Survey: Healthcare Compliance and the Board Level

May 21, 2010 at 1:00 pm Leave a comment

The Society of Corporate Compliance and Ethics and the Health Care Compliance Association recently released the results of a survey of compliance and ethics professionals in their database.

Their conclusions:

Despite all the efforts to promote better governance, it does not appear that there is yet a fully developed connection between governance and compliance.

A stint in survey research early in my career makes me question the representativeness of their sample, so let’s think of this as qualitative research that indicates themes and directions and go from there. (And more importantly, ethical behavior isn’t based on percentages. It’s based on a value judgement.) Still their conclusion is meaningful.

Regardless of the organizational behaviors of others, the question to ask yourself is, “How does my organization address its compliance and ethics management? Does my compliance function actually affect the governance decisions?”

Too often compliance is seen in the organization as something to be endured. For example, I worked for the company that went bankrupt from what was (at the time) the world’s largest corporate fraud. In the aftermath, the bankruptcy court decided every employee needed to take ethics training. “Why us?” my colleagues and I grumbled, “We didn’t lie about anything.” The training focused on legal standards and definitions. But it left a gap. The gap was that it didn’t tell us what to do when we found something irregular and how the company would respond.

Take a look at the survey (a free registration is required to see the full results), and think how your organization would answer the questions. In the end, don’t assess yourself by whether you’re company is doing what everyone else is. Whether you’re “average” or “above average.”

Regardless of your organizational structure. Regardless of who reports to whom. Do you have a compliance function that can actually affect behavior? Do your employees know the route to resolution? If you don’t, then you know what you need to work on.

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