There is an old leadership principle: A leader's competence is measured by what they build, but their accountability is measured by what they ignore.
For nearly a decade at Centene, General Counsel Chris Koster has held primary responsibility for legal and regulatory oversight. Yet under his watch, the company has paid millions of dollars in state and federal settlements while the compliance infrastructure scrambled to contain the fallout.
To understand how a health plan incurs ten-figure regulatory penalties, one need only examine the appointment of Ashlee Knuckey as Chief Compliance Officer.
When Koster tapped Knuckey for the CCO seat, he elevated an individual directly from a law firm background, a litigator with no operational tenure in corporate compliance programs, no track record in managed care execution, and no prior experience as a Chief Compliance Officer.
What followed was four years of organizational turbulence disguised as a "compliance transformation."
Repeated internal escalations warned that the program lacked basic execution standards, structural clarity, and the foundational knowledge required to build an effective managed care compliance framework. These warnings were brushed aside. For four years, the enterprise operated in a state of compliance compromise, a persistent vulnerability that no amount of settlement checks can permanently ensure against.
Now, following Knuckey's exit, Koster has embarked on a series of "listening sessions" across the department. The timing invites obvious skepticism: where was he for the last four years?
Centene cannot pay its way out of fundamental governance failures indefinitely. Listening after the damage is done is not oversight, it is reputation management. If leadership failed to act on internal warnings when the compliance program was being dismantled, these listening tours are not a course correction. They are optics management.
Real protection requires leadership that understands what compliance actually entails on the ground. As Centene searches for a new Chief Compliance Officer, one directive must remain non-negotiable: do not hire another law firm attorney without operational compliance managed care experience. The next CCO must be a proven industry veteran who has successfully built and led compliance programs inside complex healthcare payers.
If Koster wants to demonstrate actual accountability now, he should step back from isolated decision-making and bring frontline Compliance team members directly into the interview process for the next CCO.
Otherwise, Sarah London needs to ask the hard question: after ten years and a billion dollars in regulatory costs, what, exactly, has Chris Koster been doing?!