Margaret C. Scavotto, JD, CHC
Management Performance Associates
Leading a compliance program is a lot like going to the gym. You don’t set up a gym in your basement, try out the treadmill and weight machines once, do ten sit-ups, and then cross the gym off your list and never go back. To thrive, your body needs you to go to the gym regularly, week after week, year after year. You might modify your gym routine sometimes, but we all know that to be healthy, it takes continuous work. An Olympian who quits the gym and never goes back quickly becomes out of shape.
Just ask Olympic gymnast Simone Biles. In 2016, Biles took home 10 gold medals, two silver medals, two bronze medals, and a Nike sponsorship. She’s also the first American woman gymnast to earn four gold medals at a single Olympic Games. Here is her daily workout routine:
“I have practice from 9 a.m. to 12 p.m. and then I drive home and eat lunch…head back to the gym from 3 p.m. to 6 p.m. and usually have more routines. After that, I either have therapy at the gym or at home, and then I eat dinner and chill and do it all again the next day.”
Six hours at the gym. That’s commitment – day in, and day out.
Compliance is the same way: You cannot have an effective compliance program without continuous work.
Do you know any compliance officers who bought a compliance binder online for $495? Or printed out some form policies from various websites, 3-hole-punched them, and put them in a binder titled “COMPLIANCE?” Are those binders stuck on a cobwebbed shelf somewhere? We call this the “Abandoned Home Gym Compliance Program.” Without training, audits, communication, and constant updates, a “binder” compliance program is not effective – even if the binder’s contents are fantastic.
Compliance takes work. Daily work (don’t worry, even Simone gets days off). This applies to a brand new compliance program, and to a sophisticated, “Olympic level” program. Standards evolve, regulations change, and compliance officers are always coming up with new bright ideas.
So, what’s the difference between an Abandoned Home Gym Compliance Program, and an Olympic Compliance Program? A routine. What’s your end game? How do you get there? Borrow from Simon Biles’ playbook and put together a schedule and a compliance routine. Let’s take compliance training as an example. If you are trying to move beyond the abandoned home gym, you might be doing annual employee compliance training – or no training. Here’s a sample compliance training routine:
- Yearly: Train employees, contractors and the board on compliance. Attend a compliance conference to keep up your expertise. Hold a Compliance Week with games and compliance trivia.
- Quarterly: Train staff on compliance risk areas.
- Monthly: Post compliance reminders.
- Weekly: Send compliance news to your Compliance Committee.
- Daily: Read compliance enforcement and headlines. Keep a list of new issues to add to your compliance program.
These examples are just a starting point, and soon your list will grow. But if you follow a routine and give your compliance program a regular workout, you can achieve medal-worthy results.