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Q&A with Dennis Felty for October 2013 Compliance Department Newsletter

October 16, 2013

Can you please describe to our employees your role as Keystone Human Services’ President?
My central role as founding President of Keystone over the last 40 years is being an advocate for children and adults experiencing severe disabilities so that they can be valued and fully participating members of society.  My role has expanded at each step, but the mission hasn’t changed.  Over that time, there have been huge advances made allowing hundreds of thousands of persons with intellectual and mental disabilities return home from large institutions, but the fundamental issues remain in terms of what is the role of people with severe disabilities in society and what is our obligation to each other as a result of those experiences?  One of the understandings that comes out of that process is that issues of disabilities are an inherent part of the human experience and will touch every one of our families at some time in our lifetime.  Our challenge is deciding how to embrace that reality as part of our living.
What do you do to promote compliance and ethics as President of Keystone?
It’s important to help create an environment where people can really think about the importance and the meaning of their work and how it fits into the larger context of the vision we all hold for our society and our role within that vision.  I think a very important part of corporate compliance and integrity is encouraging and supporting people to do the right things for the right reasons, not simply because there is a contractual or regulatory obligation.
Can you discuss the evolution of compliance at Keystone as it relates to the changing human services field? How have the increasing regulatory requirements affected compliance?
The people at the county level had personal knowledge of the people being served on a daily basis.  If there was an issue, in most counties, there was a fairly significant level of oversight and accountability that existed, but it was a very individual and personal context for that happening.  For probably about the first 15 years of the community system, there literally were no regulations, either financial regulations, program regulations, or even licensing.  It was a time where, from my perspective, services were very high quality, very personalized, very individualized, a great degree of innovation and creativity being used to support people in a manner that was meaningful and relevant to them and their families.  What then happened, as the movement was supported by more and more resources, there was an increasing need for accountability for those resources, and we began to see regulations around financing and funding of services and then program regulations.  We also saw during that period saw a large amount of litigation brought by family members and advocates against the government, which drove tremendous change.  The product of litigation in almost all cases is that government will generate regulations around the implementation of their responsibilities in court orders and consent decrees that come out of litigation.  Family members and advocates historically have then brought additional litigation for noncompliance with the regulations as well as with other legislation that comes out of that process.  That actually drove tremendous change within the United States.  In fact, those changes would not have occurred without the extensive litigation.
What role do you think the Compliance Department plays at Keystone?
It has an extraordinarily important role in supporting the integrity of the organization and at its most fundamental level that integrity has to do is:  Are we doing what we say we’re doing?  It’s a very important set of eyes and ears that holds that question and asks the difficult questions in terms of when there is a divergence between what is actually happening and what our intent is.  It is also important that organizations fulfill their contractual and regulatory obligations as part of the very significant resources that are entrusted to our stewardship.  So it is a balance of both contractual and regulatory obligations as well as ethical and vision and values driven obligations.
How would you describe our leadership’s (including Board members) commitment to Compliance initiatives?
Our Board from the very beginning, even before the concept of compliance emerged in the corporate world, was very committed to honoring our commitments to the people we support and our funding partners.  There was always, at the Board level, a very deep commitment to accountable governance structures, to oversight, to reporting, to independent audits as part of their role as a governing board within Keystone.  As time passed, we began to see more external compliance and corporate integrity initiatives evolving as part of the expanding funding that was becoming available to human services.  That fit in very well with what was already underway at Keystone.
Finally, what directives do you have for the Compliance Department?
The greatest challenge for Compliance is to stay focused on issues that are really relevant and matter to the purpose and mission of the organization and the people that it supports.  We must carry out our contractual and regulatory obligations in a manner that holds the fundamental commitments to the people that are supported, their families and the community at large.

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