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Episode 42:
Pathways to Compliance: What Happens Once You’ve Got the Job?

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Are You Considering a Healthcare Compliance Career?

I recently sat down with my fellow compliance professional and friend, Brian Burton, to continue our chat about all things compliance careers. This episode of Compliance Conversations is part two of a six-part “Pathways to Compliance” series. In this series, we get into the thick of it and share our personal stories (some embarrassing, some not) along with tips and tricks on everything from certification and interviewing for a job to salary expectations and how to ask for a raise. In the last episode, we talked about how folks find their way to compliance. In this episode, we’re chatting about what happens once you find yourself working in compliance as an entry-level employee or a lifer with an established career.

What do those first few days as a new compliance officer look like? How do you interview for a compliance job? How do you negotiate for a higher salary, and what are some things you’ve learned along the way?

Learn what it’s like to work in compliance from two experienced compliance experts who somehow stumbled into the compliance careers they love. If you’re thinking about changing jobs in healthcare, or you’re just a compliance professional who wants to nod in solidarity on your way to work, you’re going to love this series.

Tune in to the most recent episode of Compliance Conversations with CJ Wolf, MD, “Pathways to Compliance: What Happens Once You’ve Got the Job?” for a lively and educational chat on what to do once you find yourself in compliance. This episode is for folks just beginning their journey and folks who have been at it for a while. In this episode, we cover:

  • How to Prepare for Healthcare Compliance Job Interviews
  • Salary Expectations and Asking for More
  • Personal Stories About Starting and Lessons Learned

 

Interested in being a guest on the show? Email CJ here at cj.wolf@healthicity.com.

Episode Transcript

CJ: Welcome everybody to another episode of Compliance Conversations. I am CJ Wolf and I have my wonderful friend and guest Brian Burton with us, hi Brian.

Brian: Good morning and good afternoon and evening to those who are listening all over the world and at any time of day.

CJ: That’s right people are hopefully listening to this when they are driving, walking whatever, doing those fun things [laughs]. Today we wanted to talk about compliance careers. Entry-level, established, those sorts of things. Brian and I just came back from the ACCA in Phoenix. I met a lot of interesting people. I love those in-person conferences because you get to meet people. I met people who were mid-career professionally but they’re switching into compliance so they’re first-time compliance officers. I also met a lot of people who were just coming out of college that want to go into compliance. We’re seeing a little bit more of that. In our other podcast, we’ve talked about how people come into compliance and those sorts of things so they come from all sorts of backgrounds. But we thought it might be fun to talk about those first few days, those first few jobs in compliance, and what we experienced and hopefully that will be useful to you.

Brian: Yeah and with that thought in mind CJ if you could tell us a little about your experience. I know you have this wonderful background of starting as a physician, working in the clinical space, and then transitioning into compliance.

Question: What was that like for you?

CJ: You know it was really interesting. A lot of people ask well, how did you go from medical school into compliance? I loved medical school, taught me so many great things and I don’t regret doing that at all. As I moved into the medical profession I realized that I didn’t really love the direct patient care but I loved healthcare and working in the healthcare space so I transitioned from that medical path into, starting really with coding and billing and trying to teach doctors about documentation in coding and billing. So I remember my first kind of compliance job, I was still learning myself so I was hired to teach doctors about compliance and I had to learn it myself and that was a little daunting but I had confidence in my ability to learn and I loved learning. Some of the core skills I had of being able to teach and explain and those sorts of things I think really lent to learning a new subject area and then teaching.

Brian: That’s really awesome. I wish we had a full-blown couple of hours; I’d love to hear about all of those experiences one day. You mentioned starting off and having to learn compliance yourself.

Question: What kind of resources did you find at that time and then what would you recommend today?

CJ: Yeah, fortunately for me, I had an amazing mentor and she just took me under her wing. She had been in the field for twenty (20) years or so and she just took me under her wing and just taught me. I think if you’re early in a career in compliance or maybe you’re thinking about getting into a career in compliance. Maybe you come from a nursing background. We talked about this in the other podcast. Technical background, whatever auditing, legal, whatever your background is that leads you to compliance or maybe you are straight out of school. I think finding a mentor is really important. Fortunately, my mentor was my supervisor. So I had this amazing person and then I had team members so I had one team member who had worked for Medicare. Now we were in a hospital system and he was working in the hospital system too and so I was bugging him all the time. I’m sure he was like dude, enough questions. He never said that but I was always asking questions. Kind of to your point I think it’s really important to be asking questions, finding a mentor if you can, and really working that people angle. I think finding a mentor is a good way to do that at conferences, meeting people, and co-present with someone. I’ve had people who reached out to me and said, “You have this kind of background, I have this kind of background. Let’s talk a little bit and find out if we might be good co-presenters. Now we’ve, you and I, have presented and now we’re friends and colleagues and colleagues in compliance so I think there are all kinds of opportunities like that.

Brian: Yeah that’s so interesting because I think we talked about this a little bit in the last podcast as well. I had a very similar experience. It was the mentorship I had with my supervisor, the chief compliance officer at my first compliance job was so instrumental to my career in compliance itself. To your point, she was really interested in helping me learn and grow and then we had a team of people, a team of experts that were in various fields doing different things or different areas of compliance. I think if I were talking to a new compliance professional I would say be a sponge, and build as many friendships and professional relationships as possible with a varying degree of experts.

CJ: Absolutely and you talked about this last time too and once you’re kind of mid to later career, we need to be giving back and we need to be helping others so you let that cycle repeat and that’s one of the things I’ve really enjoyed in my compliance career is watching some of the folks that I hired initially, maybe they didn’t have a full compliance background bit I helped shape that with their initiative and that’s really rewarding I think. Brian: I couldn’t agree more. There are several individuals that come to mind for me because I’m nowhere near as experienced as you are but I give myself that mid-career category, twelve [12] or thirteen [13] years in compliance and there’s been a number of new team members that we’ve had that are right out of college or new to compliance and it’s really, it’s one of the things I loved about coaching youth sports, you watch that development grow and as they start to ask more questions and they start to build that experience and one of the best signs for me is when they challenge you with a question  you don’t know the answer to.  That’s when you know you’ve really helped them and mature.

CJ: Exactly, and you know your question you asked about my first compliance job. So when I was starting I was a compliance consultant. You don’t typically start off as a compliance officer, right? Unless you’re mid-career maybe in something else and they’re asking you to transition. But if you’re younger that’s not usually where you start and I also wanted to answer your question for the first time I was hired as a chief compliance officer. So I had already had fifteen [15] years of compliance experience but now I was in charge of the whole program and that was a little bit different. During the interview for example, because I had some knowledge now on compliance and I knew, I’d been in a couple of different organizations, I knew what cultures lent themselves to compliance better than others and so I was brand new to this organization I was interviewing with, didn’t know their culture really well, and some of the questions that I asked were very pointed because you want it to be a good fit. I asked questions like if we discovered, you know you are asking me to set up this compliance program, if I discovered an overpayment of some kind what would your response be? If I bring to you a problem where we’ve worked through it and we owe a million dollars in a repayment, what’s your response going to be? And that’s before I got hired. I want to hear because that’s my job. I’m coming in to help you find issues and when we find issues are we going to do the right thing that’s a hypothetical. They give you their hypothetical answer and you hope that will be true if you ever come across it but I think asking those kinds of questions upfront. Who will I be reporting to? I am going to report to the chief legal officer? The OIG, corporate integrity agreements say that should not be the case you should be reporting to the CEO and the board. So, things like that, asking probing questions during the interview.

Question: Have you ever had an experience like that or have you had to ask?

Brian: Well, a little bit. To be perfectly frank and honest this is my first chief compliance position. I’ve worked in a couple of large health systems as a significant contributor, director, and corporate compliance and led and managed several programs at local hospitals, but this is the first I’ve been in this role here with Healthicity and it is, it’s a different hat. And I asked some similar questions and while Healthicity, we’re not necessarily involved in the payment process but we do advise our clients through our advisory services work. But it is, I talked to our clients all the time, it’s about establishing that relationship, understanding what the rapport needs to be, how does your organization manage those significant issues, who are the key players because it’s a tough job to be in compliance right? We’re a cost center most of the time, we’re not revenue-generating and when we’re doing our job really well, most of the time we’re finding some issues, right?

CJ: Exactly.

Brian: That results in more expenditures and it’s a tough position to be in and so establishing those relationships with key people inside your organization, the finance team, your leadership team, the board, the CEO, and however the organization chooses to align with compliance, it varies. And to your point, CIAs, and I can tell you from personal experience, it’s always better to have reported up through the chief executive officer and the board because you want that, you want the ability and the autonomy to execute the compliance program effectively and no fault to any CFO in the world but their job is to protect the revenue of the organization right?

CJ: Right. Same with legal officers, their job, and the corporation is their client. They have legal obligations to protect that client to do certain things and this is not to say you don’t work collaboratively with legal. I always had a pretty collaborative relationship with most legal departments. You’re not saying you need to be in contention with these other departments. If you as an organization want a truly effective compliance program these are the principles. If you want window dressing, if you’re just looking to check some boxes that is a different approach, I’m probably not the best fit for that type of organization, good luck to you, thank you for interviewing me, and I wish you all the luck in the world. And each person is going to have a different take on that fit feeling right? So we’re doing the podcast to try to help people who are trying to get into compliance. Those are some of the things that if I were interviewing today, regardless of whether it’s the chief compliance officer or a compliance position, I would just ask some of those questions and you don’t want to get into details because they’re not necessarily going to report some things but you want to probe is the answer.

Brian: Yeah I agree, and we talked about overpayments but sometimes too it’s good to ask those same probing questions. What’s the normal process for managing really complex or sensitive issues, right? A lot of time we get brought into HR-related matters that deal with harassment or a hostile work environment. How does the organization handle that when it’s a physician or member of the leadership team? Understanding those complexities and how, or has the organization experienced those before and so you as an interview candidate can get a sense of what is the environment like, what is the culture? What is my working relationship going to be like with this leadership team?

CJ: Yeah, but let me ask you, let’s flip it a little bit. You and I have both hired people in compliance roles, right? So we were the hiring managers.

Question: Those who are listening might be interested in what are interviewers interested in knowing?

Think about that and I’ll answer that question first. So when I was interviewing for compliance I wasn’t interested so much in, and this is maybe more my management style, I’m interested more in the core of the person. It’s like I can teach you coding, I can teach you billing, I can teach you HIPAA regulations, I can teach you this and that. I want to know what to know what your core ethical beliefs are, how you deal with conflict. Of course, I want someone who has experience in compliance but if I have a pool of applicants, to me I sometimes weigh heavier on the ability to solve problems, communicate, research to learn, because you and I both know you come into a compliance role with some information but that doesn’t, some knowledge but you must often learn new knowledge. I don’t’ think there is a compliance person in some role that hasn’t had to research something new. So how do you deal with that, how do you deliver a message that could be we’re doing something that we shouldn’t be or we’re potentially out of compliance and those sorts of things. So people listening who are wanting to interview with compliance officers or compliance people hiring those are some of the things that I think are important when I’m interviewing.

Question: What are your key things?

Brian: I think we are really closely aligned; I’m looking for interpersonal and behavioral activities. So my interview process has been really extensive and the past and most recently too. I’m looking for someone who can be dynamic, who can practice active listening and can manage difficult scenarios with different types of personalities because as compliance professionals we’re going to talk to all levels of the organization. From the very top of the board all the way down to our frontline staff providing care or maintaining facilities. We have to be able to communicate with everyone. And as natural human beings, there are varying personalities and as a compliance professional you almost need to have those expert communication skills but not just communicating out but the ability to listen and understand. Understand what nonverbal cues are; understand people’s body language and how they’re communicating because we can go from helping someone navigate a difficult situation, employee interactions, to conducting a very thorough interview process where you’re trying to determine whether someone can be honest with you in the interview process. So to your point, we are looking for people who are actively seeking opportunities to learn and grow and they want to be that sponge. I think I made that reference earlier. If you’re going to be a compliance professional you really need to go into the profession knowing things are always changing, it’s a never-ending learning opportunity and then you must be able to digest that information, effectively communicate and then actively listen.

CJ: Yeah so let’s say we hired this person, we’ve done our interviewing and we’ve found somebody. Let’s say they’re kind of early career and they’re kind of new to compliance.

Question: What resources would you ask them to rely upon because being a sponge they need some liquid to soak up? Where do they get that liquid?

  • Is it certain conferences; is it certain certifications, or certain free resources that you’ve found?
  • What kinds of things for people that are new to compliance do you think are useful?

Brian: The number one resource, and they’re not compensating us for this, but the number one resource is that HCCA. Becoming a member of that community, and finding other like-minded individuals who are focused on learning and growing in compliance is my number one resource. Number two [2] is twofold. If you are new to compliance go to the DOJ website, find a recent corporate integrity agreement, and as long as they are, if you are really interested in being a compliance professional read two [2] or three [3] of those in their entirety. Study them, make notes, ask questions, and then find another compliance professional whom you can ask your questions about that corporate integrity agreement. For someone who is considering that as a job I think that’s a really good exercise to be familiar with how does the government enforce compliance and then, is this something that still really interests you?

And then as a seasoned professional, it’s still good to be familiar with how those corporate integrity agreements are developing over time because I know and you know this, the way those are authored today are very different than they were ten years ago. And so, understanding that evolution of change, what’s being practiced today is just as relevant to all of our compliance programs across healthcare.

CJ: I agree, and so DOJ they have their evaluation of corporate compliance programs, OIG, the corporate integrity agreements. The other thing on OIG, so depending on what kind of sector you’re in, remember the OIG, this is not necessarily to you but to those listening, remember the OIG has compliance guidance documents. We know what the seven elements are but how do those seven elements apply depending on the provider type. So they have specific guideline documents for hospitals, for nursing homes, they have a separate one for physician practices for DME orthotics and prosthetics, for ambulance, for home health, for hospice, so these different provider types.

Brian: Payers, correct?

CJ: Exactly, payers. And so depending on what subsector of healthcare you’re in that might also be a really good starting point or starting resource to look at what OIG has published as far as guidance documents. And then like you said, following audits and that sort of thing. You know most of us subscribe to the listserv for OIG, you can be notified when a new audit is done. So that’s at a federal level those resources. The other thing I think is really important, depending on what state you’re in, looking at some of those state enforcement agencies. So some larger states especially have OIGs within the state so I’m familiar with the state of Texas, the state of New York, they are a little more robust that some of the smaller populated states in state-level type enforcement, and then of course the Medicaid fraud control units if you’re in that space. So, it’s kind of to me like finding out your jurisdiction, your region, and then pulling resources on both the federal level as well as the local or state level or maybe industry-specific.

Brian: And that also reminds me, as you evolve your career in compliance. I think one of the things that I really benefitted from, and I’m curious about your perspective as well, I found over time that my area of focus changed and one of the things that my mentor did for me was give new challenges in different areas of compliance to really broaden my experience but also add tools to my tool belt if you will. Those of you who might have listened to the first podcast I started off on triage and hotline calls. That was really my first task as a compliance professional. But over time my mentor gave me different tasks and different challenges, moving from that to doing auditing and monitoring. Doing different types of monitoring and auditing activities and then moving into training and education and really finding that evolution across the seven elements and gaining experience in each of those areas.

Question: What was your, I know you started in billing and coding transitioning as a physician, but what were some of your experiences in other areas of compliance?

CJ: Yeah, so early on in my career it was focused around coding, revenue cycle, both on the physician level first and then on the hospital level, and then I started to move towards general compliance and so that background in billing and coding really helped in auditing, reviewing, finding issues, doing self-correction, corrective action plans but then I got involved in others areas. Things like clinical research, HIPAA, you know I was interested, this was probably around eight [8] years into it. I started to feel like, I think I get the coding and billing piece, that doesn’t mean I know everything about it but just about 95% of what was coming my way I figured out a way to resolve, and I kind of need that next challenge.  And HIPAA was something I wasn’t trained in, wasn’t familiar with so I started inserting myself into certain meetings, asking our HIPAA experts could I be a part of this, and that was really interesting, and then when I transitioned to work for a for-profit international medical device company that was publicly traded I had a whole new set of things I had to learn. So they still had HIPAA and anti-kickback and that sort of stuff but I was now working with foreign practices act, so international types of laws. European union types of regulations, export controls, all sorts of interesting things, and to me that kept me interested in learning and growing as a compliance professional. The other thing that I would say is, that we are talking about being a sponge but also during that journey identify what you may know you are not very good at. [laughs] Knowing our boundaries and knowing I could push myself through this, but I would not be as effective as John over there, I know John is good at this. So learning where your boundaries are and then relying on others and collaborating can be really helpful.

Brian: That’s such a valuable point and I think that’s one reason why you and I work really well together, is I can establish the scope of a billing and coding audit but I’m not going to be the person who opens the medical record, look at the CPT procedure codes and whether or not the medical record documentation met the medical necessity of that code. I need subject matter experts to help me with that. I can look a data and data mining and determine if we have outliers and whether or not we might need to do a focused audit but I’m not that expert. So that’s a great point to highlight. You’re not going to know everything. I like to say compliance is five [5] miles wide and five [5] miles deep and you’re never, at least I have yet to meet anybody who can cover 25 square miles of compliance right?

CJ: Yep

Brian: So building relationships with experts in other areas, and complementing your skills is an instrumental part of being successful.

CJ: And plus, that can also add to efficiency. I know enough about a certain topic that I could push myself through it but it might take me two [2] weeks to do that when I know somebody else knows it off the top of their head and they can do it in two days. It’s also learning how to be more efficient and learning to use your collegial relationships in the most effective way. So that’s a great point.

Brian: That’s fantastic.

CJ: Yeah, you know we’re getting towards the end, let’s talk a little bit about money.

Brian: Yeah everybody wants to know about that right?

CJ: Show me the money!

Brian: Well the first thing I was going to say is if you’re looking to get rich choose a different profession. If you want to have a really successful career you can be very successful and make a reasonable amount of money if you’re new. And for me, you talked about it a little too. Even when we’re managing and negotiating our own salaries or we’re looking to hire and set a salary range for a potential new position there are tons of resources out there. I think the best way for me is a complement of multiple resources. Again ACCA puts out a really good tool. I think they do it near annually where they survey members on salary and then other resources like LinkedIn, Salary.com, and other recruiting websites are great resources to counterbalance.

Question: What do you think?

CJ: I think you’re spot on. So with those surveys and you have mentioned this in a prior conversation we had about regional differences right? So some states, like California may have a higher starting salary than others. So there are regional differences, there are differences in education level, there are differences in experience. You know it’s kind of hard to say exactly but I also teach in an undergraduate institution as well as a graduate school but some of those students who are just coming out think I want that chief compliance officer job that’s six [6] figures. It usually doesn’t come right out of school, usually, you need five [5] to ten [10] years of experience and that sort of thing but probably in some areas of the country you’re looking at entry level compliance analysts, and those sorts of things maybe 50, 60, 80,000 depending on what the level is, what the region is and then definitely get into the six [6] figures like you’re saying and you have a very comfortable career but you’re right, you’re not going to be buying that yacht probably.

Both: [laugh]

Brian: But you know, I think for me, what’s more, important than salary is the relationships that we get to build and the meaningful impact we have in the healthcare community in general. I tell my staff here, the people I work with on a day to day basis the reason I love compliance is I can’t put Band-Aids on children very well but I can help you manage your compliance program and that effective compliance program translates into a culture of safety which translates into better patient care in those communities and for me, I know this sounds altruistic but I love that my job helps to get people better healthcare.

CJ: Yeah, and to that point what I always found that energizing and motivating for me was can I simplify this doctor's day by understanding this rule and presenting it in a way that, you know they still have to do what they have to do with compliance. I can’t do everything for them but I sure can simplify 80% of it, have them do their piece, and we can both be successful and now I’ve given him back time or her time to see more patients. Or avoiding pitfalls where look if you get into this space you’re going to be looking at consultants and legal fees and investigations and reputational harm and all this stuff you don’t want to do so let’s stay on this side of it. And then do that for all sorts, not just doctors, nurses, therapists, administrators, like you mentioned quality and safety, I just find that fulfilling personally.

Brian: Me too, I think that’s why I love this job, that’s why I love helping people, that’s why I love these conversations with you and to help build new relationships and hopefully some people are interested in joining the profession. I guess the last thing that I would say is if you’re listening to this podcast and you think you’re interested in compliance feel free to reach out to me. I would love to have a quick conversation with you if you’re looking for that person who might know to put you on a path and help direct you, provide a check-in periodically to help mentor, that’s a great opportunity and I’m willing to do that. I can’t do that for hundreds of people but if you are interested reach out and we’ll see if we can connect.

CJ: Absolutely, and I would echo that. You know I encourage people when I’m presenting I usually throw out my LinkedIn link. Search for us on LinkedIn, connect with us that way as well, maybe we can put those things in the show notes. We’ll ask our producers here how to do that sort of thing. But absolutely, reach out.

Brian: That’s fantastic. CJ I really value these times that we get to spend together, it was great to see you at the conference a few weeks ago. To your earlier point, it’s great to see people in person. I know we’re in this new virtual world, we’re doing a zoom today but it’s great to connect with people, and looking forward to hearing from you again soon and the audience.

CJ: Yeah and thanks for joining us Brian on another episode of Compliance Conversations and thanks to everybody for listening. Until next time, be compliant, be healthy, and have a great day everyone.

Brian: Bye-bye.