Behind The Expert: Bringing Innovation To Healthcare Compliance And Disputes With Dorothy DeAngelis – Healthcare

Farma Darya

“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

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

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

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

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

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

“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

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.

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