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CITI Program’s Managing Director on Research Ethics and Healthcare Compliance

Table of Contents

Introduction

Roy Snell of the Health Care Compliance Association (HCCA) recently sat down with Bharat Krishna, Senior Vice President and Managing Director at CITI Program. With a rich and diverse background spanning research, education, ethics, healthcare, and technology, Bharat brings a unique perspective to the evolving landscape of compliance and ethics education. In this interview, he shares insights on the importance of research ethics, the challenges facing healthcare compliance today, and how CITI Program continues to support learners and institutions worldwide.


Roy Snell is the ESG and Sustainability Officer for Osprey ESG Software. Roy is the co-founder of the Heath Care Compliance Association and the Society of Corporate Compliance. He is the author of Integrity Works and The Accidental Compliance Professional.

Bharat Krishna serves as Senior Managing Director and Senior Vice President at CITI Program, a worldwide leader in online education. His diverse background and experience in research, education, ethics, healthcare and technology gives us the unique opportunity to discuss a wide-range of issues in this interview.


Interview

Snell: Thank you for taking the time for this exchange, Bharat. Can you share a bit about your professional background and how it has shaped your views on research ethics and compliance?

Krishna: Thank you, Roy—it’s a pleasure to be part of this conversation! My career has been anything but linear, and that’s part of what has shaped my perspective. I grew up in Chennai, South India, in a family that straddled two worlds: science and creativity. My mom is a biomedical researcher, so dinner table conversations often revolved around the importance of rigor and ethics in science. And my dad is a documentary filmmaker who showed me how powerful storytelling can be in connecting with people and driving understanding. Together, they gave me a respect for both precision and human connection.

I started my professional career during the dot-com boom, immersed in technology and innovation. It was thrilling to see how quickly industries could be disrupted and reshaped. When that bubble burst, I went to MIT Sloan for my MBA, which gave me a stronger foundation in strategy and leadership. My time at McKinsey post-MBA was equally formative—it gave me a frontrow seat to how large organizations solve tough problems (or sometimes don’t!).

But I’d say my subsequent decade at Kaplan prepared me for the work I do today. Managing a global test prep business in over 60 countries taught me how culture and regulation shape industries—and how to navigate both with sensitivity and precision. Since 2018 at CITI Program, I have had the privilege of leading a team that reaches nearly 2 million learners across more than 2,500 organizations. It’s incredibly fulfilling to know we’re playing a role in advancing research ethics and healthcare compliance worldwide.

Snell: What historical events laid the foundation for the modern research ethics movement, and how do they continue to shape our practices today? Can you also share a recent example where ethics in research came under scrutiny?

Krishna: That’s a fantastic question because it’s critical to understand how history has shaped where we are today— and how those lessons still apply. The origins of modern research ethics stem from moments of profound failure. After World War II, the Nuremberg Trials exposed the atrocities of unethical medical experiments conducted on prisoners of war, which led to the creation of the Nuremberg Code. This was one of the first documents to advocate for principles like informed consent and the need to minimize harm in research.

Later, in the U.S., the PHS Syphilis Study became another painful turning point. For 40 years, treatment was withheld from African American men with syphilis, even after penicillin became widely available. This tragic study highlighted the dangers of systemic inequities. It led to the establishment of Institutional Review Boards (IRBs) and the Belmont Report, which introduced the guiding principles of respect for persons, beneficence, and justice.

Unfortunately, ethical lapses aren’t just relics of the past. Take the case of Facebook’s 2012 “emotional contagion” study, where researchers manipulated the news feeds of nearly 700,000 users to see if positive or negative content affected their emotions. The study was done without informed consent, sparking widespread backlash and raising questions about the ethical obligations of tech companies researching human behavior. It’s a modern reminder that ethical challenges evolve alongside new technologies.

These examples—both historical and modern—illustrate that ethics isn’t a static concept. It requires constant vigilance and adaptation to ensure we’re protecting individuals and maintaining public trust, whether we’re conducting biomedical research or studying human behavior in the digital age.

Snell: Regulations like the Common Rule play a key role in ensuring ethical research. When these regulations are updated, how does CITI Program help institutions adjust?

Krishna: That’s a great question. The Common Rule is the backbone of ethical research involving human subjects— it sets out the standards for protecting research participants. But updates often create a ripple effect for institutions, which have to adjust their policies and practices quickly.

That’s where CITI Program steps in. Our job is to help researchers, IRBs, and institutions understand and implement new requirements effectively. When the Common Rule was last revised, we swiftly updated hundreds of training modules to align with the new guidelines. We also held webinars, created resources, and offered practical advice to help organizations navigate the changes smoothly.

But it’s not just about compliance. We want people to understand why these regulations exist—how they safeguard both participants and the integrity of the research itself. When you understand the “why,” compliance becomes not just a box to check but part of a larger commitment to doing research ethically and responsibly.

Snell: Research laws and ethics are often mentioned together, but they’re not the same. How does CITI Program approach teaching each of these areas?

Krishna: Laws and ethics might overlap, but they require very different approaches to teaching. Laws are structured and explicit, outlining what you must do to comply. When we teach regulations like HIPAA or FDA guidelines, we focus on practical application: understanding the rules, implementing them effectively, and avoiding compliance risks. It’s about making the requirements clear and actionable.

Ethics, however, is a different conversation. It’s about navigating situations where the answers aren’t always black and white. For example, how do you balance the potential societal benefits of a groundbreaking study against risks to individual participants? Ethics is more about judgment and values, and we train using case studies and reflective exercises. These tools help learners think critically and tackle complex, real-world dilemmas with confidence.

At the end of the day, whether we’re teaching laws or ethics, we tailor our online courses to the topic and learning objectives. Some focus on compliance, others dive into ethical decision-making, and many integrate both to provide a holistic understanding.

Snell: CITI Program is widely known for its research ethics training. Beyond research compliance, what other areas do you support, particularly in healthcare and life sciences?

Krishna: That’s a great starting point because while most people associate us with research ethics, our offerings have expanded significantly over the years, especially in healthcare and life sciences.

In the clinical research space, we provide training on Good Clinical Practice (GCP), which is essential for running clinical trials that comply with FDA and ICH guidelines. Another popular course is our Clinical Research Coordinator (CRC) training. It’s designed to help research staff build their skills while staying aligned with regulatory expectations—something that’s often a moving target in this field. We’re also well-known for our animal care and use training, which ensures ethical and compliant care in nonhuman animal research.

But we don’t stop there. Environmental Health and Safety (EH&S) has also become a big focus area for us. We’ve developed training on biosafety, chemical safety, and working with infectious agents—critical topics for research labs and healthcare organizations that need to stay compliant with OSHA or NIH guidelines while keeping their teams safe.

And, of course, there’s healthcare compliance itself. From HIPAA to the FCA, our training helps institutions protect their patients and their reputations. It’s been especially rewarding to see how hospitals, academic medical centers, and even smaller organizations have used our resources to build safer, more compliant environments for their communities.

Snell: Many organizations, from hospitals to biotech companies, rely on CITI Program for more than research ethics training. Why do you think they turn to CITI Program for broader compliance and professional development?

Krishna: It really comes down to trust. Organizations see us not just as a training provider but as a partner they can rely on. Healthcare and life sciences operate in incredibly complex regulatory environments, and institutions need more than just a checklist—they need resources to help them navigate these challenges.

For example, a hospital might come to us for IRB training or Responsible Conduct of Research (RCR) courses. But once they see the depth of our content, they often turn to us for other needs, like HIPAA compliance or healthcare fraud prevention. Pharmaceutical companies might initially focus on our GCP training for clinical trials but then find tremendous value in courses on conflict of interest or strategies for increasing diversity in clinical research. And even tech companies entering the healthcare space are reaching out for guidance on AI governance, data privacy, and cybersecurity.

What sets us apart is the quality of what we offer. Every course is peer-reviewed and authored by experts, which gives institutions confidence that the material is accurate and relevant. We know that no two organizations are the same, so we provide flexible, customizable solutions that fit their unique priorities. At the end of the day, it’s not just about ticking the compliance box—it’s about empowering teams and building their capabilities to thrive in a demanding environment.

Snell: Can you share specific examples of recent solutions CITI Program has developed that are particularly relevant for healthcare compliance professionals?

Krishna: Absolutely. Healthcare compliance is such a dynamic field, and we’ve worked hard to develop resources that meet the real-world needs of professionals in this space. Of course, privacy and data protection remain top priorities, and our HIPAA series has been a cornerstone for many organizations, especially with the rise of telemedicine and digital health tools.

But we’ve also broadened our focus to address some of the more nuanced challenges healthcare professionals face. For example, our course on Healthcare Ethics Committees helps participants navigate the difficult and often sensitive ethical dilemmas that arise in medical settings. It’s designed to help committee members approach these situations with clarity and confidence.

We’ve also introduced training for medical residents and fellows, which focuses on equipping early-career clinicians with the foundational knowledge they need to participate in or lead research projects responsibly. Another area where we’ve been active is federal fraud, waste, and abuse. This training helps organizations understand and address these risks, which are critical for compliance with federal regulations.

Billing compliance in clinical trials is another important topic. We developed a course to help organizations manage the complexities of trial billing and avoid the risks that can come with mistakes in this area.

Beyond courses, we’ve also hosted webinars on emerging issues like decentralized clinical trials and the ethical implications of AI in healthcare. These sessions allow professionals to engage with timely topics and walk away with actionable insights they can apply immediately. The feedback has been great—people value how practical and relevant the discussions are to their day-to-day challenges.

At the end of the day, our goal is to support healthcare compliance professionals by providing tools and resources that help them navigate this ever-changing landscape with confidence.

Snell: How does CITI Program set itself apart in helping institutions across different sectors address their compliance and professional development needs?

Krishna: What sets us apart is our perspective on education. For us, it’s not just about ticking boxes to meet compliance requirements. We’re focused on creating practical learning experiences, engaging and genuinely helping people excel in their roles.

We also work closely with hospitals and healthcare organizations, where our HIPAA compliance, biosafety, and Environmental Health and Safety (EH&S) training are especially valued. What’s key here is that our content isn’t static—we’re constantly evolving. Whether it’s developing a course on the European Union AI Act (EU AI Act) or diving into AI governance and ethical challenges, our team tries to stay ahead of the curve.

Institutions appreciate the depth and quality of our content. Everything we produce is peer-reviewed and built by subject-matter experts, so they know they’re getting accurate and reliable information. That’s why so many organizations see us not just as a training provider but as a trusted partner in navigating their compliance and professional development challenges.

Snell: AI is transforming so many industries right now, including research. How is CITI Program responding to this shift?

Krishna: It’s an exciting time, isn’t it? AI has the potential to reshape how we approach research, and we’re focused on staying ahead of the curve. For starters, we’ve introduced a course on the EU AI Act, which dives into the complexities of AI regulation in the European Union. It’s designed to help learners understand the rules and broader implications of using AI responsibly.

We’re also developing an AI Governance course to help institutions create frameworks for ethical AI implementation. And for IRBs, we’re creating resources to support their evaluation of AI’s role in human subjects research—particularly in areas where ethical considerations are nuanced and require deeper reflection.

Internally, we’re exploring how AI can improve what we do. It’s already helping us streamline operations and make our courses and engagement with learners more dynamic. That said, while AI is a powerful tool, it still has limitations when understanding the nuances of ethics and human decision-making. That’s why we rely on human expertise to shape the thoughtful, high-quality content we’re known for. AI is helping us improve, but the heart of our work remains grounded in human insight.

Snell: With AI playing an increasingly important role in compliance and research, how do we ensure it’s used responsibly?

Krishna: It really comes down to transparency and accountability. Organizations need to approach AI with a clear governance framework in place—one that tackles issues like minimizing bias, explaining how decisions are made, and ensuring accountability for outcomes. Without these safeguards, the risks can quickly outweigh the benefits.

AI has enormous potential in compliance. It can flag patterns of risk, predict potential issues before they happen, and even streamline decision-making processes. But it’s important to remember that AI isn’t there to replace human judgment—it’s a tool to support it. The kind of nuanced thinking and ethical considerations that people bring to the table are still irreplaceable, at least for now. The goal should be to use AI to enhance decision-making, not to take over the process entirely.

Snell: Misinformation and science denial seem to be growing issues. What can researchers and institutions do to push back against this trend?

Krishna: It’s definitely a challenge and one that’s only gotten more visible in recent years. Misinformation and science denial often stem from a breakdown in trust or a lack of understanding. For researchers and institutions, the starting point has to be clear, relatable communication. It’s not enough to publish findings in a journal, and hope they resonate—we need to make science accessible, transparent, and human.

At CITI Program, we have a course called “Communicating Research Findings” that focuses on helping researchers present their work in a way that connects with people. But beyond that, education plays a huge role. Teaching critical thinking and media literacy—how to question sources, evaluate evidence, and understand context—is essential to helping people navigate the flood of information they’re exposed to daily.

At its core, science denial isn’t just about data or facts—it’s cultural. Combating it requires empathy, engagement, and a willingness to meet people where they are. We’re also exploring how we can address this on a broader level with future training and resources because this isn’t an issue that will resolve itself overnight. It’s a long-term effort, and it will take all of us—scientists, educators, and institutions—to rebuild that trust and bridge the gaps.

Snell: You’ve worked internationally in a variety of markets. What leadership lessons have you taken from those experiences?

Krishna: Working internationally has been one of the most enriching parts of my career. When dealing with partners and employees in dozens of countries, you quickly learn that context is everything— cultural norms, regulatory landscapes, and even communication styles can vary so much from one place to another.

One lesson that sticks with me came from a situation in which an international partner was upset over a contract we decided not to renew. What started as a business decision escalated quickly, with emotions running high and local legal considerations coming into play. It was a reminder of how complex these situations can get and how important it is to rely on the right experts—whether that’s local advisors, legal counsel, or your team.

Perhaps the biggest takeaway was this: leadership isn’t about having all the answers. It’s about knowing when to listen, building trust, and working collaboratively to find a path forward. That situation was a curveball, no doubt, but it taught me how important it is to approach challenges with humility and resourcefulness. Experiences like that shape you as a leader—and honestly, they make you better prepared for the next curveball.

Snell: You’ve talked about the challenges of bias in compliance. What steps can organizations take to reduce its impact?

Krishna: Bias is one of those things that can sneak into decision-making in so many ways, and it can undermine trust if it’s not addressed. It could be confirmation bias, where we lean toward evidence that supports our beliefs, or anchoring bias, where our initial impressions overly influence our judgments. The first step for any organization is acknowledging that bias exists—it’s human nature—but then taking proactive steps to counter it.

At CITI Program, we stress the importance of bringing diverse perspectives into both training and decision-making processes. When you have a team that’s diverse in backgrounds, experiences, and viewpoints, and they’re encouraged to challenge assumptions, you’re naturally better equipped to spot and address bias. Training plays a big role, too. Helping people understand the types of bias and how to recognize and mitigate them is essential to fostering fair and thoughtful decision-making.

Then, there’s bias in AI, an emerging area of concern. The truth is, I’m not sure there’s such a thing as a completely unbiased dataset—it’s all influenced by the people and systems that create it. So, the focus has to shift toward minimizing bias where possible and understanding how to work with it responsibly. It’s not an easy fix, but the key is awareness, transparency, and a commitment to continuous improvement.

Snell: You’ve mentioned that Malcolm Gladwell’s Revisionist History podcast is one of your favorites. Is there a particular quote or take away from it that stands out to you, and what draws you to his podcast?

Krishna: Yes, Revisionist History is one of my favorites and a podcast that makes you think differently about the world. As an auditory learner, I enjoy how podcasts let me absorb insights while on the move, whether I’m walking or just reflecting. Gladwell has this incredible way of taking overlooked or misunderstood moments in history and reexamining them in ways that reveal surprising truths.

One idea he often comes back to is that “the act of remembering is a creative process.” While I don’t think this is his original quote, he’s used it to frame how memory is shaped by what we learn over time. That resonates with me, particularly in the context of ethics and compliance training. So much of what we teach at CITI Program is about understanding lessons from the past—often hard lessons where mistakes or lapses led to significant consequences for individuals or institutions. It’s about taking those stories, viewing them through a fresh lens, and using them to inform better decision-making.

I also appreciate how Gladwell connects seemingly unrelated ideas to tell a personal and universal story. That’s very much how we approach our training. Ethics and compliance are nuanced topics—they’re not just about memorizing regulations but understanding the underlying principles and the human decisions behind them. By learning from historical missteps and successes, institutions and individuals can build frameworks that prevent problems and foster trust and integrity in the long term.

Snell: CITI Program has been producing podcasts as well. What can you tell us about them, and what makes a podcast successful in your experience?

Krishna: Podcasts have been a great way for us to engage with our audience in a fresh, accessible format. At CITI Program, we’re always looking to make complex topics like ethics, compliance, and emerging trends easier to understand and apply. Our three series—On Campus, On Tech Ethics, and On Research—each focus on unique challenges. For example, On Tech Ethics has explored the ethical implications of synthetic data in healthcare and research, a topic that’s becoming increasingly relevant.

In my experience, relevance and clarity make a podcast successful. You need to address issues people are actively grappling with and present them in a conversational way that feels approachable but still substantive. We aim to keep episodes concise, bringing diverse experts to provide practical insights.

The feedback has been encouraging. Listeners tell us they value how actionable and relevant the discussions are to their work. For us, that’s the goal—sparking thoughtful conversations and providing tools that professionals can use right away, just as we strive to do with our broader training efforts.

Snell: Your team conducts many webinars for professionals. What styles work best for this format, and what kind of feedback do you typically hear from participants?

Krishna: Webinars are a great way to tackle important topics in an accessible and practical format. In my experience, keeping things interactive and focused on real-world applications works best. People don’t want to sit and listen—they want to see how the content applies to their work and have the opportunity to engage with it. Including time for Q&A or breaking down ideas into relatable examples significantly affects how participants connect with the material.

At CITI Program, we’ve hosted webinars on various relevant topics, like Handling of Hazards in Research Animal Facilities and Study Start-Up: Challenges and Strategies. These sessions bring in subject-matter experts who share valuable insights and actionable ideas that participants often tell us are incredibly helpful.

One feature of our webinars that participants appreciate is how our tech platform supports their learning. For example, all webinars come with transcripts, and learners can search by chapter or keywords, so if there’s something they want to revisit later, it’s easy to find. It’s handy when they’re working through a challenging issue and wish to review a specific point.

The feedback we get consistently emphasizes the clarity and practicality of our webinars. People appreciate that we focus on timely, real-world issues and deliver content they can use immediately. We’re always looking for ways to improve— whether by adding more scenario-based learning or incorporating panel discussions. Ultimately, a successful webinar respects the audience’s time while equipping them with tools and insights to solve the challenges they face every day.

Snell: Personal development seems to be a priority for you. How has it shaped your leadership style, and how do you manage to continue learning with such a demanding schedule?

Krishna: Lifelong learning is something I’ve committed to throughout my career— it’s essential for personal growth and effective leadership. Staying curious and informed helps me make better decisions, but just as importantly, it keeps me adaptable in an environment that’s always changing. I don’t think leadership is about having all the answers. It’s about knowing where to look for them and how to ask the right questions, whether that’s turning to your team, your peers, or other resources.

Of course, time is always a challenge. That’s where microlearning and just-in-time learning really work for me. Podcasts, short articles, or quick reads are great ways to fit learning into a packed day. For example, while walking or exercising, I’ll listen to a podcast at 1.5x or 2x speed—it forces me to focus, and I can learn something new while getting my steps in. I’ve also realized that some of the best learning comes from conversations. I make it a point to listen to colleagues and team members—it’s amazing how much insight you can gain just by being open to other perspectives.

We live in a time when access to information has never been easier. It surprises me that more people don’t take advantage of the accessible or affordable learning resources available. Learning is not about adding it to your to-do list; it’s about making it part of how you move through the day. That mindset has been invaluable to me, both personally and professionally.

Snell: People often describe you as a down-to-earth leader. Do you think that’s accurate, and what do you believe are the most important traits for effective leadership?

Krishna: That’s kind of you to say, and I’d like to believe it’s true. Being down-to-earth doesn’t mean being less ambitious or driven—it’s about staying approachable and grounded, no matter how big the challenges or goals may be. Leadership is about service at its core: listening, understanding, and doing what you can to support your team as you work toward shared goals.

One trait essential for leadership is humility. None of us has all the answers, and pretending otherwise only erodes trust. Being humble also makes you more open to input and collaboration, which is critical to making better decisions. Empathy is another cornerstone—it helps you connect with people, whether they’re colleagues, clients, or stakeholders.

That said, humility shouldn’t be confused with indecisiveness. At some point, a leader must take all the input, weigh the options, and make a call. And that’s where resilience comes in because you’ll face setbacks—it’s inevitable. How you navigate those moments and the calmness you project can set the tone for your entire team.

Ultimately, leadership is about balance: being confident enough to make decisions while staying humble enough to learn and adapt as you go. It’s not always easy, but I have found it is a rewarding way to lead.

Snell: You’ve mentioned that your career path hasn’t always been linear. Do you think taking a winding road helped shape your success?

Krishna: Absolutely. My career path has been anything but straightforward, and I think that’s been one of my biggest assets. From what I know of your own story, Roy, it sounds like you’d agree! You’ve gone from horticulture to computer programming, healthcare administration, consulting, and eventually leading HCCA and SCCE—talk about a winding road that worked well.

I started in technology during the dotcom boom, then explored media before transitioning to consulting and, later, education. Each of those experiences taught me something unique. Technology gave me a firsthand view of how innovation reshapes entire industries. Consulting showed me how to break down problems and design practical, impactful solutions. And working in education has reminded me of the power of learning and how critical it is to keep evolving.

I think that kind of “wandering” can give you a broader perspective, which is invaluable as a leader. It helps you connect the dots between seemingly unrelated challenges and develop creative approaches. Some of the best insights, in my experience, have come from unexpected places—things I learned years ago in a completely different field that suddenly became relevant again. That’s why I encourage people not to fear a nonlinear path. Sometimes, it’s the detours that teach you the most.

Snell: Ethics can be a challenging topic. How can organizations create a realistic and inclusive definition of ethical culture?

Krishna: That’s a great point—ethics can feel like a big, abstract concept, but creating an ethical culture starts with something very practical: clarity and shared values. It’s not about expecting everyone to agree or push a single perspective. Instead, it’s about fostering respect, transparency, and accountability as foundational principles.

Open dialogue is key here. Organizations must create safe spaces for people to ask questions, share concerns, and discuss ethical behavior in their specific context. Training plays a role in this, but more importantly, culture is shaped by what leadership models. Leaders who act with integrity and empathy set the tone for everyone else. Ethics is something you live, not just something you teach.

I’ve seen firsthand how critical this is. Early in my career, I worked for an organization where the culture had taken a serious hit because of top-down ethical lapses. A senior colleague summed it up perfectly when they said, “The fish stinks from the head.” That phrase stuck with me, and it’s a constant reminder of how much influence leadership has. If you want to build a truly ethical culture, it has to start at the top. Leaders need to embody the values they want their teams to follow.

In the end, ethical culture is about action. It’s not just having a mission statement or running a training session—it’s about showing, through consistent behavior, what your organization stands for. That’s what inspires trust and accountability.

Snell: What’s one of the most memorable or thought-provoking questions you’ve ever been asked, and why?

Krishna: That’s an interesting one. A question that’s stayed with me came from a colleague who asked, “What keeps you going, especially when things aren’t going your way?” It caught me off guard at the time because it’s not something I’d consciously thought about. And things weren’t going my way when the question was posed to me. I had to sit with it for a while, and the more I reflected, the more I realized how much it comes back to purpose.

For me, purpose is about the impact we can have. Knowing that the work we do at CITI Program supports researchers, institutions, and entire communities keeps me grounded, even when challenges arise. There’s something gratifying about contributing to a mission that promotes trust and integrity in research and compliance. It reminds me that the hurdles we face are worth it when the end result helps people make a difference in their fields.

It’s also the people I work with—they’re a huge source of motivation. Seeing their passion and commitment, whether in creating high-quality training or engaging with learners, is energizing. It’s not just about the work itself; it’s about being part of a team that genuinely cares about making an impact.

That question helped me define what drives me, and I think it’s essential for anyone to ask themselves. It forces you to focus on what matters most and reconnect with the deeper “why” behind what you do.

Snell: If you could go back to any time period, where would you go and why?

Krishna: I’d jump right back to the dot-com boom of the ’90s or the Web 2.0 era of the 2000s. The ’90s felt like the internet’s Wild West—big ideas, big risks, and a lot of “this will definitely change the world… once we figure out how to make money.” The Web 2.0 era was more polished, with social media and platforms making the Internet feel collaborative and user-driven.

That said, if I could go back, I’d invest heavily—and early—in Apple, Google, or Microsoft. I’d probably also tell my younger self to hold onto those shares no matter how tempting a new tech IPO sounded! Looking at today, I think we’re in another one of those transformative moments with AI. It’s exciting and chaotic, and part of me wonders which AI startups will be the Googles of this era—and which ones will end up being the digital version of pet rocks.

Snell: You enjoy golf, and analogies often appear in your discussions. What lessons from golf resonate with your work in compliance?

Krishna: Golf is full of lessons that resonate with compliance, especially when it comes to education and training. One of my coaches used to say, “You miss a hundred percent of the shots you don’t take.” It’s a simple line, but it stuck with me because it’s so true for compliance. Sometimes, people think compliance is just about avoiding risk, but really, it’s there to support innovation. In research, for example, compliance frameworks exist to help people push boundaries responsibly, not to hold them back.

Another parallel is the importance of preparation and adaptability. You don’t just show up in golf and expect to hit every shot perfectly. You practice, adjust to the wind or the course conditions, and keep refining your game. The same is true in compliance training. Regulations are always evolving—kind of like the weather on a golf course—so it’s about staying sharp, learning continuously, and being ready to adapt.

Mistakes are inevitable, whether it’s a bad swing or misinterpreting a regulation. What matters is how you recover. In both golf and compliance, the goal isn’t perfection—it’s progress. If you focus on the fundamentals, like regular training and staying curious, you’re better equipped to navigate challenges and, ultimately, drive innovation.

Snell: What is a key takeaway you would like to leave us with?

Krishna: Compliance isn’t just about following the rules—it’s about trust, progress, and responsibility. At its best, compliance supports innovation, particularly in areas like research and healthcare, where the stakes couldn’t be higher. It creates the guardrails that allow organizations to take those critical “shots” and make a meaningful impact while staying ethical and accountable.

Whether it’s addressing AI’s ethical challenges, navigating the complexities of healthcare billing, or ensuring clear and transparent communication in science, compliance professionals are at the intersection of integrity and innovation. They’re not just preventing issues; they’re helping shape the future. That’s a responsibility we all share.

I’m incredibly proud of the team at the Collaborative Institutional Training Initiative—CITI Program—and the work we do. The “Collaborative” in our name is more than just a word; it’s a mindset. Everything we create, from courses to webinars, is built with input from experts, peer reviewers, subscribing institutions, and learners themselves. Their feedback and insights are what make our programs relevant and impactful. It’s a privilege to work with such dedicated partners who care about building trust, advancing research, and ensuring ethical progress across the industries we serve.


This interview was posted from the Journal of Health Care Compliance, Volume 27, Number 1, January–February 2025, pages 29-38, 50, with permission from CCH and Wolters Kluwer. For permission to reprint, e-mail permissions@cch.com.


Bharat Krishna and the CITI Program logo
An Interview with Bharat Krishna on Research Ethics and Healthcare Compliance Download Interview