I understand there have already been many posts about the VSP and involuntary separations (layoffs). Some posts provide information people need at the moment, while others are more focused on sharing opinions or experiences. Either way, there was a post some time ago about SIU suggesting that the changes there might only be the beginning, and that the broader Compliance & Ethics organization may need to be reevaluated, reorganized, and reassessed to ensure its policies, procedures, and processes are current and effective.
I don't want to beat a dead horse, but recent departures within Compliance & Ethics caught my attention.
I understand that the Vice President overseeing the Conflict of Interest (COI) team and Compliance Investigations Unit (CIU) is no longer with the company. I also understand that certain management personnel within Special Investigations Unit (SIU) are no longer there, and that the former Chief Risk & Compliance Officer, is no longer with Centene.
Any one departure can happen for many different reasons, and I don't think it would be appropriate to speculate about why individuals have left. However, when there are multiple departures across different levels of a Compliance organization, I think it is reasonable to ask whether the organization itself should be taking a closer look at its structure, processes, and leadership.
Perhaps this is an opportunity for Centene to take a step back and conduct a comprehensive review of Compliance & Ethics before simply continuing with business as usual.
Some questions worth asking:
• Are the policies and procedures current, comprehensive, and consistently applied?
• Are there clear guidelines and quick-reference resources for investigators and management?
• Are investigations being conducted and closed using consistent and documented standards?
• Are employees given clear and consistent expectations for handling cases?
• Are investigators receiving the appropriate training and qualifications for the responsibilities they are performing?
• Are compliance standards being applied consistently within Compliance & Ethics itself?
• Are management decisions consistently supported by established policies and procedures?
If Compliance & Ethics is responsible for ensuring that other departments follow policies, regulations, and established standards, shouldn't the same level of scrutiny be applied internally?
This isn't about pointing fingers at individual employees. It's about asking whether the organization has the right structure, leadership, policies, procedures, training, and oversight in place to effectively perform one of the most important functions within the company.
When there are departures at different levels of Compliance & Ethics, perhaps the appropriate response isn't simply to fill the vacancies and move forward. Perhaps it's time to stop, look at the bigger picture, and ask whether there is something within the organization that needs to be addressed.
Before Compliance can effectively hold the rest of the organization accountable, Compliance should be willing to hold itself accountable as well.