Delivering Criticism During Internal Audits


John NoceroBy John Nocero

A compliance practitioner needs to be extremely attuned to the environment– highly observant and watching for the smallest changes – because multiple dangers abound there. Never is this more important than during internal audits, when you are delivering criticism.

Criticism is the expression of disapproval of someone or something based on perceived faults or mistakes. You can criticize in one of two ways: you can critique someone’s character or their behavior. When conducting an internal audit, you should be rating one’s compliance related to contractual and regulatory mandates relative to the payment of services provided. This is done by reviewing processes or documentation on standard tools. When documenting findings on these tools, remember that your goal should be to get people to change non-compliance behavior. Realistically, people can change behaviors. You should be calling out specific, temporary actions. If you use these tools to assassinate someone’s identity, you are condemning them to their very core. Whether unintentional or not, your documentation is marking them a bad person.

As an internal auditor, it is tempting to issue global labels; it may even feel highly satisfying or justifiable – “But John, they were non-compliant.” This recipe is not effective. Internal audits are conducted by doing much front-end work – documenting the audit scope clearly in an e-mail to all parties, setting preliminary and final meeting dates, and working with the team to obtain clarification to things you do not understand, before you deem them non-compliant. You then prepare a quality final report that includes areas of compliance – yes, the things the program did right – unresolved deficiencies, recommendations and a concrete deadline for completion. You need to ensure that you give them a realistic timeframe to correct their identified deficiencies. This report should be shared at a meeting with all appropriate stakeholders. You then follow up within the timeframe specified to ensure all corrections are made appropriately.

Blanket condemnation hurts more than it helps. It puts people on the defensive and unknowingly absolves you of any responsibility. Don’t criticize for the sake of criticizing because you work in compliance. Don’t make people feel that their effort is futile. Their success and your success during the internal auditing process is a result of what you do together.

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