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Why CNOs care about compliance

By: Leah Curtin, RN, ScD(h), FAAN

It’s a matter of ethics.

Why do chief nursing officers (CNOs) care about compliance? From a purely pragmatic viewpoint, hospitals will quickly go out of business if they don’t meet standards. Receiving payment from the Centers for Medicare & Medicaid Services (CMS) requires complying with CMS Conditions of Participations (CoPs); since 1965, accredited hospitals were automatically deemed compliant with CoPs. More recently, The Joint Commission, DNNV, and other accrediting entities must apply to CMS for the hospital deeming authority required of all accrediting organizations. Although accreditation by these organizations is voluntary, CMS isn’t. CMS closes hospitals it finds to be seriously jeopardizing patient safety.

From a historical and humanitarian viewpoint, all those who allocate public monies for the public good have additional responsibilities. History richly documents an enduring belief that ethical stewardship is the key to producing economically relevant services and goods. For centuries, scholars have directed their ethical reflections, concerns, and principles to the formation of upright men and women who can be entrusted with the burden of decision-making that will lead to the general prosperity of the people—the common good.

The common good is the result, outcome, blessing, advantage, and reward of ethical administration. So, for the administrator, the obligation to act for the common good expands the demands of honesty to include accountability for the outcomes of those decisions. Therefore, business ethics have, by and large, been teleological, or outcome-oriented; all issues and actions are analyzed through the prism of results, aims, and purposes.

As nurses, CNOs have additional ethical and professional obligations. Like all their predecessors and models, CNOs derive their political and social advantages from their power to allocate the limited resources assigned to their discretion. And nursing leaders derive their moral authority to allocate resources from their clinical knowledge and professional commitments, which are expected to moderate a purely outcome-oriented ethic with one that also incorporates nursing’s obligations to patients and the public. As both nurses and administrators, CNOs are concerned about nursing ethics and business ethics. Although these two are not inimical, they are derived from different traditions that, in some cases, may lead to different conclusions.

Professional ethics derive from quite literally the “public promises” (from the Latin profiteer, the root of professional) that comprise the profession’s social contract to do no harm, to act in the patient’s best interests, to keep in confidence all private matters entrusted to one, to maintain competence, and to advocate for the patient’s needs. In other words, CNOs incur ethical obligations from their professional commitment to meet vulnerable patients’ needs and their stewardship of public investments entrusted and allocated to them. Their core ethical responsibility is to ensure safe patient care, the common good, and the fiscal viability of their organization. And this is why CNOs not only should care about compliance but actually partner with CMS, The Joint Commission, and other agencies concerned with ensuring patient safety.

– Leah Curtin, RN, ScD(h), FAAN, Executive Editor,
Professional Outreach, American Nurse Journal

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