By Frank Ruelas
Facility Compliance Professional, St. Joseph’s Hospital
and Medical Center/Dignity Health
One common theme that comes up in compliance related discussions is the idea of how to make compliance related training more engaging. This is a longstanding discussion point which often is responded to with anecdotal replies such as to relate the training to a person’s job duties, using an engaging method for training such as interactive activities, and other similar responses. However, a particularly noteworthy recent event also represents an opportunity which people may want to think about in how its occurrence can help promote effective training about non-compliant activity.
So for starters, let’s just call it as it is while also being sensitive given the nature of the situation. The incident involves allegations sexual harassment involving a well-known television personality which resulted in this firing from a popular, network morning news program.
Try to put aside some of the storylines that this event has created and think about it from the perspective of the basic issues or topics that are related to the management of an effective compliance program. Then ask yourself the question, does this present an opportunity to highlight or reinforce, if applicable given the state of one’s compliance program, a valuable training opportunity?
The reason for this is that this is a situation that has captured the public’s interest for a number of reasons. It has to do with a topic that is very much in the news lately, it involves a high profile person, and a very high profile and well-known organization. So why not capture some of this attention and help members of your organization realize how such an incident or other non-compliant behavior may become known and responded to by the organization.
One can use this to highlight how everyone, despite their role or title is held to the same expectations and how the Standards of Conduct or other communications identify what these are. The idea of how people can make good faith reports of misconduct using established communication channels such as a hotline, designated email address, using their chain of command, or other available options is certainly very topic. The important topic of how people should not fear retaliation or retribution for good faith reporting is one that never goes out of date and certainly applies to this situation given that it was reported by someone within the organization.
Other topics include using the incident to show how one’s organization is committed to investigating reporting events, responding in a timely manner to reported incidents, and the consequences that people may expect when these allegations are substantiated.
Sometimes an occurrence of an incident of this nature, as offensive as it may be, captures the attention of many people to include members of an organization’s workforce, especially when this interest is amplified by the use of social media and the traditional media outlets. Redirecting some of this attention to educate people how the organization has mechanisms to respond to non-compliant behavior may provide an opportunity for very effective reinforcement of the existence and operation of one’s own compliance program.