By: Greg Radinsky, VP & Chief Compliance Officer, Northwell Health
Greg Radinsky is Vice President and Chief Corporate Compliance Officer for Northwell Health, the largest health system and private employer in New York. Find out more about Radinsky below.
Compliance Metrics Role in Conveying Important Signals
A company’s compliance metrics serve as a nervous system to convey important signals to management and the board. With an increasingly demanding regulatory environment, companies will be required to prove to regulators that a reasonable approach was implemented to assess and address industry compliance risks. “Paper tiger” compliance programs are no longer acceptable.
Northwell Health evaluates several data points that are transmitted throughout its network of data systems and facilities. In today’s data-centric world, it is easy to lose sight of what data is important. Northwell’s compliance department hones in on three vital data metrics to keep a healthy pulse on addressing potential risks: compliance inquiry statistics, case completion time, and predictive analytics.
Compliance Inquiry Statistics
It is critical for companies to hear employee, vendor and business partners’ compliance concerns and have them appropriately addressed. Northwell considers all communication channels when evaluating this metric. Northwell logs and tracks all compliance complaints from an anonymous compliance hotline and website. Any concerns the compliance department receives directly are also addressed, and individuals are encouraged to raise concerns to their manager or supervisor.
Data Mining & Predictive Analytics
It is also vital that organizations address potential unknown risks by utilizing data mining and predictive analytic tools. For example, Northwell uses a third-party software application where we feed large quantities of real-time billing data that is run against algorithms based upon known government and industry risk areas to identify potential outliers. Northwell also has a third-party application that identifies users who are engaging in patient record access patterns that are indicative of snooping, identity theft or other inappropriate behaviors. Our staff investigates outliers to determine whether there is a legitimate reason for the billing trend or record access and whether an additional compliance review is necessary.
The data results identified from these types of applications allow Northwell to have a greater degree of confidence that the key risk areas are being identified and addressed. Northwell shares these data findings with management and its board to provide additional assurances that we are targeting the appropriate risk areas in our audit plans.
About the author
Greg Radinsky is a frequent contributor to professional publications, he often shares his expertise via presentations on compliance topics at conferences for national organizations. Greg received his M.B.A. from the Kellogg School of Management, his J.D., magna cum laude, from Saint Louis University School of Law, and his B.A., magna cum laude, from Tufts University. Read more.