clarity to that chaos, right? There are always going to be laws, or other rules that come from other regulatory agencies, and our role is to take all those different pieces and create something that makes it easy for everybody else to follow. If we’re able to pull those pieces together and say this is where the black is, this is where the white is, this is where we fall on the side of the line, it makes it easier for all our employees to do the right thing because it’s not so "iffy" as to what the right thing is. And most people, most of our employees, are very, they want to do the right thing, they just don’t know what that is. So, if you can give them that clarity, it makes a big difference to them.

CJ: That is so true, I was just talking to somebody the other day about compliance and they asked me what I liked about it, because it seems so strange to like a career in compliance, and I told them exactly what you just said. I love to teach, and I love taking complex things and making it simple for people. I explained my answer from a clinical background. I know what the doctors are doing and how busy they are, and the mission of most healthcare organizations is to supply some sort of excellent care for patients. And doctors didn’t go to medical school to learn all these compliance rules. I try to do what you just said, try to take something complex and apply some sort of clarity to people who want to do the right thing, they just know that, you know, there are all these rules and regulations. And it’s not always easy to sift through that, and if we can sift through that and pick out the pertinent pieces we can provide training or guidance in a more clear way. I find that very satisfying.

Brooklyn: And I agree with that. We over the recent years have implemented some encrypted emails and other things to help our employees better communicate with other organizations and I know it was really difficult for them for a while because we had 2 users from our entire organizations that could send encrypted emails. So we were constantly evaluating if we needed to send this in an encrypted matter or if I could send it just normal, does it matter, does it need to be secured? They had to go through this whole thought process every time, and it was very frustrating for them because they didn’t always know the right way to do things. Now, one, our email will automatically encrypt if there are certain pieces of information in it, so they have backup protection, but they also can just hist secure themselves and it’s done. It’s all about making it easier for our end users, so that they don’t need to know all these sticky compliance things, because they know if they do this it will be fine.

CJ: Yeah, that’s so great, I love the way you put that. You’re coming from, you’re obviously well trained, well educated in other kind of areas. You’re relatively new to compliance. You mentioned to the last couple years as a Compliance Officer. With that perspective, having worked professionally for a while in a newer role, what are some of the top challenges for someone that might be just two years behind you? They’ve worked professionally in other fields and they have proven themselves with great skill, so they’ve been asked to take on compliance because no one else usually wants it. But people recognized that person has skills but they are new to the field of compliance. What kind of tough challenges did you face, or you think people in those circumstances face?

Brooklyn: I think there are a few. The biggest issue or challenge that I faced when I first started out was trying to reconcile all the different regulatory agencies, all the different pieces of compliance that needed to meet and making them work together. Because some of them just don’t fit. You’ve got one organization that tells you to do things this way, you have somebody else that says you need to do them that way but you also need to do X, Y, and Z, you have another that says kind of, but don’t do X, and Y, in this way, do it in this way, and nobody tells you how to do it, they just tell you what you need to do. Trying to pull all those regulatory agencies, all those different pieces together, and melding them to something that is actionable is difficult. I think the other big thing for me was "you don’t know what you don’t know." There’s that thing where someone comes in and says, "Are you doing this? Because this is what this is supposed to be." And you go, “I didn’t even know that was a thing! I had no idea I needed to be following this because I didn’t see any information about it," and not feeling you’re doing a terrible job and that things come up. That comes up for everybody for every task that you walk, you just don’t know. You’re going to be learning new things every day, and that it is okay, you’ll get there at some point. You’ll never know all the things, there isn’t anybody that knows all the things.

CJ: That’s right. The other thing. I think, and I’ve hopped around a little bit in compliance roles, it’s not even the same at a new organization. For example, if you go from one state. I remember I was at one organization in Utah and then went to Texas, a lot of the billing and compliance rules that I was responsible were similar at the fed or national level, but at the state level they were totally different. You might have a Medicaid agency interpret something different and add different policies or rules. I just remember feeling comfortable in certain things, there was new information to learn like you were saying. These competing agencies and reconciling priority, which one is top priority, and sometimes they are all equal priority, so you need to make them all work. I think that’s what fun with compliance is learning that new body of language, or body of knowledge.

Brooklyn: A big old puzzle you get to put together.

CJ: Exactly, and it really is satisfying when you get some of those pieces to fit. Any other challenges that you can think of?

Brooklyn: Yeah, I mean everything. Just making connections and being able to find the people that are supposed to be there to help you out. That can be challenging sometimes, because trying to call anybody at CMS, trying to call HERSA, and getting in touch with the right person at those organizations can be a real difficult thing at times. If you’ve got people that have already made those inroads to you, that’s helpful if you can reach out to them. It’s an interesting field to jump into. Organizing everything that you’re working on and being reminded that I must remember in three months from now I need to check on this again to make sure we’re still good. I need to make sure our word composition is correct every 6 months, or however your organization chooses to do that. That’s the other piece too, when it comes to audits, and it comes to looking at yourself internally, and making sure that you’re doing things the way that you should be. There is nobody saying you should look internally every 3 months to make sure you’re really meeting this. For instance, word composition, I set up something to check every 6 months to make sure that we are still okay, that all our board members have been seen within the last 2 years, that we are still in compliance with our board composition. I never really had a reason to set up a task in outlook to make sure I was checking that. There was no great way for me to go through all my line items to make sure everything was checked off. Until now! And now I’m much happier, but it’s a challenge to try to keep track of all that.

CJ: I remember one challenge too, and I’ve talked to some other people that were relatively new to compliance or maybe in a new organization, people are testing the waters with you. Internally I’m talking about now, there’s obviously these external pressures, agencies and enforcements, just internally here’s a new compliance person, are they going to be cooperative, are they going to be a hall monitor. So kind of setting that reputation and earning that reputation as someone who is cooperative in the business and not put the business on hold, but rather guiding people through complex regulation, but also taking a stand if you need to. I just always remember in almost every organization I’ve worked in, the first time I’ve had to take a real stand, you can’t make everything a huge battle but there are times you just have to take a stand. So that, I’ve always found, to be challenging for me.

Brooklyn: Yeah, and it’s an uncomfortable position to be in. Especially if you’re up against someone that is higher up in the organization, and you’re saying something that is very unpopular with them. For the most part I think, as long as you can say what you need to say in a calm and collected manner, this is why I feel this way, this is what the law says, this is why I’m drawing this line. Then people are generally responsive to that. It’s also, being able to take those stands when you need to but being approachable enough that people will bring you concerns, and not being afraid of getting in trouble so to speak. We had some of those issues come up lately. It’s felt nice to me, because we have people that will come to me with concerns, and say we have this going on I feel this isn’t quite the way that it should be handled, can you help us? And instead of me saying “Uh, yeah, no you’re all being written up for this”. It’s okay, let’s work together, this is not the way we should be doing this. Let’s figure out a way for us to do this so it ends in compliance and we’re doing things by the regulations, and then write this up so we have it all documented so going forward this is how this is going to work. I think people have been responsive to that. Any risk management kinds of thing, people are not willing to talk to anyone about it because they are afraid of getting into trouble, you’re going to end up with safety risks that you didn’t even know you have. You’ve got to keep those doors of communication open.

CJ: What you just described, and you said it there at the end, you described one of those seven elements of an effective compliance program, which is open communication. When people trust you enough then they can bring you things. It’s always important to have an anonymous hotline, but I’ve always found there is a measure of progress when people are bringing them to you personally. Bringing you issues, they are starting to trust you, and just like you said you are there to help them find a solution, and not write someone up. Of course, if there are major violations you have disciplinary actions, but what you just described is an effective communication pattern, so I appreciate you sharing that. One of the things I want to ask you, so now we’ve asked what those challenges were, now that you are a couple of years into this as a compliance officer, having come from other professional backgrounds, what advice would you give somebody that you wish you would have received at the time maybe 2 years ago. What 2 or 3 things if there are that may, in advice, that would have really helped you.

Brooklyn: I think there are a lot of professional organizations out there, I feel like there is almost too much information. So you can go do research on something and you’ll find 50 different resources to look at, and I actually, sadly, am a little disappointed in myself, but I found that the best way, for instance, the HIPAA guidelines that everybody needs to follow, I actually go back to the letter of the law, I don’t go to other people any more. There are so many ways to interpret things, that if I am trying to figure something out, I am always going right back to the law’s in front of me, because I know what I’m following what it says. Yes, there might be some interpretive guidance that says whatever, but generally what I’m finding isn’t from the law makers themselves, it’s from joe shchmo who knows what he’s talking about, kind of. I like to have the actual law sitting down in front of me. The other piece is that you have to make those connections, those professional organizations that really do have a lot of the information. For instance, I work with HIPAA COW, the HIPAA collaborative of Wisconsin, and they pull together all of that information, both the state and federal regulation, and give you a lot of information about policy templates, and other sorts of resources that help you to get everything together in your organization. There are certain organizations like that all over, that will help with certain pieces of information. So, it’s finding those organizations that are really beneficial, and can help you pull all of that information in a more useable format, and then going back to the actual legislation itself, and saying okay what does it say exactly. Sometimes that helps you to lean one way or another in a decision you need to make.

CJ: Yeah, that is such great advice. Especially going back to the legislation. Frequently I’ve been in meetings where people say I want to see what the law or regulation says. I think it’s good to get other peoples take and perspective, when I get that from people, mainly so that I’m looking from both sides of something, so that I’m not missing something. I like to kind of get all these, you know, sometimes varying opinions. I just don’t take those opinions as a letter of the law, but I use them to say maybe this is what they are getting at, and like you just said you go back to the law and regulation, that’s usually what you would be interpreting anyway.

Brooklyn: When you look at who we’re working with, we’re working in healthcare. They are use to evidence based practice. You back up whatever opinion you have with fact, so they really respond well with. If I can copy and paste a bit of legislation in the email or document I’m putting together for them, it’s much more meaningful and they understand. This isn’t just our compliance officer making stuff up again, she’s actually quoting the law that is in place, and I think that’s been really beneficial, especially when it comes to provider level. I have a dentist that specifically requested the legislation from me in the past, I want to see where it says that, I’ve never heard that, and I was able to pull it out and show him, and he was more willing to work with me on that item, because he knew I wasn’t just making it up, I really do have a paper that is telling me we have got to do this. He was then much more agreeable.

CJ: Oh that’s such a great point, and I’m glad you brought up on another point, that HIPAA COW, and I know it’s specific to Wisconsin, but a lot of it is applicable because a lot of it is federal. I know a lot of people that have used that as a great starting point, reference point, that’s just a great example of the resources that are out there, so I’m glad you brought that up. I also rely a lot of some other professional organizations, and they can be helpful, again not that you just take what they say as a final answer, but at least it can sometimes help you from recreating the wheel. If somebody has already worked though all of this, maybe you can take some of that information that is 80% or 90% and you can adjust the rest specific to your state or organization, I appreciate you mentioning that. Well this has been a great conversation, I really appreciate your time, I wanted to see if you had any last-minute parting thoughts or comments on this topic, I think it’s refreshing, because I think a lot of our listeners are in a similar situation, and it’s great to hear from somebody making it work. I think just the moral support that people are doing it and they are relatively new. I just get calls from people all the time that are an expert in finance or an expert in this or that, but they’ve gotten a new job in compliance and I usually tell them, first of all congratulations, that means the people around you think you can take a complex thing and make it work. That doesn’t make them feel better, but because they’ve been doing a good job in one area now they are being asked to do a good job in another, so I think it’s a compliment most of the time, but do you have any parting thoughts for those types of people who might be listening to the podcast.

Brooklyn: Just that I think as a compliance team, all of us together, it really is, and I think everybody goes about compliance a little bit differently, and I think it is because we are all coming from different backgrounds, I come from kind of an IS background, some of the compliance professionals come from a finance background, I lean more on my finance director to do the compliance on that side because I don’t have that knowledge. On the IT side, IS side, I work with our IT team and do those pieces, but we’re all kind of doing different pieces of the same job. Being able to reach out to one another and having that really great community of people to lean on if you don’t know the answer is kind of the most beneficially thing you can do. Being able to have people that can come to you and having people that you can come to is phenomenal. I worked for an FQHC, coming from an FQ where you wear multiple hats, so I’m not only doing compliance, I still manage our IT, I still do quality pieces, I’m still calling our reporting. It’s easy to get overwhelmed. Don’t let yourself do that. You can only do one piece at a time, and eventually it will all get done, but there is always going to be more on top of it. You know, just do the best that you can with what you have and reach out to the resources that you have. As new compliance professionals, I think that is how you get through.

CJ: Great advice Brooklyn, thank you so much for your time.

Brooklyn: Yes, thank you.

CJ: Yes, we really appreciate it Brooklyn, and thanks for our listeners for listening to another episode, stay tuned, we’ll talk again in our next episode of Compliance Conversations, have a great day.