Compliance Officers Are Ruff and Tuff and Hard to Bluff

Reprinted with permission of the Journal of Health Care Compliance

When I retired in 2020 to spend more time with family, like our four grandchildren above, I was interviewed by a few publications and they asked me one question that surprised me – Did I have any regrets related to the evolution of the compliance profession??This was a surprising question that instantly made a lot of sense.?I had a few regrets. One was related to the name of our profession.?I wish we would have used the term Integrity Officer instead of Compliance Officer.?The Compliance Officer title implied enforcement and, of course, enforcement is important.?However, Integrity Officer focuses on the outcome we are looking for… integrity.?It makes more sense to begin with the end in mind.?Maybe we could have used the title Director of Integrity and further minimized the onerousness of the Compliance Officer title.

As I began writing this Letter from the Editor, I wondered if my regret was wrong. The title Compliance Officer does imply a level of seriousness that I think was important but the title may have put some people off. Although integrity is the end goal, the Compliance Officer title emphasized how to get to the end goal and why our profession was created in the first place.?The world lacked people who would find and FIX problems rather than find and point at problems. Our profession was created because all those who came before us, lawyers, auditors, risk officers, ethicists, etc., failed to prevent epic corporate ethical and regulatory meltdowns.?

Some industries like Hollywood were ethical cesspools. Some industries like healthcare were regulatory disasters. They did not improve because no one had the authority or courage to stop ethical and regulatory wrongdoing.?We had a sea of people who were more concerned about their next promotion than stopping a powerful and unethical person.?They would find and point at a problem but they did not ensure compliance.?I once wrote an article about these people who I referred to as the Pointer Sisters.

Compliance Officers were not the Pointer Sisters.?We would do everything we could to prevent, find, and fix ethical and regulatory problems.?Our jobs were occasionally stressful.?Some of us were fired for not looking the other way like the Pointer Sisters.?But we were respected. We were thanked for addressing issues that hurt employees. If you asked people to be ethical they act like they acted before compliance officers came along.?If you do a comprehensive investigation, find wrongdoing and take bad people before the compliance committee… they stopped doing wrong.?We may have seemed onerous and punitive but made the world a better place by occasionally being ruff and tuff and hard to bluff.?So upon reflection… maybe the title Compliance Officer is the right title after all.