Margaret C. Scavotto, JD, CHC
President, Management Performance Associates
In April 2018, the Society of Corporate Compliance and Ethics and the Health Care Compliance Association released a report: The Relationship between the Board of Directors and the Compliance and Ethics Officer.
This report includes (among others) the following compliance officer survey findings:
- About half of compliance officers report to the board
- 46% of compliance officers believe the board “values compliance a great deal”
I don’t know if the boards that receive regular compliance reports are the same boards that value compliance a great deal. – that wasn’t part of this survey. But it’s a good guess that they are. Do the boards who receive regular compliance reports value compliance more? Maybe. I’ll go out on a limb and opine that it’s highly likely.
How can a board value compliance if it isn’t aware of compliance activity?
How can a board appreciate the role of compliance if it doesn’t hear about compliance successes?
How can a board lead and be responsible for a compliance program if it isn’t informed on compliance?
It can’t.
Is your organization part of the 50% where compliance doesn’t report to the board – or the 50% that does?
If the compliance officer does report to the board, how often? According to the HCCA & SCCE report, 35% of compliance officers report to the board four times a year, and another 29% report five or more times a year. If reporting is new in your organization, quarterly reports will bring you in line with many others in the industry.
I think you are “preaching to the choir” so to speak. Many of us understand to whom we should be reporting but have had difficulties convincing leadership at our organizations that this is necessary. I for one would like to see a discussion as to how we can move past this and have the reporting relationship that we should have — perhaps from individuals who have overcome it.
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