A "culture of compliance" will only happen if the compliance DNA of the organization changes. As we all know, changing a culture is difficult to do and does not happen overnight. It's an organic process. What can the Elephant, the Rider, and the Path teach us in this regard?
The Elephant, the Rider, and the Path
Big problems require small solutions[1]. It's not that the end state solution will turn out to be small or trivial, in fact it is likely to be quite encompassing, but rather that the ultimate solution can only be achieved through a series of smaller solutions. In Switch, a book on change when change is hard (read HITECH), Chip and Dan Heath posit three core components of change: 1) the Rider (our rational side); 2) the Elephant (our emotional side); and 3) the Path (the context in which the change takes place)[2]. All three must be aligned if change, within any difficult context, has any chance of succeeding. The authors summarize their findings as follows:
For things to change, somebody somewhere has to start acting differently. Maybe it's you, maybe it's your team. Picture the person (or people). Each has an emotional Elephant side and a rational Rider side. You've got to reach both. And you've also got to clear the way for them to succeed.[3]
There is very little chance of success if the change agent appeals solely to an individual’s (or a group’s collective) Rider. No matter how compelling intellectually, or how strong the numbers look, appealing to the Rider alone is not sufficient to get the Elephant (our emotions) to move. In order for difficult change to occur we need to move the Elephant. Elephants don’t move easily, and when they do, they tend to go wherever they please.
The compliance Elephant will
be difficult to move without help
from key stakeholders in your
organization.
Unless you move your organization’s compliance Elephant you may likely implement one of several HITECH compliance strategies that are guaranteed to fail. Moving the healthcare compliance Elephant is no small feat—yet another reason that the problem is wicked. Fear of fines from Big Brother may be a necessary enough incentive for the Rider, but will likely prove woefully insufficient for the Elephant. You have to get the Elephant to want to move, because elephants don’t scare easily.
How do we get the healthcare compliance Elephant to move? Commit to the patient. The patient wants his or her PHI secured. The patient wants you to ensure privacy. The patient wants anywhere / anytime electronic access to his or her PHI. Patients will soon start demanding from the healthcare industry what other industries provide as a matter of course (e.g. the banking industry), and they will get it. Innovative players within a highly competitive marketplace will find a way to deliver on the promise. To the victors go the spoils.
[1] See generally Chip Heath & Dan Heath, Switch: How To Changes Things When Change Is Hard (New York: Random House, Inc.)
[2] See Id. (Switch is told through a series of stories including the now legendary 100,000 lives campaign)
[3] Id.
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