I had the pleasure of attending my first Basic Compliance & Ethics Academy in San Francisco in February. While I expected to learn a lot about compliance, I walked away with way more material than will fit in one post! I’m kicking off a series of posts with this one, Compliance 101.
We kicked off the Academy with a lesson in basic compliance, and I was pleasantly surprised by one of the facts presented. Did you know that a vast majority of the non-compliant behavior in our organizations falls into one of two categories? It’s not because individuals are inherently bad applies, or rule breakers, but rather because of a lack of knowledge of the rules, or a lack of clearly defined expectations within the organization. This was encouraging to hear, because while it is seemingly impossible to rewire someone’s moral compass; education and awareness are two things that can be addressed with an effective and thoughtful compliance program.
[bctt tweet=”@SCCE Investment in #compliance programs to educate unknowing rule breakers will pay off in the long run.”]
Building an effective compliance program can prove to be a challenge in and of itself. The profession has many challenges, whether it be a company culture, buy-in from the top, or budgetary. However, the upside is that the investment in an organization’s compliance program to educate the majority of unknowing rule breakers will provide a vast payoff in the end. So how do we get the backing and support of the organization to implement these programs? A few suggestions were raised in our small group discussions:
- Code of Conduct – Have one… it’s a must. Make it simple and straight forward to the average reader. Be sure to take into account cultural factors such as presenting the code in other languages as needed. Be sure to have everyone sign and return their copy. Keep them in a separate file to make it easier on yourself if you ever need to provide bulk documentation to the OIG.
- Hold Ongoing Compliance Education and Training – Keep the organization up to speed on ethics and compliance requirements by holding initial training and onboarding, and reinforcing that training on a routine basis. Some folks are implementing quarterly refreshers, while others are holding annual check-ins.
- Seek Buy-In from Key Players within your Organization – “Tone at the top” plays a valuable role in successfully implementing and maintaining an effective compliance program. If others at the organization are watching leadership take these initiatives seriously, they will be more likely to participate in the training and education. If managers are held accountable for their team’s participation, you will likely see an increase in participation.
While there are many reasons to strive to implement an effective and thoughtful compliance program, the most motivating seems to be the mitigating effect one may have pursuant to the Federal Sentencing Guidelines. Considering these factors and investing in the program before there is an identified problem will inevitably be better for the organization in the long run, should any issues arise in the future.