In this Q&A with SearchCompliance, Roy Snell, CEO of the Health Care Compliance Association and the Society of
Corporate Compliance and Ethics, shares his thoughts on the business gains to be had from a compliance program, and the need to balance patient privacy with the need to gather patient data to improve the healthcare industry.
Does a compliance program have more influence on business strategies and business decisions because of the expanding regulatory landscape?
Roy Snell: With the press, public, politicians and prosecutors so focused on fraud, some companies are using compliance and ethics as a business strategy to differentiate themselves from the competition. They want to let the patients and potential business partners know they can be trusted. Some have stopped fighting it and embraced it. Others are still fighting. The latter group is the group most likely to be fined.
Is there a way to prove the return on investment [ROI] of a corporate compliance program? Is it just a matter of "we haven't been found to violate any laws, so we must be compliant" or are there metrics that can be put in place?
Snell: It's just as hard to prove the ROI for compliance as it is for HR, legal and audit. They are all functions we need be effective in business. It is difficult to determine the ROI, however every company that has paid a multimillion-dollar fine understands the ROI of the compliance program they could or should have had in place.
Big data analysis and data mining for improved care, better population health, better outcomes, etc., is key for healthcare. How can organizations balance this influx of data with the need to keep patient information safe?
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For more information on the conference, see GlobalDirections '13
Snell: We protect all of our financial data, intellectual property and internal documents, and we do so eagerly. We have easy access to all that information for decision making. It's possible to get to a secure patient data environment without impeding patient decision making. It's just complicated by the fact that there is so much patient data, and so many people need access to it.
How does a healthcare organization balance the benefits of new technology that can potentially improve patient care (such as mobile device connectivity or physician iPad use), with the threats this technology poses to patient privacy? BYOD strategies?
Snell: Healthcare has to make sure that the new technologies they develop or purchase do not expose patient information. With or without regulations and compliance, that should be a priority. It's not a matter of balance or choice; it's the right thing to do.
Given the recent Advocate Healthcare data breach, the second largest HIPAA breach on record, should encryption no longer be an option for the protection of PHI? What is your advice to CIOs who are handling sensitive information across industries, in terms of best practices and standard procedures for keeping it safe?
Snell: Everything is eventual when it comes to regulations. If we don't encrypt, and massive patient data breaches keep occurring, there will be a regulation related to mandatory encryption. My advice for CIOs is to work closely with the compliance/privacy officer to handle exposures like stolen laptops, password education, etc. They are very skilled in this area.
Roy Snell is CEO of the Health Care Compliance Association and the Society of Corporate Compliance and Ethics. He will be speaking about healthcare compliance assurance strategies and technologies at the Global Directions 2013 conference.