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At the end of March 2017, the OIG issued a new resource entitled “Measuring Compliance Program Effectiveness: A Resource Guide” (Guide). A group of compliance professionals met with OIG staff to discuss ways to measure the effectiveness of compliance programs. The roundtable was generated to provide as many ideas as possible for looking at compliance programs. The guide was offered not as a “checklist,” but rather to present ideas that compliance officers may wish to consider in looking at their compliance programs. Program effectiveness is related to evidence of “outcome,” not output. For example, having compliance training for all covered employees is a process outcome metric. How well the participants learned the lessons and retained them is a factor of outcome, or effectiveness, of the training. Most of the items listed in the guide relate to process or output, but one big exception is the reference to surveys.
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Throughout the Guide, the OIG suggested using surveys to learn about employee knowledge, understanding, and attitudes related to compliance issues. In fact, surveys were mentioned repeatedly throughout all seven elements. Surveys are also referenced in the various OIG compliance guidance documents as a means for measuring compliance program effectiveness. Organizations can use two types of surveys: a knowledge survey that measures employees on their knowledge and understanding of the compliance program; and a culture survey that measures employee attitudes and perceptions concerning organizational compliance. Both compliance knowledge and culture surveys were cited as ways to determine how well program aspects were functioning. If a validated and tested survey is used and administered independently, and ensures anonymity of respondents, there is great value in the results. The value can be magnified many times if the results can be benchmarked against a large universe of those using an identical survey instrument. Organizations can also benchmark results from one survey to another to show program improvements. Results from surveys provide powerful evidence of compliance program effectiveness to executive leadership, the Board, and even to outside authorities.
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If you have questions regarding compliance surveys, visit our Compliance Survey Center. Ready to connect with a compliance expert? Contact us online, or call (703) 683-9600 to learn how we can help your organization identify risk areas and maintain compliance.