I’m tired of hearing about “check the box” compliance programs.
I’m sure that there are some out there. I’m sure that there are some people who, either out of a lack of desire or coercion, do the least they possibly can. But for all the talk about avoiding “check the box” compliance programs, I wonder how many of them there really are. I also wonder if we’re doing ourselves more harm than good by suggesting that the business world is full of “check the box” programs.
Also, I’m not sure how to create a “check the box” program, given how complex some of the boxes are.
Often the concept of a “check the box” program is brought up by an individual or organization that is offering a product or service, or advocating for a set of standards or practices that do more than meet the existing requirements. A recent report on recommended best practices on compliance contained the phrase “check the box” five separate times. Among the things it said was, “…if all organizations adopted the principles and practices described in this report, ‘check the box’ programs would fade away and far fewer headlines would report the kind of organizational wrongdoing that jeopardizes public trust.”
That may be. But it’s also convenient to suggest that any program that doesn’t do what the authors or vendor advocate is somehow just going through the motions.
The corollary to these claims about going “beyond checking the box” is that checking the box isn’t good enough. The same report says that top compliance programs “…are not satisfied with the mere compliance or ‘check the box’ efforts.”
The fact is, though, that in some areas, checking the box, or mere compliance, is just fine. Driving at 65 in a 65 zone is a pretty “check the box” approach and about all that you need to do to stay in compliance with the speed limit. So are countless other rules and regulations that are pretty darn complex. If you make sure your sales people know that they can’t talk pricing with competitors, and they don’t, is that just checking the box? If so, what’s the problem? Should we be teaching them to run screaming from the room to go beyond check the box?
Other areas of compliance make checking the box really hard, mostly because it’s a hard box to fill. Take the area of rewarding good behavior and penalizing bad behavior. It has proven to be a surprisingly difficult part of the Sentencing Guidelines to follow. Many honorable institutions have struggled mightily with it, and not for reasons most outsiders would think.
The discipline part has proven relatively easy, although not always so. The reward part has been the complex issue, with many wondering what’s the right way to reward people for what they should be doing in the first place.
Using the driving analogy again, as a society we’re all generally comfortable with pulling people over for speeding and giving them a ticket. It’s the person who’s driving the speed limit that’s the problem: should we be rewarding her for doing so? Many think not.
But the biggest issue is that every time someone talks about “check the box” programs it suggests that the presence of these programs is a big problem that the compliance community faces.
That’s not the problem I see being faced by the vast majority of the thousands and thousands of attendees at SCCE and HCCA meetings.
To my experience there are two key challenges. The first is understanding what specific laws and regulations require and how to meet those requirements.
The other great challenge is a timeless one: getting people to act ethically and follow the rules. Sometimes the rules are complex, counterintuitive and difficult to follow. Sometimes cultures get in the way. Sometimes people don’t realize what they are doing wrong.
And, sometimes, well, people are just people. They have an alarming tendency to lie, cheat and steal if they think they can get away with it and still feel okay about themselves.
Research by Dan Ariely and others have proven that. And the never-ending stream of new laws is testament to our human tendency to try and get around all the rules we already have.
So let’s stop distracting ourselves and others with the idea of “check the box” programs, and let’s stay focused on the actual challenges at hand.
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