Alternative New Media for the Gulf South
Is it an inherent conflict for a compliance department of an organization to report to the legal department of the same organization? Compliance is to police the organization and its people and practices and legal is to protect the organization. Right? Makes me wonder if certain “issues” have been shredded or dismissed without investigation. If said organization is known to have engaged in suspicious or illegal practices, one could suggest that these two mutually opposed yet enmeshed entities be investigated and completely separated.
The answer is no, it is not an inherent conflict for the Compliance Department to report to the Legal Department of an organization. That is if you are referring to a true “Compliance” department that has the oversight and monitoring responsibilities for laws and related matters that impact an organization. There are surveys out there that show that for large companies that have true Compliance departments (lead by a Chief Compliance Officer – CCO), that there is a mix between those that report to the Head of the Legal Department and those that report Directly to the Board of Directors of an organization. If you really mean an Internal Audit function, then that is different. An IA function of an organization would not typically report to a Legal Department or technically any other Department head, but have ultimate reporting responsibility to the Board of Directors – since they are tasked with providing independent evaluations of company processes amoung other activities. However, most companies that have in house Law Departments and Internal Audit departments, will have Internal Auditors supporting various Law Department requests periodically.
However if this is related to SRHS, I would guess they are too small of an organization to have a large stand-alone Compliance Department led by a designated CCO if they even have that function at all. You see that more in large publically traded companies. I would suspect they are large enough to have some sort of Internal Audit function. It would be interesting if that was done in house or the function was outsourced to an outside firm.
SRHS had a C C O for many years. Her name was Stephanie Barnes Taylor.
And I got pictures. She literally was the SRHS Queen. Not sure how much compliance work she actually did.
Things that may you go Hmmmmm :
The appointment of Mr. Guice as a so-called independent investigator of SRHS makes me think of what happened in Jefferson Parish where the Council appointed a so-called independent substitute for Parish President who had political attachments which seemed to interfere with contracting with independent auditors.
However. the DA of Jackson County and FBI are supposed to be on the scene hopefully to verify the onion is completely peeled back, that it is sliced and diced and some people will be crying very soon.
SRHS’ Chief Compliance Officer and General Counsel were one in the same. It was a small dept but it did have another full time attorney and a director of compliance
I doubt very much real compliance work was being done… You see the former CCO/GC was so busy on company time wearing her fabulous tiaras, 4 inch heels and sparkling suits not to mention writing her book , developing her leadership classes and using the company’s email to send out notices and soliciting for students to attend her personal for profit classes to really be a chief compliance officer let alone SRHS’ GC.
Her “fabulosity ” was a detriment to the entire organization – it was a joke! I can honestly say that this is one thing that Holland did correct out the gate. He and Larry Shoemaker decided early on that their CCO/GC was a liability and had to go
Go she did with a very public email sent to all émployees
If you want pictures of just how she did look and behave in her role at SRHS one simply goes to facebook and search. ‘SBT’. When you browse her photos you will be amazed at how such a world class facility tolerated such behavior from one of their own C-suiters
SRHS was nothing but a playground for Anderson and his Senior Executive Team
And they wonder why they are in this horrific mess!!!?
Wow, I did do the search and ran across the page. Very interesting. As I noted above, the designated CCO (even if they are the GC) has a typical job description to assure a company is in compliance with all federal and state laws that are applicable to the organization. Also to ensure that the responsibly individuals in an organization are aware, trained, etc on these laws. If she was terminated from her position, have they re-filled that post? Have they added to the department of in-house compliance personnel or lawyers?
SBT came to SRHS at the same time her physician husband came.
O07 and Rebellious One:
Thanks for clearing that up for us readers and the above misconceptions of commentor “Observer”
I’ve enjoyed some delicious BLT’s but a “fabulosity” SBT sounds too juicy , too much superficial gravy and condiments for me too. He,He, He
Quality commenting guys – keep them coming we have lots more popcorn to enjoy.
Locke is a “character”, Observer is one as well. I remember Observer from another blog and a day gone by. You have him read wrong friend.
The PR people know better than to astroturf here and I personally like objective analysis for feedback purposes alone. No one is perfect so once in a great while you get a fleeting glimpse of the person behind the name. We’d be damn lucky as a community to have Observer stick around that long.
Continue on with both the pop corn and inside muck. 🙂
I’ve already supplied my opinion on this, and will gladly second SOP’s encouragement of new participants.
I would hate to see well intentioned people discouraged from providing new information or thoughts here or elsewhere.
Concerning SRHS compliance, have they decided to adopt a new slogan yet? The old slogan under SBT used to be:
Don’t let unintentional errors cause
Here are some links.
Locke – again I post factual information and you want to suggest otherwise. I clearly stated that the CCO can and often does report into the Legal department of an organization based on outside analysis of many other companies. My statement stands and is factual and is not “cleared up” by other posts. All the other posts did was state that at a small operation like SRHS (small based on on sales $ and number of employees in respect to large publicly traded companies on the stack market) actually has a CCO which happens to be the GC. I would venture to say that other companies of this size may not have a designated CCO. I have seen other companies where this is the standard C-suite setup. Now if the person did not fulfill the job requirements, that is a different story and I do not have insight into that. But other posters seem to.
You seem to be encouraged to make off the wall derogatory comments to other posters who are not in line with your line of thinking.
But it seems like you have it all figured out as you like to let everyone know (lock them all up right?). I’m sure someone will eventually catch on to your thought train and right the ship. Best of luck.
In your original post concerning the question of the existence of a Compliance Dept and a designated CCO at SRHS you stated:
” However, if this is related to SRHS, I would guess they are too small of an organization to have a large stand alone Compliance Dept. led by a designated CCO if then even have that function at all.”
007 was kind enough to correct your “guess” and clearly state that there was indeed a Dept. and SBT was the CCO and yet you are back telling me in your above comment you stated “factual” statements and criticizing me personally for thanking 007 and Rebellious One for their corrective comments.
I’ve stated things in error in comments before but if corrected I usually try to apologize and do not attack the commentor pointing out my error. You may not be a PR plant and indeed a person Doug says is a good guy, but your initial optimistic post on the plight of the pensioners, pending retirees and employees as per your 4th grade math is forgiven but not forgotten. Especially in light of your personal decision to deny your original misplaced optimism and not to apologize to the victims who could have read your initial optimistic post of their horrific financial situation.
May the Lord grant you more sympathy for less fortunate souls who worked hard for many years to retire and through no fault of their own have now been robbed of such a lifetime dream. While the robbers ironically will probably not have to pay retribution for their evils and will retire with full pensions and live a luxurious life. Is it that hard for you to put yourself in their shoes and state some compassion, sympathy and mercy ?
So, when it comes to contracts that are deemed to have conflicts of interest or even RICO violations, who is responsible? Each administrator was directly responsible for his areas. Kevin, as COO, was directly over facilities as well as other departments. If any unethical or illegal contracting happened in facilities, isn’t he responsible along with compliance and legal? Legal approved all the contracts.
As far as the criminal investigation goes, who are the alleged criminals? The administrators who ran away? Don’t some of the others have some responsibility?
I’ve heard talk about Medicare and Medicaid billing issues along with sweetheart deals with some providers who refer patients. Who is responsible for making sure SRHS is compliant in those areas? Just the Big C’s? Or just legal and compliance or all of them? Did the investigators set up a hotline to call to report alleged unethical or illegal activity because i doubt anyone is naive enough to think calling the SRHS compliance line will result in anything other than the compliance head pressing delete or shredding the report.
SBT is packing the UHaul as we type. She may take all those snazzy shoes with her, but I hear she is planning to leave a few roadmaps behind. Time will tell if those maps are legit or just an attempt to lead someone on a goose chase.
Observer, To answer some of your questions- SRHS did not replace SBT. They promoted Celeste Oglsbey but Celeste’s title is not CCO nor is it GC. It’s something similar but not as prestigious or paid as much as the former.
SRHS has not added to their Compliance Program/dept. In fact Holland and Shoemaker could not see any benefit from having a Compliance Dept and Legal Dept so they downsized. When SBT left , they immediately let Angela McGee go, who was a minority with a masters degree and kept an employee with only a HS diploma. They moved one assistant from compliance to another dept because of his special skills with Heath Thompson aka The Weasel of OSH. Another member of the compliance dept was let go, and one was moved to work under Facilities Support. The Risk Manager who is a nurse still falls under compliance dept but works more with nursing and attends their dept meetings
Compliance and Legal has been a long time joke at SRHS. Which one could surmise as a possible reason everything at this world class facility went to hell in a hand basket so quickly!
Perhaps a cute long legged dancer will emerge from one of the local casinos to be appointed to oversee their compliance dept. Oh wait, she got promoted to director of patient access. I’m sure Kevin and his boy Lee will find the right butt kisser to fill the vacancy.
More than once recently something like: “Celeste Oglesby, general counsel for SRHS, denied the request “because these records are exempt from mandatory disclosure” and she cited a state statute.” has appeared in the media.
Without correction as far as I know.
RFP, thank you for making me aware of the correction.
I’m not sure which is correct.
A report in the media is a data point.
Letterhead with the title would be much more convincing.
I might have seen that recently, but I’m not sure.
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