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Connecting Compliance and HR to Keep Patients Safe: Takeaways from Our Conversation with Ochsner Health During the 2021 HR Healthcare Keynote

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To illustrate the significance of a strong relationship between Human Resources and Compliance at healthcare organizations, ProviderTrust facilitated a conversation during the virtual HR Healthcare event between:

  • Donna Thiel, Chief Compliance Officer at ProviderTrust
  • Dylan Thriffiley, Vice President & Compliance Officer at Ochsner Health
  • Stephanie Victoriano, Assistant Vice President of Human Resources at Ochsner Health

The Ochsner Health and ProviderTrust Partnership

Ochsner Health is the largest non-profit health system in Louisiana with 30,000 employees, more than 40 hospitals, and more than 100 urgent care and healthcare centers across the state. They are working to reinvent the future of health and wellness in the region and are passionate about quality care. From healthcare license verifications and OIG exclusion checks to enterprise compliance and eligibility monitoring, ProviderTrust delivers it all in one powerful platform. Ochsner has partnered with ProviderTrust since early 2016 to help keep their patients safe. 

Through our longstanding relationship, we’ve learned how Ochsner’s unique structure has fostered open and honest communication between HR and Compliance, ultimately ensuring better outcomes for the health system and their patients across the state. 

A Different Approach to Connecting HR and Compliance

According to Dylan Thriffiley, Vice President &  Compliance Officer at Ochsner, their departments initiated an organizational restructure about two and a half years ago, which included the addition of a new role: Chief Risk & HR Officer. The Chief Risk & HR Officer reports directly to the Chief Executive Officer and oversees the HR, Compliance, Legal, Risk Management, and Physical Security departments, as well as other risk-based functions. Prior to the reorganization, the HR and Compliance departments had a strong relationship as it was a necessity to be effective in their roles. However, the transition required constant communication as well as the ongoing management of expectations. Over the past two and a half years, Dylan has seen a significant difference in their relationship.

The relationship between the two departments has blossomed into an even more fruitful partnership between the two of us and frankly, it helps that we’re all reporting into the same area within the organization.
Dylan Thriffiley
VP & Compliance Officer, Ochsner

The Keys to Building a Productive Relationship

Donna, Chief Compliance Officer at Provider Trust, followed up with a question about the keys to success in building and maintaining a successful partnership between HR and Compliance. Both Stephanie Victoriano, Assistant Vice President of Human Resources at Ochsner, and Dylan agreed that it requires consistent effort, but it pays off to build and maintain trust between the two departments. 

Trust Between Teams

  • Our teams need to trust each other to handle the investigation (or whatever we’re working toward) in a professional and timely manner, while meeting expectations.
  • Another vital component is the Employee Relations function. 
    • Prior to the reorganization, the Employee Relations function was handled by HR business partners. Ochsner centralized this function and brought in an external resource that specialized in investigations and employee relations. 
    • Now, when Compliance partners with HR, they feel confident that there’s an in-house, dedicated resource team to focus on investigations.

Consistent Investigations

  • The centralization and consistency of investigations also proved to be important. The timing of the restructure coincided with the Ochsner Compliance Team’s efforts to change the culture around how the health system viewed and handled patient privacy incidents. 
    • Although every investigation invariably has unique circumstances, Compliance worked with HR to put a consistent process in place, as well as guidelines around, what prioritization and outcomes should look like.
    • They also established clear escalation paths when it comes to reporting possible risks to ensure that not only are processes being followed but that there is ongoing communication, especially as the Compliance Team is much smaller than the HR Team at Ochsner. The difference in team size can lead to information being disseminated at different speeds. 

Valuing Expertise 

Valuing each other’s distinct areas of expertise has also helped both departments to be successful. The teams are working together to ensure that the appropriate HR and/or Compliance expertise is brought forward in each investigation or case.

Communication Practices for Joint Success

When it came to discussing how both teams rely on trust, ongoing feedback, and routine communication to be successful, both Dylan and Stephanie said that all of these components take hard work. One of the foundational aspects of a successful working relationship, according to Dylan, is to always try to understand where the other person is coming from when taking into consideration their distinct perspective. Dylan said that she always tries to remember that Stephanie constantly has to wear different hats with her myriad responsibilities at Ochsner, one of those as the Compliance business partner. Dylan also noted that realizing and understanding  Stephanie’s perspective has helped foster respect during difficult conversations. 

Ongoing Feedback

In addition to understanding each other’s unique perspectives, Stephanie said that ongoing feedback is key so there’s no “gotcha game.” There’s a mutual understanding that both HR and Compliance are on the same side and are all working together toward a common goal. Both teams consistently seek out feedback from each other. When Dylan’s team was seeking out a new compliance system, she brought in Stephanie’s team early on in the process. And if there’s a disagreement between their teams, they make sure to escalate the situation in partnership. 

Dylan provided an anecdote to further illustrate the solid relationship between HR and Compliance at Ochsner. During the recent evaluation process, Dylan asked her three directors to provide three to five leaders at the organization, outside of Compliance, to solicit feedback on their performance. Every one of them provided at least one leader from the HR Team.

When I tell you that HR is the team we work with the most, that we try to be in lockstep with as much as possible, that is 100% true. My leaders work directly with the leaders in HR, literally, on a daily basis.
Dylan Thriffiley
VP & Compliance Officer, Ochsner

Routine Communication

Routine communication, whether hard-wired or not, sets expectations between the two departments while ensuring visibility. Specific automated reports that the Compliance Team receives from the HR Team on a consistent basis are key, like the report that’s generated if an outgoing employee answers a question during the exit interview that raises a red flag from a compliance perspective. The Compliance Team receives this report on a recurring basis and they also have an assigned HR point of contact for further clarification and partnership, if needed. 

Stephanie noted that a lot of the routine communication between the two teams is hard-wired, like the report listed above, as well as a weekly report she receives from Compliance that shows all open investigations, in case she needs additional insight or needs to escalate a situation.

We have a rhythm and rigor to make sure nothing gets dropped. It’s another trust-building factor - we both have confidence that everything will be handled in a timely manner.
Stephanie Victoriano
AVP of HR, Ochsner

Advice for Building Enduring Connections Between HR and Compliance

The most important initial step, according to Dylan, Stephanie, and Donna, is to simply reach out and get to know one another on a personal level to set a relationship baseline. Building the initial trust and a solid relationship are foundational to a successful working partnership. Donna also added that always assuming the best intent on the other side of the table as well as taking time to learn about individual job responsibilities are both crucial. Stephanie’s last piece of advice was to centralize the Employee Relations function as Ochsner did. Hiring an expert with strong credentials that can help staff a team with similar backgrounds has helped both teams immensely. Not only has it resulted in increased trust between HR and Compliance, but by centralizing the Employee Relations Team, Ochsner’s EEOC charge and employment litigation levels are at almost zero.

This new way of managing HR and Compliance in a joint fashion will, I hope, spur so many organizations to model after what Ochsner has done.
Donna Thiel
Chief Compliance Officer, ProviderTrust

The discussion between Donna, Stephanie, and Dylan showed how the connection between HR and Compliance in healthcare organizations ultimately leads to better outcomes.  Leaning into the relationships between Compliance and HR is absolutely vital. Dylan said it best: “If we want our patients to trust us, we have to be willing to trust each other.”

Join us for a webinar on Connecting HR & Compliance

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