October 14, 2019

October 14, 2019

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October 11, 2019

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The Rise of the Chief Data Officer

There is a new kid on the block . . . the Chief Data Officer (CDO).  There is no surprise in our data-driven world that such a role would exist. Yet, many organizations struggle with defining the role and value of the CDO. Effective implementation of a CDO may be informed by other historical evolutions in the C-Suite.

Examining the rise of the Chief Compliance Officer (CCO) in the 2000’s mirrors some of the same frustrations that organizations faced when implementing the CCO role. While organizations were accustomed to having legal, HR, and internal audit departments working together to ensure compliance, suddenly CCOs stepped in to pull certain functions from those departments into the folds of the newly-minted Compliance department.  Integrating CDOs appears to follow a similar approach. Particularly in health care, the CDO role is still afloat, absorbing functionality from other departments as demand inside of organizations evolves and intensifies to focus on the financial benefits of their data pools.

Corporate evolution is challenging and often uncomfortable, but the writing is on the wall . . . there are two types of companies:  ones that are data-driven and ones that should be.  Which will you be?

What is a Chief Data Officer?

CDO responsibilities will vary depending on the organization. Some organizations position the CDO to oversee data monetization strategies, which requires melding business development acumen with attributes of a Chief Information Officer. In some organizations, the CDO may oversee the collection of all of the company’s data in order to transform it into a more meaningful resource to power analytical tools.

A survey of CDO positions identified three common aspirations that organizations have for the role: Data Integrator, Business Optimizer, and Market Innovator. Data Integrators primarily focus on infrastructure to give rise to innovation. Business Optimizers and Market Innovators focus on optimizing current lines of business or creating new ones. These aspirations will likely vary depending on the nature and maturity of organizations. Regardless of the specific role, CDOs can help organizations bridge the widening gap between business development, data management, and data analytics.

Further, a key component of a CDO’s activity will relate to responsible data stewardship.  CDO activities will heavily depend on developing a data strategy that complies with legal, regulatory, contractual and data governance boundaries around data collection, use and disclosure.  CDOs should work closely with legal counsel and compliance personnel to effectively navigate these challenges.  Further discussion of the legal and regulatory landscape around data use is available here.

The Importance of CDOs in Transforming Healthcare Companies

It is clear that leveraging data will be key to innovating, gaining efficiencies, and driving down costs over time.  Yet, many organizations continue to struggle with making sense of the data they possess.   For some, the CDO may be a critical driving force to advance a business into a new landscape.  Just as the CCO helped address decades of frustration with corporate ethics and practices (and was soon demanded by lawmakers and regulators), the role of the CDO has emerged in response to demand for efficiencies in business practices and the recognition that data has become the world’s most valuable commodity.

In light of the explosion of data in the healthcare industry, organizations should consider whether and how a CDO will fit into the corporate structure. Furthermore, organizations should work to understand how having a person at the table with a keen eye towards giving life to an organization’s data resources can benefit the business long term from internal and external perspectives.  The ultimate question a CDO can help solve is:  What don’t we know that, if we knew, would allow our organization to innovate or operate more efficiently or effectively?

©2019 Epstein Becker & Green, P.C. All rights reserved.

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About this Author

Alaap Shah Attorney Healthcare Life Sciences
Member

Alaap B. Shah is a Member of the Firm in the Health Care and Life Sciences practice, in the firm's Washington, DC, office.

Mr. Shah:

  • Advises clients on federal and state privacy and data security laws and regulations
  • Advises on cybersecurity and data breach matters
  • Advises clients on health care fraud and abuse matters and government investigations relating to health information technology
  • Counsels clients on digital health and data strategies and related compliance issues

His work focuses on defense and counseling...

202-861-5320
Andrew Kuder, Epstein Becker, Law Clerk
Law Clerk

ANDREW KUDER* is a Law Clerk – Admission Pending – in the Health Care and Life Sciences practice, in the Newark office of Epstein Becker Green. He will be focusing his practice on fraud and abuse, health care compliance, and privacy and security issues. 

Mr. Kuder received his J.D. in May 2018 from Seton Hall University School of Law and worked at the school as a Research Assistant, performing research and presenting information regarding veteran’s health accessibility on the state and federal levels to a not-for-profit health care trade association. While attending law school, he was a Fellow at a major health care insurer in New Jersey, where he researched and reported on the Affordable Care Act, health care compliance, and formal corporate risk assessments, and then served as an Extern at the New Jersey Office of the Attorney General, where he analyzed state and federal cybersecurity, privacy, and data protection standards.

973-639-5234