Starting off this year's compliance institute, I attended Compliance Program Start Up: What Are the Basics Needed for Your Infrastructure. Debbie Troklus of Aegis Compliance and Ethics Center and Sheryl Vacca of University of California discussed the overall necessities of a compliance program. There are seven elements of an effective compliance program:
- Policies and Procedures
- Education and Training
- Oversight
- Monitoring and Auditing
- Reporting
- Enforcement and Discipline
- Response and Prevention
And, to think that are more than a dozen areas for which to cover each step.
Debbie and Sheryl stressed that while "tone at the top" is important, tone in the middle is crucial. What this means is that it is while it is important for the management and executives to back compliance, it crucial that middle management is compliance's champion. If middle management isn't on board, it won't get done.
It was also emphasized that your organization must embrace a culture of compliance. Does compliance take top priority in the organization? Are all employees on board right down to the bus drivers, do they know who to talk to if they see a problem? It is everyone at an organization's responsibility to keep an eye out for compliance offenses and report them and it is management's job to listen such that employees don't become frustrated and resort to whistleblowing.
Stay tuned for more from the 2015 HCCA Compliance Institute!
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