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Strategic Management ×
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  • Measuring compliance culture provides useful metrics on program effectiveness
  • Internally developed/administered surveys lack employee credibility
  • Great for benchmarking compliance program advancement

Developing a culture of compliance within an organization should be a major goal for any Compliance Officer. A strong compliance culture can only exist where there is an alignment of interest among executive leadership, operational managers, and the compliance office. No compliance program can be considered effective without knowing the degree that employees and management have bought into the program. An increasing number of health care organizations are making use of employee compliance culture surveys to obtain quantifiable data on workforce attitudes and perceptions that can be applied by companies to benchmark and monitor progress against their own results (i.e., trending historical company survey data), as well as possibly allowing for comparisons to industry peers and national averages. Such surveys have been advocated by governmental authorities. The U.S. Sentencing Commission explicitly recognized the significance of “culture,” stating that businesses must “promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.” This suggests that a compliance culture survey to evidence compliance meets this standard. In their Compliance Program Guidance for Hospitals, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) noted that “as part of the review process, the compliance officer or reviewers should consider techniques such as…using questionnaires developed to solicit impressions of a broad cross-section of the hospital’s employees and staff.” In other compliance guidance documents, the OIG reinforced this by stating that it “recommends that organizations should evaluate all elements of a compliance program through “employee surveys, management assessments, and periodic review of benchmarks established for audits, investigations, disciplinary action, overpayments, and employee feedback.”

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Steven Forman, CPA, has been employing the Compliance Benchmarking Survey©  (Survey) with his clients for over 20 years, when evaluating compliance programs. He finds it very useful in measuring attitudes, behavior, and impressions that gauge how well an organization has adopted and accepted the compliance program principles. For those organizations just getting their program underway, the Survey can establish a benchmark that can be used to measure the progress of the program. For a mature program, it is a way to gain insights into the strengths and weaknesses. He sees much to be gained from asking employees about their attitudes and perceptions of compliance. Results provide a gold mine of data about what employee impressions are when someone observes and reports problematic behavior, how they perceive the level of management commitments to correcting reported problems, as well as whether management promotes compliance by communicating and reinforcing it. Surveys can also provide intelligence as to whether employees believe management is applying consistent forms of discipline to breaches of the code of conduct. Mr. Forman strongly advocates using surveys that include in the results not only how well respondents scored, but how they compare with other organizations using the same instrument. He has found that executive leadership and the Board find high credibility in results of these types of surveys. To ensure reliability, validity, and credibility of survey results, the survey should be professionally developed, tested, and validated. The surveys should be independently administered to guarantee respondent anonymity. He warns that employees are generally wary and suspect of surveys developed internally, especially those administered in-house, and this discourages people from sharing their views openly, which will undermine the reliability of results.

Carrie Kusserow, MA, CHC, CHPC, CCEP, has over 15 years of experience as a compliance officer and consultant. She has found that administering a compliance culture survey sends a signal that the organization is interested in what employees have to say and that it will be used to improve the work environment. This is a very positive result in that it opens a door with employees and can evidence that management cares about what they think. However, this also raises expectations that something useful will result from the process. Employees will be looking to see if anything comes from the Survey. The danger of raising expectations is failing to evidence that results were taken seriously and acted upon. This can create a negative effect on employees. As such, survey results should be incorporated in compliance training, along with what actions are being taken to strengthen areas of identified weaknesses.

Jillian Bower-Concepcion, MPA, CHC, CHPC, at the Compliance Resource Center, has assisted many clients with two types of compliance surveys: knowledge and cultural. Compliance knowledge surveys measure employee knowledge and understanding of the compliance program, and culture surveys focus on the beliefs and values which guide the thinking and behavior of an organization’s members. These types of surveys can measure outcomes or the “impact” of their compliance program activities, and can examine the extent to which individuals, coworkers, supervisors, and leaders demonstrate commitment to compliance. Consequently, these surveys can be extremely useful tools for assessing the current state of the compliance climate or culture of an organization. A well-written, thoughtfully executed ethical culture survey that is disseminated anonymously and confidentially is a very efficient compliance culture measurement tool. Healthcare organizations that make good use of compliance culture surveys experience many benefits.

For more information, please contact Jillian Bower-Concepcion, MPA, CHC, CHPC, at jconcepcion@complianceresource.com  or (703) 535-1405.

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