Creating a Culture of Compliance: It Starts With You
Several weeks ago, I was fortunate to attend the inaugural Advanced Healthcare Compliance Certificate Program hosted by the Seton Hall School of Law. We covered a lot of ground, from effective compliance programs to third-party relationship management to internal investigations. But what struck me the most was that the size and reach of a company doesn’t matter and a particular employee’s position doesn’t matter—compliance is everyone’s responsibility. Whether you are Fortune 500 company or a scrappy start-up, you must have a culture of compliance that is adopted at every turn. But how do you create a culture of compliance?
The program at Seton Hall posed even more questions: Are your policies easily understood, or have they become overcomplicated? Is your program catching misconduct? Are adjustments being made if gaps are found? If we identify misconduct, are we being fair and consistent in our handling of the individuals involved? Are we protecting witnesses from retaliation? Have we learned from past mistakes? Has the pandemic created new opportunities for misconduct? Do our employees, contractors, and customers trust us? Most importantly, do we deserve that trust?
To answer these questions, we must take a comprehensive approach to compliance. Below are the top 4 ways to ensure compliance at your organization.
- It starts with leadership—According to the current U.S. Department of Justice’s Evaluation of Corporate Compliance Programs, “The effectiveness of a compliance program requires a high-level commitment by company leadership to implement a culture of compliance from the middle and the top.”
- Train and test—Create a robust training regimen to train employees on how to identify and respond to compliance violations; this training should begin at onboarding, with refresher trainings implemented periodically throughout an employee’s tenure. Additionally, employees should provide written certification that they understood the training.
- Address violations— Establish a written protocol to address investigation and remediation of misconduct; a company’s compliance department should send representatives to programs periodically to monitor for any compliance violations; any detected violations should be swiftly addressed, with sanctions proportional to the violation.
- Get a fresh perspective—Consider hiring an outside party to fully review and test your compliance programs and protocols. Especially for smaller organizations, it can be difficult to stay on top of all the guidelines and recommendations. Bringing in an outside party can help you find blind spots in your compliance approach.
While ensuring compliance is no easy task, with the right plan and protocols in place, you can conduct business with confidence. Another way to further ensure compliance is to work with a partner with extensive compliance experience. At AVAIL, compliance is in our DNA. We’ve established compliance protocols from scratch and have a team of industry compliance standard-certified professionals.
If you’re looking to execute speaker programs that adhere the highest compliance standards, reach out to us today.