Compliance Culture Building Block #6: Pave a Two-Way Street


Compliance Culture Building Block #6: Pave a Two-Way Street

Margaret ScavottoBy Margaret Scavotto, JD, CHC
Director of Compliance Services
Management Performance Associates

Does the Golden Rule (do unto others as you would have them do unto you) play a prominent role in your compliance program? Here are four ways you can respect employees and make compliance a two-way street.

Discipline should be clear and fair.

Compliance programs require disciplinary guidelines. Compliance cultures benefit when discipline is not a surprise, and when it is consistent. Make expectations clear from day one of employment. When disciplinary guidelines come into play, be fair and objective. This means applying discipline consistently regardless of position.

Admit mistakes.

All health care providers make mistakes. A provider without an effective compliance program doesn’t know what mistakes it has made—that’s a ticking time bomb. A provider with an effective compliance program finds these mistakes, discloses them, fixes them, uses them as a teaching moment, and improves.

It isn’t easy for anyone to admit mistakes. Compliance expects employees to admit mistakes—and so should compliance leaders.

Open the door.

Employees constantly hear about the need to report non-compliance internally. But where do they go with compliance questions? A compliance officer who encourages questions as much as internal reporting will find more employees stopping by for both reasons. Establish an open door policy. Better yet, frequently leave the office, walk the halls, and talk to people about their concerns.

Follow up—and say thank you.

If possible, follow up with complainants so they know their complaint was taken seriously. Employees often sweat bullets about making a complaint. A simple phone call explaining that you looked into the matter, combined with whatever information you can share (after talking with your legal counsel if necessary), can let an employee know you took their complaint seriously. Don’t forget to thank them for making the complaint. If employees believe your organization is committed to compliance and doing the right thing, reporting will seem worthwhile. This increases the likelihood of internal reporting.

Compliance expects a lot from employees. Compliance leaders can strengthen compliance culture by paying it forward: be fair, and give credit where credit is due.

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