"Anytime you are in any industry with such high regulation and you have the pressures of declining reimbursement coupled with new mandates, anytime you have pressures like that they are going to invite environments where ethics must be carefully scrutinized," he says.
Compliance programs, ethical standards, and codes of conduct and professional accountability can vary greatly from hospital to hospital, Huddleson says. To be effective, however, they must have strong top-down support. Orlando Health showed that it was serious about ethical and professional standards, he says, when the health system made its chief compliance officer a corporate post.
"That sends a message that our board and our senior executives value compliance and ethics. When our corporate officers meet, I'm at the table," Huddleson says. "It's the tone at the top, leading by example. The feds have made it very clear that they expect compliance officers to be in this position. They aren't mandated yet, but that day is probably coming."
Avots-Avotins and Huddleson caution that ethics and compliance programs can bog down in minutia. Rather than wallowing in details, they say, build on the mantra of patient care above all else, and accountability at the highest levels.
"You don't instill an ethical culture overnight," Huddleson says. "It's not a computer program or something you buy off the shelf and plug in and play it. You have to build it. And it has to start with your senior leadership and board of directors."