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Hamlet-Inspired Rationale for the Thoughtful Use of AI

The Increasing Prominence of AI for Compliance Professionals

If you took a drink every time you heard the word “AI” at the recent Pharmaceutical Compliance Conference (PCC), you’d have been drunk before 10 AM. It seemed as if every presentation mentioned “AI”, including several exclusively focused on the topic.

“To AI or Not to AI?”

Many of the discussions centered on whether companies should use AI.

In one corner were those emphasizing the impact AI can have in streamlining manual tasks and advancing data analytics. Oversimplified, no need to hire, AI can do that.

In the other corner were those claiming that AI can never (or at least not in the near future) replace the human component of compliance programs.

The naysayers added that AI creates a myriad of new risks for the organization including access to confidential information, privacy concerns, and potential for error and put simply, needs to be approached with extreme caution.

With apologies to the Bard, I believe “To AI or Not to AI”? is the wrong question. Like the debate on rules vs. values-based compliance programs, the answer is both.

Generative AI is here to stay. And for any who refuse to approach it head on, I cite Hamlet’s Queen Gertrude — “the lady doth protest too much, methinks.”[1] Let us not be like Hamlet and allow our conscience to make cowards of us all. Instead, let’s focus on three critical questions:

1. What is AI best at?
2. How do we use generative AI effectively?
3. When should we not use AI?

I conversed with ChatGPT to flesh out these questions and found it immensely helpful. All text in blue was drafted by ChatGPT (often edited for brevity). The subsequent Hamlet quotes were largely identified by ChatGPT — including one from Henry IV. More on that later…

[1] Please note, gendered language used throughout this piece is specifically from Hamlet, written in ~1600).

What is AI Best at?

Automation of Repetitive Tasks

“Though this be madness, yet there is method in’t.” – Polonius

First and foremost, AI — and technology more broadly — should be used to automate manual processes. At Potomac, we often talk about the importance of sharpening your saw as conveyed in the 7 Habits of Highly Effective People. Undo the madness of performing the manual activity, identify the consistent method to it, and automate it. Technology is great at this.

There are many use cases for compliance professionals. Some are easily identifiable and have been available for years, such as aggregate monitoring and automated sanction screening. Others are newer, such as using tools like Microsoft Copilot to reduce formatting time. I cringe watching transparency professionals look up HCPs one at a time in the NPPES registry (if you do this, please, please reach out to me to stop that madness).

And as natural language processing continues to improve, there will be a growing host of automatable functions. For example, highly educated (and compensated) human beings in the Medical Affairs function frequently review doctors’ résumés to “tier” them as part of a “fair market value” assessment. In the future, this first pass could and should entirely be handled by machines.

Enhancing Creativity

“There are more things in heaven and earth, Horatio, than are dreamt of in your philosophy.” – Hamlet

The potential of generative AI in ethics and compliance transcends our current understanding, offering opportunities for innovation and advancement that may surpass our wildest imaginations.

Generative AI is exceptional at expanding initial idea generation. In Hamlet, the “play’s the thing.” When dealing with AI, you could say “the prompt is the thing.” The key is knowing where and how to prompt the discussion. Because Generative AI is best when building on existing creative ideas. It becomes an instant group brainstorming session. If you have an inkling of an idea, ask the AI for more. See what it says, and then ask for more details. It’s like having colleagues working with you on a whiteboard.

I don’t know about “surpassing our wildest imagination.” Maybe I haven’t mastered prompts. But in building this piece, I initially asked for Shakespeare quotes to help support this piece. When it provided an example from Hamlet, I pivoted and asked for more quotes from Hamlet and how to tie those quotes into my central theme.

If Hamlet is not your thing, ask generative AI for lyrics from Taylor Swift songs that relate to your latest Code of Conduct training. Or famous movie quotes…or…. Like any good brainstorming session, you’ll get good ideas and bad ideas; the key is to zone in on what you want to keep.

Motivation

“Something is rotten in the state of Denmark.” – Marcellus

I’m feeling a little “unmotivated” to write this one.

I submitted the following prompt to ChatGPT, “Can you tie the concept of motivation to starting something new with the quote “Something is rotten in the state of Denmark.” Aiming for something centered around how hard it is to get going when you are feeling “rotten” or unmotivated.“ (Note: I have edited the text below for length by deleting redundant paragraphs).

“Something is rotten in the state of Denmark” serves as a poignant metaphor for the internal state of disarray or discontent that can hinder our motivation to embark on new endeavors. Just as the characters in Hamlet confront the pervasive sense of corruption within their society, individuals grappling with feelings of disillusionment or stagnation may find it challenging to summon the motivation needed to initiate change or pursue new opportunities.

However, just as Hamlet ultimately confronts the corruption within his kingdom and takes action to restore order, individuals can overcome their internal barriers and find the motivation to initiate change.

Staring at a blank sheet of paper is hard. Generative AI can be a useful starting point to get a first draft moving. It need not cover everything but can help overcome that initial inertia. Especially when you are feeling unmotivated to tackle the corruption within your kingdom.

How do We Use Generative AI Effectively?

Validate Independently

“Doubt thou the stars are fire, Doubt that the sun doth move, Doubt truth to be a liar, But never doubt I love.” – Hamlet, as read by Polonius

“Here’s a list of 30 additional Hamlet quotes… 26. “The better part of valour is discretion.”

To which I immediately asked ChatGPT where I could find that quote in Hamlet. It responded:

“The better part of valour is discretion” is a famous quote from Shakespeare’s play “Henry IV, Part 1,” spoken by Falstaff in Act 5, Scene 4.

For those looking to use Generative AI to help provide compliance answers to complicated questions via chatbots and similar tools, I have serious concerns. While natural language processing is improving, there is still a tendency by GPTs to “hallucinate” and guess at responses even when facts are straightforward and easily verifiable. It’s obviously harder when different words are used in the questions than those specifically stated in the policy or training are fed into the system. There is a real risk of providing inaccurate guidance.

Others have covered this topic much better than I can. Maybe these hallucinations are the ghosts of Hamlet’s father. Over time, I imagine AI hallucinations will improve, potentially immensely. But right now, answers unchecked by human eyes can be troubling. “Doubt truth to be a liar.”

Edit for Clarity and Conciseness

“Brevity is the soul of wit.” – Polonius

Polonius’ wisdom reminds us of the importance of clarity and succinctness in communication.

GenAI ≠ “Clarity and succinctness.”

A friend and colleague of mine (who inspired this article) mentioned at PCC how much bad writing we’ve fed into the AI engine. It has not learned to be concise. Edit the output.

Organizational Preparation

“The readiness is all.” – Hamlet

ChatGPT did a good job with this one. I’ll let it explain:

Hamlet’s profound realization before the climactic duel with Laertes speaks to the importance of preparedness. When it comes to automating repetitive tasks with AI, readiness in terms of data preparation, infrastructure setup, and organizational alignment is crucial for successful implementation.

For those looking to use AI to develop risk-based insights, I’ll remind everyone of the importance of data quality: garbage in, garbage out.

And there must be organizational alignment on how and when to use AI securely to prevent loss of confidential information, protect privacy, and be net beneficial to compliance efforts.

When Should We Not Use AI?

People and Culture

“This above all: to thine own self be true.” – Polonius

Polonius encourages Laertes to prioritize authenticity and self-awareness…to maintain one’s integrity and moral compass…

Human interaction plays a crucial role in fostering trust and building relationships, especially in compliance investigations and audits….

Ethical dilemmas and complex compliance decisions require human expertise to consider factors such as intent, mitigating circumstances, and ethical implications…

Humans are better equipped to communicate findings, address concerns, and collaborate with stakeholders…

Human oversight is essential to ensure that AI systems are deployed ethically, responsibly, and in alignment with organizational values and regulatory requirements.

Our role as compliance professionals must expand with AI. We need to shift our own focus from the monotony of following the black and white “rules” towards the gray area of “values.” We need to step up our game and show thoughtfulness in evaluating complex scenarios. Only humans will be able to solve new and evolving compliance concerns that cannot be fed into the algorithms.

The job for building and enforcing the company’s culture will remain the job of the Compliance Officer. At the heart of that is our individual relationships with people. AI will not replace that.

Reflections on Potomac’s First 18 Years

Potomac turns 18 today. For Jewish people like me, the number 18 has special meaning. It stands for “life.” As Tevya sings in Fiddler on the Roof, Jews say “L’chaim!” which generally translated means, “to life.”

About Hebrew numerals

When I was in second grade, we learned Roman numerals in school, which was important if you wanted to read Super Bowl logos. My local team, the defending champion (at the time named) Washington Redskins, got crushed in Super Bowl XVIII to the hated (at the time) Los Angeles Raiders. All of us in the DC-area knew XVIII meant 18.

Ancient Hebrews also used letters to represent numbers. Each of the letters in the 22-character Hebrew alphabet represented a unique number. Rather than using five characters to represent 18, you only needed two.

The word chai (life) is made up of two letters: ח ( “chet” with a “kh” sound as in the guttural German pronunciation of “Bach”) is the 8^th letter of the alphabet so = 8. And The letter י (pronounced “yood” like yellow) is the 10th letter of the alphabet so = 10. These two letters form the word chai and add up to 18.  This is why the number 18 is associated with life.

L’Chaim – To Life and For Lives

While L’chaim generally means “To Life,” the “L-” sound up front is translated as both “to” and “for” in English. The word chaim is the plural of chai, so is more accurate as “lives,” not just one life. Put together, “For lives” is just as accurate as “to life.”

Some have claimed that l’chaim “expresses the idea that no one can live life alone. We all need someone else. There’s no point in toasting to life alone.” It’s not about one life – it’s for lives.

Reflecting on my life and Potomac’s lives

For the last 18 years, I have had a hard time separating my life from Potomac. I’ve admitted to my team on many occasions that I often take criticisms of Potomac as personal criticisms. When something goes wrong, I wonder what I could have done differently to have prevented it. On the external side (especially in the early years of the company) we worked hard to brand Potomac as being unique from “Jon’s company.” But personally, I felt like there was little separation between Jon’s life and Potomac’s life. It seemed like one life.   

But there is no point in toasting to life alone. We all need someone else. And to get to 18 years, I’ve had the benefit of working with many, many hard-working and dedicated people. We’ve had and currently have an incredible team. 

I am truly grateful for the more than 100 people who have worked for the company, whether as employees, independent contractors, or our third-party support partners. I am proud of the relationships built over the last 18 years. I have danced at our employees’ weddings, met their new babies, and wished others well as they left us for business school or other pursuits.  In several cases that included becoming our future clients.

I am especially appreciative of our senior team, who have worked tirelessly to embed our values of integrity, accountability, professionalism, and discretion into all that we do. Many of our team members have been with the company for more than 10 years. We would not be the company that we are today without their unwavering dedication.

The picture on the left below is from 2016 and of the 11 people pictured (besides me), 6 are still current team members—from left: Carla-Marie Ulerie, Adam Oakley, Meredith Swartz, Michael Young, Dan Koerner, and Graham Rich. I’m proud of that longevity.

Reflecting on our clients’ lives

We’ve had the privilege of working with over 150 companies and thousands of people.  Over time, I’ve watched as our client leads have gained promotions and changed roles, taken on wider responsibilities, or in some cases, opted to downshift and/or retire.   

Over 18 years, you get to know some of the people at those clients very well.  We work hard to become an extension of our clients’ teams and, in some cases, like our co-workers, our clients become our friends.  I’ve heard stories about weddings and divorces, babies being born and kids going off to college, exciting vacations to far-away places, and debacle home renovations.  This past month, one of my earlier and most fun-loving clients passed away relatively suddenly. That one touched a nerve – wasn’t prepared to add funerals to this list.  

18 = Becoming an Adult

About 10 years ago, a client described her company as a “gangly teenager” that was going through the awkward phase that many teenagers do. I hadn’t really thought about companies maturing in a similar way to humans but the more I thought about it, the more I realized it was true:

• Start-ups, like babies, need constant help and support.
• Young companies keep trying to make themselves seem older.
• Teenagers go through emotional growing pains, balancing not being a startup / kid anymore but not having the infrastructure / maturity of a full adult

And now, we’re 18 and Potomac is supposed to be an adult. In some ways, I feel like I’ve been preparing for this day for a while, getting my child Potomac ready to go off to college. Especially over the last year, when we’ve pursued a project appropriately named Operation Evolution. Part of its focus is to make the business less dependent on me. This included changing my role to allow the company the space it needs to grow and mature. And give me time to write these types of articles. 😊

Meanwhile, our senior team has stepped up and taken on additional responsibilities –ranging from Finance to HR to Business Development. The transition has been hard at times, but we are evolving and making progress.

Evolution is necessary to sustain life (and business). There will be more change to come as we work through new structures, processes, and approaches to remain a sustainable, long-term business.  We are committed to maintaining the level of excellence and teamwork that has marked the first 18 years of our life.

I personally look forward to also evolving my role back to where it started. Completing the circle of life, if you will.  In the months ahead, I am hoping to spend more time working directly with our clients.  I love wrestling through their most complicated issues, working together to make our industry more ethical.  And ultimately safer for the lives of patients.

In closing, I pledge to continue to work to make a difference in the lives of our team members and our clients. We will continue to be a great company that people want to work for and work with for the foreseeable future.

L’chaim. For lives.

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As a follow-up to my prior post on goals, I wanted to take a step back and focus on how to achieve your goals. The key is to have a plan. It sounds simple and obvious, yet it’s so often overlooked. As Antoine de Saint-Exupéry, author of The Little Prince once said, “a goal without a plan is just a wish.”

Why bother?

The ROI on Planning

Dale Carnegie once said, “An hour of planning can save you 10 hours of doing.”  I personally think Carnegie undersold it.  He only focused on you – i.e., the person doing the planning.  But most projects involve other people, often very large teams.  That hour of planning can easily save 10 hours per person.   Which makes the potential return on investment of planning exponential. 

How to get started

At Potomac, we teach a project management framework called Think-Plan-Do for project management.  It’s important to note: the thinking needs to come first. Understand your goals, objectives, and what you want to accomplish. Have a clear vision about what the end looks like. 

But the critical part for moving from vision to reality is the plan.  How will you achieve your objectives? What steps do you need to take? Who else should be involved?  

 Five tips that can help you be a better planner

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I failed to achieve one of my “SMART” objectives for 2023. Yet, I still fulfilled my intended goals.
The difference lies in the meaning of “goals” and “objectives” and the importance of articulating what you want to happen, as opposed to getting caught up in the measurement.

As we reach the new year, many people and companies right now are thinking about New Year’s resolutions and their overall goals. Many experts will talk about how goals need to be SMART. This is based on a framework initially developed by George Doran in an article in Management Review in 1981:

• Specific,
• Measurable,
• Achievable (Doran used “Assignable”)
• Relevant, (Doran used “Realistic”)
• Time-bound (Doran use “Time-related”).

I read the original Doran article for the first time this past week. While I’ve heard the term “SMART goals” for years, Doran used the term “SMART” to define corporate “objectives.” Without knowledge of the original Doran terminology, that is the term we’ve used at Potomac as well. We encourage Potomac employees to identify their goals and think about the best path forward to achieving them using a
framework that looks something like this:

• Goals = Plain text descriptions of what you want to happen in the future.
• Objectives = The steps that you will take to achieve your goals.
• SMART Objectives = How you will measure over a specified time period whether you are fulfilling your objectives.

My personal example:

Early last year, coming off shoulder surgery, I was concerned about its impact on my health. I knew many of my preferred exercise activities were now off-limits, including cancelling a planned ski trip with friends.
I wanted to ensure I stayed in shape, so I decided I wanted to walk more. I’d also been reading about the mental (and physical) health benefits of being outdoors for some portion of the day. I decided I wanted to spend more time outside. Lastly, since I often sit at a screen for much of the day, I thought that quiet time by myself would be beneficial for me and Potomac.

Goals

• I want to exercise more.
• I want to spend more time outside.
• I want to spend time by myself – without a screen (e.g., thinking, listening to music/podcasts).

I started 2023 by walking my neighborhood before work. I didn’t do it every day, but most. I’d also try and go for a longer walk/run on weekends. After a couple of months, I looked at my iPhone’s Health app and saw I was averaging 3,000 more steps than 2022. Being a math geek, I realized that would be more than 1,000,000 steps over the course of the year. I thought that would be really cool! 1 million more of anything sounded like a huge accomplishment.

I did some more math and to get to 1,000,000 more steps, I needed to average 2,740 more steps per day.
I felt that was hard, but achievable and led to my SMART objective:

Objective	SMART Objective
I am going to regularly walk my neighborhood on days with no commute	I will walk 1,000,000 more steps in 2023 than 2022 (as measured by my phone).

The Result:

The 3,000+ pace was tough to maintain. During the summer, I found it harder to keep up my walking habit, especially on weekends. By autumn, the average was down to 2,500 steps so I figured out how much I’d need to increase my walking to get to the 2,740 per day pace. I tried – but had a hard time increasing activity to the needed pace and remained flat throughout the Fall. By the end of October, I knew I was going to fall short.

As the year approached the finish line, with my shoulder now fully healed, our family went on a ski trip. I managed to ski 6 days and got the most exercise of any week I had the whole year! And all of it was spent outdoors.

Yet, my phone (correctly) didn’t count any of my skiing as “steps.” By December 27, I was down to 2,445 more steps per day than 2022, the lowest it had been all year. Multiply that by 365 and you get 892,425 more steps. I had failed to hit the 1 million step objective by more than 10%.

The Result, Part 2:

I am “goal-oriented” and don’t like missing objectives. It would be easy for me to dwell on being 100,000 steps short of my objective. But I was able to flip my mindset and focus on the original goals: I had exercised more, spent a lot more time outside, and had time to quietly reflect.

Goals	Achieved?
I want to exercise more.
I want to spend more time outside.
I want to spend time by myself (e.g., thinking, listening to music/podcasts).

It was during one of the walks that I came up with the idea to write this article. Keep your priority
focused on the outcome that you want to achieve, not the measurement.

Epilogue: 2024 Goals:

I am very much still working on how I want to implement these (more on that later), but I’ve come up
with a few goals so far for 2024.

• I want to write more
• I want to support Potomac’s goal of implementing a “teaching and learning culture”
• I want to stay in touch with people that I don’t communicate with often enough

I decided to start with this piece. I hope you’ll join me as I start my walk toward achieving my 2024
goals. Have a Happy New Year!

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