Mary Shirley on What to Do When Leadership Doesn’t Take Compliance Seriously [Podcast]

By Adam Turteltaub Here’s a little nightmare every compliance officer dreads.  You leave your current job for an exciting new one, only to find out that you just walked into a position where the compliance efforts are token at best because the organization’s leadership doesn’t take compliance seriously. In this podcast Mary Shirley, Vice President, Chief Compliance and Privacy Officer, Scion Health, shares what to look for and how to protect yourself if this bad dream becomes your reality.  And, for the record, she has not run into this disaster at Scion Health. So, what are the signs there is insufficient commitment?  Any or all of the following could be, although generally one or two, she notes, may not be definitive: The title and standing of the top compliance officer is relatively low with little authority The compliance teams is greatly understaffed compared to industry benchmarks (cross-industry, healthcare data), without some compelling reason such as the organization is undergoing financial difficulties There is insufficient or no budget for necessary outside resources A lack of management appetitive for even inexpensive compliance initiatives Lack of support for professional development for the compliance team Compliance not included in major deals or transactions A chief compliance officer with no background in compliance If you find yourself in a situation where the compliance role is not worth keeping, it’s best to determine if there is hope for change or if it is best to leave. Either way, take the time to protect yourself by documenting what you have done and recommended, including what management ultimately decided. To prepare to leave, turn to your network, if you have one.  If you don’t have one, it’s time to start building it out. And, regardless of whether you are in a bad situation looking for a better one, or just looking at a potential career move, she advises asking these questions during the interview to determine if the new position is one that is set up for success or failure: What gets people fired around here? It’s a good way to see if there is real and consistent discipline. Can I speak to my predecessor? What would you like to see improved in the compliance program in the next six months? How would you describe the company’s risk appetite? What would the rank and file say about whether leadership is held to the same standards as they are? What deliverables from the compliance team were rewarded? What types of meeting does compliance attend? Does it have a seat at the table? What professional skills development programs were the compliance team sent to or given last year? What is the full-time staffing of the compliance office? What percentage of that is dedicated vs. liaisons? Is there budget for travel for investigations, training, compliance and ethics week activities and other purposes as needed? Listen in to learn more about how to find the right compliance role.