“Diverse Perspectives, Results Delivered comes to mind when I think about our team here at Ankura. It’s how we operate every day. From the makeup of our team to the way we collaborate with clients, we are constantly striving to add value by seeing things differently and approaching problems from diverse perspectives.” – Dorothy DeAngelis, Senior Managing Director
1. You’ve worked with some of the world’s largest health plans, government agencies, PBMS, and pharmacies. How has that experience shaped your career, and how does it help you serve clients?
I think having that background really helps me bring a ton of “been there, done that” sort of experience for my clients and on my casework as an expert witness. Throughout my career, I’ve built, implemented, and tested the effectiveness of countless compliance programs in the healthcare space, I’ve engaged with government agencies on regulatory investigations and sanctions, and I’ve helped clients through their most complex healthcare disputes. I’ve also served as a Compliance Officer for a large health plan, so I understand the challenges that my clients face.
I’d also add that I have always been intentional in gaining multidisciplinary expertise in my practice and field throughout my career. You really have to think end-to-end in these complex situations. My experience allows me to be comfortable when diving into high-stakes moments or moments of crisis, and help my clients come to a solution that protects and creates their enterprise value. To be totally transparent, these are my favorite sort of projects and cases to work on. I’ve found that it is these cases and moments that you can make the most cultural and operational changes to an organization. There’s really no better time to build better sails than when you’re rightening the ship.
2. Speaking of that multidisciplinary skillset, you provide testimony in the courtroom and advise corporate leaders in the boardroom. How is your approach different in each setting?
I don’t think the approaches are all that different. In both cases, there’s a level of independence, authority, and – frankly – gravitas that you need to be successful.
Let me start with compliance first. As a compliance leader, you need to be able to advise and help your C-Suite leaders think through risks and challenges to your business. You also have to be able to design, implement, and deploy solutions that mitigate these risks and address these challenges. You have to be outcome-driven and be able to play the field of your entire organization. Again, independence is key, but it does you no good if you’re always at arm’s length of the business and can’t understand it enough to put yourself in others’ shoes and make an objective decision. Finally, you have to have enough gravitas to stand shoulder-to-shoulder or sit at the table with your fellow leaders that are driving the business and be seen as a trusted partner. Without that, you simply won’t be able to mobilize your organization to reach a place where compliance is a valued function.
When I’m in the courtroom, my job is to objectively analyze the situation at hand and help those in the room understand what happened – what steps should or should not have been taken and the like. Yes, there’s a lot more expectation and formality to serve as an objective, third-party witness. But if you’re doing your job right as a compliance leader, what you do in the courtroom is no different than what you should do in the boardroom.
3. What are the biggest challenges facing healthcare organizations when it comes to compliance?
One of the biggest challenges on the horizon for healthcare organizations – on both the payor and provider sides – will be real-time prior authorizations and the automation that’s necessary to pull that off. Being able to provide real-time prior authorizations for services will be a huge lift for organizations and will require a lot of compliance expertise to make sure it’s done correctly. To do both – and do them well – it will require a lot of coordination and communication between different parties, which can be a challenge in and of itself. This coordination and communication is critical because of the various regulatory frameworks that are set up as guardrails and I think you could see some organizations struggling to build and deploy the systems and processes they need in place to manage these challenges.
4. What would you say is your brand of compliance? What do you feel sets you apart from other healthcare compliance experts?
My brand of compliance is that you cannot divorce compliance from operations. You have to drill into every part of your organization, or that of your clients, to understand how compliance – and non-compliance – will impact your business and strategy. Having been in the shoes of my clients and sat in the chair as a Compliance Officer, I can be honest when I tell my clients that I’ve already gone through a lot of challenges that they face. I’m not just a theorist – I’ve actually been in the trenches and know what it’s like to be on the front lines.
“My brand of compliance is that you cannot divorce compliance from operations. You have to drill into every part of your organization, or that of your clients, to understand how compliance – and non-compliance – will impact your business and strategy.” – Dorothy DeAngelis, Senior Managing Director
5. What is a recent case or engagement that you worked on that was particularly challenging or interesting?
Not too long ago, I was engaged by a major healthcare insurer that had been sanctioned by CMS (Centers for Medicare and Medicaid Services) for alleged Medicare Advantage violations in their contracts on a number of fronts that were focused on issues of potential member harm. Putting aside the truth of these allegations, the impact of these sanctions went far beyond a slap-on-the-hand sort of regulatory fine or the difficulties of having to manage a regulatory investigation. It also caused them to lose a lot of trust with their customers and the government, which prevented them from entering new markets and set them behind on their strategic and financial goals. In this case, we worked with the client’s leadership team for two years to lift the sanctions, which involved meeting with the government and today, that client is largely seen as a well-respected, model-actor for its programs and the government even goes to them often for input on their policy decisions.
6. What makes Ankura unique as a firm that provides expert testimony and compliance services?
I would certainly first point to our multidisciplinary approach and ability to tailor our solutions to the client every time. Of course, every consultant says that’s what they do but we truly do not use off-the-shelf solutions in any case – not a single one. You may not call us for a routine assessment, but in crisis situations or bet-the-firm moments, you call us. The other thing I’d say is that our diversity is unmatched. Not only is our team incredibly diverse, but we are also diverse in terms of our expertise, backgrounds, skillsets, and thinking. We have former regulators, C-Suite leaders, and skilled practitioners. We do not limit ourselves in our thinking and how we deliver our solutions.
That sort of diversity is incredibly important in today’s environment. Regulators have done a great job of hiring from industry (and vice versa) and the court has become increasingly adept at scrutinizing expert witnesses on major cases. Both regulators and the court have become increasingly efficient in seeing through a paper tiger compliance program or expert witness. When it comes to compliance, more than ever, you need to make sure your compliance program not only meets regulatory requirements but goes beyond that to protect and create enterprise value for your organization. On the witness stand, you must be able to show not only that you have the required expertise but also be able to engage and assist the trier of fact and the regulator on the issues.
“We’ve arrayed and structured our team in the same way so when we come to the table, you’re dealing with former executives, leaders, and practitioners who deeply understand the issues you’re facing from a variety of angles. That allows us to deliver better, more tailored solutions for our clients.” – Dorothy DeAngelis, Senior Managing Director
7. According to the WHO, women account for 70% of the global healthcare sector. Yet, at the executive level, women make up just 25% of leadership positions. As the leader of Ankura’s Healthcare Compliance and Disputes practice, when you think about women aspiring to a career in healthcare or in consulting what advice would you give to them?
The biggest piece of advice I can give to anyone is that, if you don’t feel like you have a seat at the table… build your own table. You’re going to face adversity – everyone does – but you have to stay true to your own voice. Oftentimes, young people get too caught up in doing whatever they think other people expect of them in order to be successful. Instead, you should lean in and try to show off your way of thinking, your background, and your expertise because that’s how you’re going to learn. The ability to carve your own path will come with time, but you have to put in the work to be ready to take it when it does.