Perspectives is Habi Green's collection of short essays on various topics. Practical thinking on accreditation, compliance, and leadership under pressure, drawn from two decades inside regulated healthcare organizations.
The organizations that pass surveys comfortably are not the ones with the thickest policy manuals. They are the ones whose front-line staff can explain, in their own words, why a policy exists. Here is how to tell which one you are before the surveyor does.
Read the perspective →Across audits by CMS and state regulators, the same categories of findings appear again and again: delegation oversight gaps, stale policies that drifted from practice, and reporting that no one owns. All three are preventable, and prevention costs a fraction of remediation.
Read the perspective →A turnaround in a regulated industry is a different sport. Cost cuts that would be routine elsewhere can create compliance exposure; speed matters, but a missed filing can end the effort entirely. The discipline is doing both at once.
Read the perspective →Every organization preparing for an NCQA, URAC, AAAHC, or JCI survey builds documentation. The ones that struggle are those where the documentation and the daily reality quietly diverged years ago. Surveyors are trained to find that gap, and they find it quickly, usually in the first conversation with a staff member who has never seen the policy they are supposedly following.
True readiness looks different. Policies are short enough to be read, current enough to be trusted, and familiar enough that staff describe them naturally. Mock surveys are treated as diagnosis, not rehearsal. And leadership treats the survey not as an event to survive but as a free examination of whether the organization actually works the way it believes it does.
If your survey is on the calendar and you are not certain which kind of organization you are, that uncertainty is itself the answer, and the good news is that there is still time to change it.
After enough audits, patterns emerge. The first repeat offender is delegation oversight: plans delegate functions to PBMs, TPAs, and other entities, then oversee them with an annual attestation and hope. Regulators hold the plan accountable for the delegate's failures, and the plan is often the last to know about them.
The second is policy drift. A policy written five years ago described the operation accurately at the time. The operation changed; the policy did not. In an audit, the gap between the two reads as noncompliance even when the current practice is sound.
The third is orphaned reporting. State, federal, and NAIC requirements accumulate, staff turn over, and eventually a required filing has no owner until a deficiency notice arrives. The fix for all three is the same: compliance treated as a living operation with named owners, not a document set reviewed annually.
In most industries, a turnaround leader has one master: the balance sheet. In regulated healthcare there are two, and the second one, the regulator, does not pause its expectations because a company is in distress. Filings are still due. Member protections still apply. Network adequacy does not take a quarter off.
That dual mandate changes the playbook. Every cost decision needs a compliance review before it needs a spreadsheet. Communication with regulators should increase during a turnaround, not decrease; silence reads as concealment, and regulators reserve their harshest treatment for surprises.
Done right, a turnaround conducted in full view of regulators becomes an asset: the organization emerges not only financially stable but with regulatory relationships stronger than before the crisis. That is the standard a turnaround in this industry should be held to.
The earlier the conversation, the more options you have. Tell us where you stand and we will give you a candid assessment.
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