Debbie Troklus, Managing Director at Aegis Compliance and Ethics Center
Sheryl Vacca, Chief Compliance and Audit Officer at University of California
Having joined MD Ranger in January 2016, this is my first year attending HCCA. I started off the conference attending Compliance Program Start Up: What are the Basics Needed for your Infrastructure. This session discussed the realities of running a compliance program within a larger organization.
As a foundation, there are seven essential elements a compliance program should have:
- Standards and Procedures
- Education and Training
- Monitoring and Auditing
- Enforcement and Discipline
- Response and Prevention
Each of the above tenets is packed full of do’s, don’ts, and gray areas that challenge even the most veteran compliance professionals. While recognizing these difficulties, the speakers were clear that the principles of independence and accessibility are crucial to the success in every area. Compliance programs should function independently of other departments which might have a vested interest in the outcome of an investigation, such as management or legal. Instead, these partners should act as peers rather than supervisors, bringing us to the next point of accessibility. Compliance is everyone’s job. Accordingly, the compliance expectations, policies, and education must be communicated to every employee with a goal to promote real understanding and adoption.
The list above can be incredibly overwhelming but taking efforts one step at a time can get you where you want to go. It’s important to perform baseline audits and then evaluate the progress of your efforts. Ask questions like, Did the program get implemented the way it was designed? What impact did it have? According to our speakers, “Rome was not built in a day...compliance programs are also not built in a day”. Document, evaluate, celebrate success, plan for improvements, and take your compliance program to the next level.