Strategies for Building Trust and Driving Success in Compliance

In this episode, we welcomed Stacey Crudup, Chief Compliance Officer at The SEES Group, to share her insights on why building relationships with team members on the front lines of healthcare is essential in driving strong compliance programs.

Stacey's experience and practical advice shed light on the benefits of understanding the business, spending time with your internal teams, and creating value through compliance efforts.

Tune in to our new episode, “How Compliance Teams Can Build Trust to Accelerate Success,” to hear more about:

• • Stacey's journey into compliance from an IT background 
  • The importance of building relationships in the world of compliance 
  • Practical tips for embedding compliance into operations 
  • Overcoming obstacles in the process 
  • How to add value to your organization through compliance 

Stacey has unique expertise in recognizing the role of compliance in daily health care operations and communicating effectively with staff at all levels about the practical application of compliance principles. She is experienced in developing and executing organizational policies and procedures related to legal questions in the health care environment, compliance, and risk management. 

Interested in being a guest on the show? Email CJ directly here.

Episode Transcript

CJ: Welcome everybody to another episode of Compliance Conversations. I am CJ Wolf with Healthicity and I'm excited. I always say that I'm always excited because I always like meeting new people and hearing their stories. Our guest today is Stacey Crudup. Welcome, Stacey!  

Stacey: Thanks for having me, CJ. I'm excited to be with you.  

CJ: Really appreciate your time. I think we're going to talk about a very important topic, but before we kind of jump into that topic, I'd like to give you an opportunity to maybe share a little bit about yourself, what you're doing, you know, background professionally, those types of things if you like.  

Stacey: Sure! My name is Stacey Crudup. I'm the chief compliance officer for a company called The SEES Group, we're based here in Franklin, TN, and we are very narrowly focused on ophthalmology. So, single specialty practices and ASCs, and prior to my work here with The SEES Group, I was with a Nashville-based hospital operations company and was with that company I think in total for about 14 years. So, I have a quite lengthy history and helpful compliance, I guess I've been doing that since 2004, so that kind of gives you an idea.  

And like many of us, a lot of us, I think kind of segued into compliance from other areas and I actually was in IT before getting into healthcare compliance and had helped build out some custom databases and case management software for the Tennessee Supreme Court. Very, very circuitous path, probably to compliance, but some of the skill sets from my old job as a business analyst and database mapper kind of helped me and some of what I do on the day-to-day now. This is how I got here.  

CJ: Absolutely! And thank you for sharing that. We all come from different backgrounds like I come from a clinical background. I meet people who come from a legal background, accounting, auditing, right? and IT! And I'm seeing more and more folks that and that's a great skill set I think in compliance. It's kind of what I love about compliance; it's people from different backgrounds coming together, making a great team, and working through the issues.  

And that's actually kind of related to our topic today, we want to talk about embedding compliance into operations, which some of us do more of than others. There are reasons why you might do it. There are reasons why you might want to stay away from it and it can vary. And so, I thought this was a great topic, and I'm grateful that you're willing to talk a little bit about it. And then let's just start with why it would even be important if you have thoughts on that.  

Stacey: I think it can become important for a variety of reasons, but from a practical perspective, if you work in a smaller organization, I think compliance officers are called upon to wear just a myriad of hats and it's and it is imperative that you understand what others that you may be interacting with on a day-to-day basis are actually doing, what makes up their standard work and what duties and tasks are they carrying out that might have risk attached to them on a daily basis.  

And from another perspective and perhaps this is more personal, I actually like to get to know people on the frontline of operations. I think that sometimes compliance can have a bad rap. We can have a perception perhaps of being glorified police officers or sort of a negative connotation that when people see our names or our faces they want to run, but hopefully when you get out into the field where you're working in hospitals, clinics as I do, or ASCs as I do, just putting a name with a face and hopefully it's a smiling face can actually build some relationships.  

And I know that we talk or hear a lot of talk about relationship building and a lot of our compliance seminars, but I think we have to ask ourselves; "It's a great concept, but how are you actually doing it?" And I think just getting out there and letting them get to know you personally and see how you work is a great approach to doing that.  

And then lastly, as compliance officers, one of the things I think that we have to have is credibility. And in my experience, and this is something that I've had to continually work on, as you know, as compliance officers, we're constantly battling newly updated regulations, new rules, new regulations, new interpretations of existing rules. So, understanding all of the authorities is pertinent, but also having a flip side understanding of what is it mean if you're sitting in a front desk, or person's chair, and to actually implement that. So, if I'm, you know, sitting on some in some ivory tower, thinking you got to do this that or the other, It's not nearly as meaningful coming from me unless I have been sitting down with that front desk receptionist or doing patient intake and actually understanding what their job entails and once I have done that, they know that I understand what walking in their shoes and tails and so then they're going to give you a lot more respect. And I think what you do have to say, we'll have more credibility and weight when you have an occasion to say it.  

CJ: Those are all excellent points. And I having been around compliance for many years now, I think you hit on all the things I was thinking about as well. Like you said, just from a practical standpoint, you might have a smaller compliance department and you have to, right? But I've been in organizations where they've had large compliance departments and they've strategically made the decision to embed compliance into operations. We always say, at least we always think we say; "Compliance belongs to everybody. It's everybody's job, it's not the compliance officer's job. It's people on the frontline." What better way to make that true than to actually give them compliance responsibilities, right? and embedded it in.  

And I love what you said about relationships. I think you know from a compliance perspective, I gained more from developing good relationships than any sort of kind of mechanical or technical thing that I put in place. It was always like you just said, understanding what that person is faced with in operations. And learning what their day-to-day job is, you gain credibility by helping them find solutions, not being a roadblock. I love that, I think that's really good.  

I was at one organization that was a client of mine, as a large university and in the university setting, I think embedding compliance in operations is a little bit more common than I've seen. So, for example, like in the research entity, the compliance folks were hired, they actually belonged to the research department and then they had a dotted line into the compliance program. Now I know that there are different opinions on that, you know, dotted line versus solid line and those sorts of things. But sometimes it can work depending on the culture, the organization.  

Stacey: Indeed, yeah, I agree. Totally the culture. The culture, I think, is that unspoken element that can really make you or break you. It will either drive your success or perhaps present an obstacle. But culture is absolutely important.  

CJ: Yeah, absolutely. So, it sounds like you've done this before, so any tips or tactics on how somebody might succeed if they're thinking they want to embed some or a lot of their compliance functions into operations?  

Stacey: So, we can talk through kind of some broader tactics that I've used in the past and then get down into some more nitty gritty type things, so I'll speak most recently of my current position, I think as anyone coming into new compliance position, whether you're at an analyst or at even a Chief Compliance officer, well, you do have to initially just understand the business before you can get down into the deep weeds of operations, you do need to understand what are what's the mission of the business, where the strategic goals and strategic initiatives and if you can get access to it, which hopefully you do have access to it. You should understand what is the strategic plan for say the next 12 months, or the next five years because that's going to give you some insight into what is going to be happening in the different operational departments that are supporting those strategic goals and missions.  

And then one of the things that I had to do in my current position because I was coming from hospitals, and so it was a big change for me. It was actually a much more narrow role. Going into a single specialty physician practice world, and single-specialty ASCs. But I did learn there are specific risks that are involved in ophthalmology which is where I find myself now and so certainly before you go out and start sitting down with other team members understand the regulatory environment that you're living in now;  

What are the current issues? Are there current advisory opinions? Have you looked at the most recent rules, whether they're OPS? You know, make your position, fee schedule, HIPPA, OCR; gather everything that you can gather and it may even be in trade magazines or even the specialty boards where your docs are practicing.  

But understand you know kind of the rules of the road before you go out because the worst thing you can do is probably go out prematurely and not really know exactly what you're talking about. You don't want to do that, and then some of the things that I have tried to do and this is something I guess I learned years ago working at Ascension is certainly learn how to use the EMR yourself. You know, take good courses. I would say, you know, work with the EMR for about two weeks before you go out into the clinic for the hospitals so that you can have intelligent conversations with the folks that are out there actually doing the work, whether they're sitting at the front desk or they're a scribe or a tech or a nurse, you want to be able to follow the conversations that you're engaging with the folks on the front lines.  

And once you kind of giving yourself that education and something I've tried to practice is what I've referred to as high-risk department immersion. I know that sounds very lost and all it means is, you know, in any environment, you're going to know or likely you're going to know as a compliance officer; what departments are engaging in day-to-day tasks that are going to create the most amount of risk for the organization.  

So, once you identify those departments, then you go to specific locations that you can pick. When I have always worked, I've tried to go to either the larger clinics or at least high-volume clinics, high-volume ASCs so that I can see you know a lot of activity in a short span of time and shadow positions within each of those risk areas.  

I will say, you know, even recently certainly the No Surprises Act has been a challenge for I think smaller organizations to implement, but just being able to sit down with your front desk, in our case, we didn't have Centralized scheduling, and centralized insurance verification, but understanding something as simple as what tools are you using to meet good faith estimate requirements and are they even really working? Do you understand the time frames that are in place?  

So, constantly having to sit down and understand people's workflow and just really immerse yourself in their day-to-day and that could include even physician shadowing or surgical scheduling, you name it and it will, I don't think it will ever be a negative for you to sit down and spend time with the people who are the subject matter experts in those daily tasks so that that immersion, absolutely go ahead.  

CJ: I totally agree. And I actually want to maybe share a quick little example of that that I experienced, but I'm going to do this after our quick break that we're going to take. So, stick with us everybody and we'll be right back.  

Welcome back, everybody! We're talking about embedding compliance into operations and Stacey was just talking about shadowing and Stacey that reminded me early in my career, it was in a very large health system and did just that, we probably had 4 to 500 docs, and this doc was new in his profession. So, like he had just been out of residency a few years and it was E&M's, right? Evaluation and Management Coding and he was frustrated with the rules and the EMR, just like you said, know the EMR and went out and shadowed him and just learned what he was doing, and over the course of a little bit, a few days learned that he like, 80% of the patients he saw fell into three different buckets. And so, we helped him create templates that made sense for, you know, 80% of his patients, and then he still had to work on the others, but that was a big like, efficiency improvement for him. But we were involved from a compliance standpoint to also make sure it was being done for recording and so like you said it's rare that those types of investments of time and relationship building. It's rare that that's ever a negative. I've always found it to be a positive just like you have said.  

Stacey: Totally agree! We literally are going through something very similar. We have a practice in the US Virgin Islands and just recently converted them to an EMR and as we continue to work with them, just understanding their practice patterns, understanding their patient population and you know, population health really, we've been able to partner with them also and build out some templates that helped their processes and gave them faster throughput certainly, but also on the back end it keeps them compliant in terms of medical necessity and coding and billing regulations so totally, totally agree. I think there are so many levels of value that you can get from just spending that time and learning practice patterns, learning the EMR, and interfacing with the people actually doing the work.  

CJ: And I think in that case I would have to insist that I must do that type of shadowing and help in person since it's the Virgin Islands.  

Stacey: Exactly! Although I did have a phone call with an employee you have down there and they are expecting a hurricane service with them 

CJ: Oh yes, that's true.  

Stacey: But you do have to be strategic about when you when you travel to the island.  

CJ: Excellent point. I've been there, went during COVID actually it was a wonderful time to go, strangely enough. But we talked to a lot of the folks that live there and yes, like hurricanes and when power goes down, it goes down for a long time, lots of issues and things like that.  

Just a side note question, I know about Medicare Administrative Contractors, right? And how they are divided up regionally, you know and you always see all this MAC covers these states. I'm assuming there's a MAC that covers the Virgin Islands, the US Virgin Islands.  

Stacey: There is, it's First Coast, so they have both Florida, because we have clinics in Florida as well as the Virgin Islands. But you are always learning something, I had never known the rates in the Virgin Islands are different than the main ones, so that was an education point for me. But it is First Coast and I've actually was on the phone with them yesterday. Of course, we have Palmetto for our clinics in Tennessee, Alabama, and Georgia.  

CJ: Interesting! I just was curious, sorry about that little diversion, but I find it interesting. Let's continue maybe a little bit more. And what types of obstacles then do people face when they're trying to embed, you know, compliance into operations? What have you seen and what have you heard from maybe peers and colleagues too?  

Stacey: I think sometimes there is the perception and I understand why people have this perception. I think it's up to us to kind of be able to persuade people from this point of view, but I think that people often come to the table, especially if you haven't been involved in compliance programs before. But you can see them as unfunded mandates and basically, you're a cost center, you're not adding value. We aren't revenue producing, certainly what I would say is that we are very good at revenue capture, and I think something, you know, the templates, that's an excellent example of revenue capture. You're not allowing denials to go out the door. You're being able to prove that things are medically necessary.  

CJ: Right!  

Stacey: So being able to articulate and persuade your case that you are not just a cost center that you can actually add value to the organization I think is just incredibly imperative and so we try to do that through a number of KPIs, I sit on the denials committee here. I've done it before in larger institutions and being able to quantify dollars that might have been overturned on appeal or captured and overturning denials as it were. And then the other piece on the front end is just making sure this was something that I had never seen before or encountered, so this is a learning experience for me too, it's making sure that whatever department or business segment that you are working with understands how to know that it has done its charge capture completely. 

CJ: Right!  

Stacey: Do they have a reconciliation process? So that has been interesting in a smaller organization and helping to build out those structures. So, I'm thinking between coding audits that we also manage in my department, making sure that we're capturing things there helping with charge reconciliation and capture denials, management appeal, appealing, overturned denials, those things all can prove your worth. And then certainly when I was even interviewing for this job, I always think of compliance risk in terms of a heat map, and in my opinion, the two top issues they're always going to be facing healthcare companies are the billing and coding piece which we've talked about, but also potential referral source relationships and those financial arrangements.  

CJ: Right!  

Stacey: And helping people understand what the fines are, or can they? If you don't have compliant financial arrangements with potential referral sources, certainly it's even gone up recently they're starting at what, 11,000 to 22 grand, I think for civil monetary penalties per claim. 

CJ: That's right.  

Stacey: So, having that number handy! And being able to help folks understand through good leadership and executive education what the ramifications are under start AKS and certainly the False Claims Act as we're seeing more and more enforcement around those. I think once you begin to paint that picture, you can overcome a lot of obstacles who may have been there, and I would say that's true from the frontline team all the way up to your executive team and maybe even boards of director member.  

CJ: Yeah, those are all I think really good things to kind of watch out for obstacles you might face. I'm curious if you've ever heard or seen of this. So, as I work with clients they ask; "Can you come evaluate our compliance program? Can you help us design the compliance program?" And there are many ways to skin that cat, and when I bring up kind of embedding certain functions into operations, some of the compliance folks get nervous and they say well, but will they really look at it from a compliance perspective or will they only look at it from an operations perspective, right? Will they really be that police, that you know, and I try to stay a word from stay away from trying to be seen as the police, but some compliance folks really want that.  

Have you heard that or run into that, concerns about the operations folks, maybe not knowing compliance well enough or not having the right appetite to report things and that kind of stuff?  

Stacey: Absolutely, yes! And I think that's been historically present in every one of my roles, I think it probably comes in ebbs and flows, but I think that's something that you always are going to have to contend with and something that I've used beneficially in the past is, in my opinion, a lot of what we do is compliance professionals can be seen in the prism of performance improvement.  

CJ: Right!  

Stacey: And as you know, most operations folks are very concerned with how do we do things faster and better and less cost? And so a lot of times I will frame my conversations in the terms of performance improvement.  

CJ: That's right, exactly. 

Stacey: And that is how a lot of times I've been able to get my end. We're dealing with that even now with, we have a large retina practice, and this year in the past year we've had a lot 3 brand new drugs that have come out to treat retina disorders, and some of them were not assigned J–Code for some time.  

CJ: Oh boy! 

Stacey: And so, we didn't realize that some of our physicians were already using some of these drugs and we're billing non-specific codes and others not getting paid.  

CJ: Right! 

Stacey: So, we were able to go back and get buy-in on, you know, we need to approach these new drugs differently. It behooves all of us to get paid for what we do. And so let's build out a new services process. So, that will include not only the physician not only the billing faults, but make sure that we've got, you know, the payer relations people. Are we even covered under contracts? Do we know how to get pre-asked for this at the insurance verification stage?  

So, we've been able to not only get us compliant with some of the LCDs surrounding these drugs but also get people on board because they understand that by having a process, we're actually going to get paid and get to keep the money that we earned through billing and providing the service. So, I always try to come at it from maybe a PI perspective up to get the operations on board.  

CJ: Yeah, that's such a great idea and it's really what you've been kind of telling us all along is understand the business, understand the people you're dealing with, how they see life, how they see work and those sorts of things.  

Stacey: Right!  

CJ: Stacey, we're kind of coming up to the end of our time and it's been a pleasure talking to you. I always allow our guests kind of the last word and see if they have any kind of last-minute thoughts or advice or favorite book, favorite movie, whatever! Any last words?  

Stacey: My famous last words are I still go back to relationship building, I think it's important to not only build relationships with the folks on the front lines, but I can't say enough for the people who work with me on it on a daily basis. I've always said if you say that you're a leader, but then you look over your shoulder and no one is following then you may be in trouble.  

But when I think about relationship building just always put some personal value and let people know that you would love to help them personally, you want to help their personal growth and be sincere in those interactions and I think that will help you not only from a compliance perspective but certainly just as personal growth because you never know when you're going to see those people again in the future that would probably be my parting shot.  

CJ: That's right. Yeah, great advice, and I echo it. I've experienced that myself and so thank you so much, Stacey for your time, sharing your insights and expertise today.  

Stacey: Thank you for having me! Have a great one.  

CJ: Absolutely! And thank you all to our listeners for taking the time to listen to this episode. I always invite our listeners to send in ideas. Do you know of other guests that you think would be good guests? Topic ideas we'd love to hear it and if you are enjoying these please share these podcasts with friends like and subscribe, do all those good things and we wish you a very good day and happy compliance to you. Thanks, everyone!