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A compliance budget is a lot more than the numbers in it, explains Betsy Wade (LinkedIn), Chief Compliance & Ethics Officer at Signature Healthcare. It should be a reflection of the organization’s priorities and risk profile.
The budget is also a point of focus of the US Department of Justice when examining a compliance program during an investigation. Their Evaluation of Corporate Compliance Program guidance for prosecutors asks not only if there are sufficient resources but if they are allocated on a “risk-tailored” basis.
So, what is the right budget to have? To determine that answer she recommends compliance teams do a risk assessment and determine what mitigation efforts will be needed. In addition, benchmark against other organizations to learn what they are spending and doing. Just try to make sure that you do so against as similar a business as possible.
Look also to publicly available resources such as benchmarking surveys from HCCA and SCCE.
Keep your eye out, too, for what regulators and enforcement authorities are saying. US Assistant Attorney General Kenneth A. Polite, Jr., she reports, recently called for compliance FTE for every thousand employees.
The compliance budget should include the cost for all that compliance personnel. Also in the budget should be any travel, certification costs of staff members, staff training, services purchased, and more.
To win management approval, she recommends continued analysis of the budget and making adjustments. She also advises using the risk assessment as a tool to support the compliance team’s budget request.
Listen in. Doing so won’t add a penny to your budget.