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SCCE/HCCA

Corporate Compliance & Ethics Week is Moving

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2014-snell-roy-speaking-headshot-200By Roy Snell
roy.snell@corporatecompliance.org

We have been celebrating a week in the spring called Corporate Compliance & Ethics Week, for some time. The week has been moved from the spring to the fall (November 1-7 in 2015) to coincide with the anniversary of the creation of Chapter 8 of the Federal Sentencing Guidelines. It may cause a little confusion this year, but it should be fine over the next couple years. Everyone should feel free to celebrate compliance and ethics whenever they want. However, we will benefit from respecting the document that is generally credited for the creation of our profession, as well as respecting a document that suggests there are financial incentives to hiring a compliance officer and implementing a compliance program. We will continue to offer Corporate Compliance & Ethics Weeks products (posters, pens, mugs, etc.) to help you with your celebration.

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For those of you who are new to Corporate Compliance & Ethics Week, it is intended to help promote a better understanding of compliance and ethics programs. It is celebrated by individual institutions and is typically coordinated by the compliance officer. Some compliance officers get other departments involved. Corporate Compliance & Ethics Week is helpful to send a message to all employees that leadership believes compliance and ethics is important. Celebrating the week can be as simple as just putting up a few posters, or as elaborate as holding all-staff meetings with leadership speaking and giving compliance and ethics awards. It’s really just another excuse to make a little fuss to help the organization maintain their gains, and perhaps make a little more progress toward a compliant and ethical culture.

If you have any questions don’t hesitate to call our office or check out the Corporate Compliance & Ethics Week website.

 

Live from Managed Care – Compliance Executive Communications: What do Business Leaders Really Want to Know?

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by Kortney Nordrum, CHC

Presentation by:

Alison Green, Director, Compliance Program & Reporting, UnitedHealthcare Medicare & Retirement
Steve Bunde, Vice President, Internal Audit and Integrity and Compliance, HealthPartners
John Tanner, Medicare Compliance Officer, AVP, Molina Healthcare, Inc.

Do your leaders say, “That’s great information, but how is the compliance department doing compared to the rest of the industry?”

There are several ways to help communicate to your leadership how you’re doing as a compliance department. One way to do that is to show them the trends. Answer the questions, “Are we getting better? Are we getting results?”

To help you do this, answer the following questions:

  • Are we getting complaints to the Compliance department? Questions? Reports?
  • Are you resolving the issues as they are reported?
  • What is your culture?
  • Do you have a management issue? A training issue?

Another way to benchmark for leadership is through audit readiness. The speakers suggest putting together a dashboard that shows where you stand. Use bright colors to get their attention. For example, use bright red for potential ICARs (Immediate Corrective Action Required). After all, the purpose is to get your senior leaders’ attention and get the resources you need to remediate any issues before they become even more problematic.

You can also perform a mock audit. If you do, graph those results out for your leaders. When you present your mock audit findings, make it clear where your program currently stands, compared to what CMS expects.

When preparing your leadership for audits (and to some extent for mock audits), it’s important to set realistic expectations, for your organization and your senior leaders. CMS had told the industry where the problems are, and what to do to remediate those problems. It’s your job to do that in your program. However, you need to let your leaders know that every CMS audit since 2010 has resulted findings. It’s your job to set the expectation with your leaders that there will be findings and corrective actions will be necessary. Finally, you can report on enforcement actions throughout your industry. This will help to let leadership know what the industry expectations are and give context to the audit results.

The speakers also suggested regularly reporting your compliance program metrics to your business leaders. This would include:

  • How many of each type of reports do you have?
  • How many incidents lead to investigation?
  • Are the calls you’re receiving reference or research questions, where employees are asking questions of the compliance department?
  • How many of the reports are referred out to different departments, HR for example?
  • How many of your incidents are still open more than 30 days out? If incidents are more than 30 days old, can you identify why?
  • How complex are your incidents?
  • Do you have adequate staffing to handle what’s coming into the compliance department?
  • Is Compliance properly delegating work to others?

With these metrics, and the audit/mock audit results, you should be able to provide an accurate, helpful snapshot of your compliance program to your executive leaders.

Celebrating Corporate Compliance & Ethics Week: Is truth bad for business?

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A new report by the Ethisphere Institute identifies areas companies should work on to enhance transparency across all operations.

The release of the 2014 Ethics Communications Best Practices Report coincides with SCCE’s Corporate Compliance & Ethics Week May 4-10, a national week-long event that recognizes the importance of ethics and compliance in the workplace. Many companies use this week to advance the dialogue surrounding compliance and ethics and engage employees in these hot button issues.

AECOM’s Susan Frank Divers, right, talks with Dr. Edward Queen, director of the Ethics and Servant Leadership Program, The Center for Ethics, Emory University, during last year’s Best Practices in Ethics Communications Workshop.

AECOM’s Susan Frank Divers, assistant general counsel for Ethics and Compliance, right, talks with Dr. Edward Queen, director of the Ethics and Servant Leadership Program, The Center for Ethics, Emory University, during last year’s Best Practices in Ethics Communications Workshop.

“We are excited to build on the momentum and energy coming out of our second-annual Best Practices in Ethics Communications Workshop by publishing the expert perspectives and successful strategies that were shared at the New York Stock Exchange in October,” said Paul Gennaro, AECOM’s senior vice president and chief communications officer, who also chairs the Ethisphere Institute’s Communications Advisory Board.

The report features insights and perspectives from several recognized leaders in communications, academia, and legal and compliance, including Paul Argenti, professor of Corporate Communication and Corporate Responsibility, The Tuck School of Business at Dartmouth; Roger Bolton, president of the Arthur W. Page Society, the leading global professional association for senior public relations and corporate communications executives; Gary Sheffer, vice president of corporate communications and public affairs at General Electric and chairman of the Arthur W. Page Society; and Dr. Edward Queen, director of the Ethics and Servant Leadership Program, The Center for Ethics, Emory University.

“There are times when silence is important, especially when you don’t know all the facts. Long-term silence is never the right answer, but you have to achieve a balance where you are not rushing out with potentially false information, which can really discredit the company in the long run,” said Gregory.

Dawn Werry, vice president, marketing, Milliken & Company, added that while it is important to know all the facts before communicating, a quick response is important to controlling an organization’s rumor mill.

“You can’t go too long without telling people something, or else they will fill in the blanks,” said Werry. “Immediate communication allows you to be in control of your story, which is better than the alternative.” Werry also added that social media provides a unique tool for hearing feedback. “During a crisis while working for a previous employer, the biggest turning point for us was when we started using social media to listen.”

Click here to download a full copy of the report.

In the Spotlight: Corporate Compliance and Ethics Week

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HCCA Director of Communication Margaret Dragon interviewed Nancy Gordon (nancy.gordon@hcca-info.org), HCCA Managing Editor.  Nancy also oversees Corporate Compliance and Ethics Week products and information.  

MD: Please tell us about Corporate Compliance & Ethics Week, when is it held, and its history.

NG: The idea for Corporate Compliance and Ethics Week grew from conversations among active members of HCCA back in 2002. They were looking to find new ways to educate employees about the compliance and ethics program and its importance. Someone suggested if they had a designated day called Compliance Day, they could have a “hook” around which several activities could be planned, which would have more impact. By coordinating with department leaders, they could do some individualized training and then hold a big compliance celebration event to reinforce the organization’s commitment to compliance and ethics. For those organizations that were much too large to do all that in a day, the concept was expanded to a Compliance Awareness Week.

Two members who had success with this idea, Gene DeLaddy and Cheryl Atkinson of the Carolinas HealthCare System, wrote about their experiences in the December 2002 issue of Compliance Today. Many compliance and ethics professionals responded by holding their own events. The HCCA Board of Directors and the SCCE Advisory Board decided they liked the idea so much they wanted to help even more members benefit from it.

They created the first National Corporate Compliance and Ethics Week, which was held May 22-28, 2005. At that time, they worked to have a resolution passed in the U.S. Senate, which would have allowed a National Corporate Compliance and Ethics Week to be officially recognized by Congress. Unfortunately, the senators who were sponsoring the resolution left office before it made its way through. But by that time, the week had taken hold among compliance and ethics professionals.

The name was shortened to Corporate Compliance and Ethics Week in following years. Then in 2009, the event was moved from the last week of May to the first full week of May, to avoid the overlap with Memorial Day that so often happened. We will celebrate the 10th annual Corporate Compliance and Ethics Week on May 4-10, 2014.

MD: What is the purpose and value of this specifically designated week for the Compliance department?

NG: As you know, employee education is one of the seven elements required for an effective compliance and ethics program. By having a designated week, compliance and ethics professionals can take the opportunity to build awareness in ways that reinforce not just specific rules and regulations, but the overall culture of compliance. It is much easier to promote compliance and ethics topics when a spotlight is already focused on Corporate Compliance and Ethics Week. Also, when employees see that the organization’s top executives and managers are supporting and taking part in the week’s celebrations, the message is clear: Compliance and ethics are a big priority.

MD: How do SCCE & HCCA support Corporate Compliance & Ethics Week?

NG: Each year we develop a new logo for the week that includes a compliance-related theme. The theme for 2014 is Compliance Makes a Difference. The logo is available free on our website.

Over the years, we have tried to facilitate the sharing of ideas that our members have used to successfully capitalize on the week. We have published many articles in Compliance Today and sponsored web conferences by our members who share what has worked for them. New this year, we have created a free “train-the-trainer” kit that can help members have a place to start their planning efforts. In it, you will find sample newsletter ideas and templates focused on compliance and ethics awareness, sample newsletter articles and e-mail blasts promoting Corporate Compliance & Ethics Week, event planning ideas and activity instructions, etc. And finally, we provide low-cost posters and promotional products to use in conjunction with Corporate Compliance and Ethics Week celebrations. These are all available in our Corporate Compliance and Ethics Week section of the website.

MD: When you communicate with those who order supplies, do they discuss the activities they are planning and how they plan to maximize the week to benefit their compliance and ethics program? If so, would you mind sharing their plans with us?

NG: We don’t really get full descriptions of their events, but sometimes they will share how they used a particular product with an activity. For instance, many people have told us they like to offer the flashlights for a “shine the spotlight on compliance” theme. And I’ve heard the sticky flags have been used for a “flag those errors” theme. And one member told me she has every official Corporate Compliance and Ethics Week poster we have issued, and she’s lined a hallway in her department with all of them in a row.

MD: Would you tell us about some of the items HCCA will have available for members to order in 2014 and how soon can they order supplies?

NG: We actually have our 2014 promotional items available now—we wanted to give members more time to plan and budget for their events. They will find a lot of new items we’ve never offered before, including all new inspirational quote posters, awareness bracelets, mini-tool sets, smart-phone stands, and table tents. Plus we have the old favorites—pens, sticky flags, flashlights, stress balls, and mugs.

MD: Is there information available about events and programs others have developed to celebrate Corporate Compliance & Ethics Week and if so, where?

NG: We have put all the tools available to help with planning Corporate Compliance and Ethics Week in one section on the website. That means past articles and web conferences, downloadable logos, and train-the-trainer kits, as well as our online store to order promotional items. You can find them at SCCE’s Corporate Compliance & Ethics Week Resources page. 

MD: Thank you for taking the time  to tell us about Corporate Compliance and Ethics Week.