Assertive and Approachable

Assertive and approachable.

These are the terms that the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services uses to describe an effective Compliance Officer.

There has been less discussion of this point than about the OIG’s recommendation that the Chief Compliance Officer should report directly to the CEO or the Board. While the reporting line discussion is important, it has been my experience that striking the balance of assertive and approachable — at every level — is more important.

Assertiveness and approachability may be key to gaining access, and making use of it. I have witnessed a situation where a caustic Chief Compliance Officer reported directly to the CEO, but didn’t have unfiltered access to him. I have also personally experienced reporting to the General Counsel, but having direct and unfettered access to the CEO and the Audit Committee. Access is key. But once you have access, what will you say and how will you be perceived. OIG’s recommendation is to be assertive and approachable.