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Steve Forman, CPA, has built, managed and assessed over 50 compliance programs. In his experience, a good way to gain a fresh look at an organization’s compliance program is by following the OIG’s advice in its compliance program guidance documents. According to the OIG, “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 employees and staff.” Further, the OIG recommends, in its resource entitled “Measuring Compliance Program Effectiveness: A Resource Guide”, that organizations should evaluate elements of a compliance program through employee surveys. Mr. Forman notes that the Guide recommends using surveys to learn about employee knowledge, understanding, and attitudes related to compliance issues, and using them as a means for measuring compliance program effectiveness. He, therefore, makes it a standard practice to include the Compliance Knowledge Survey© (Survey) when evaluating compliance programs. Results from the Surveys reinforce his field assessment findings.
Daniel Peake works at the Compliance Survey Center, (the “Center”) which has been employing healthcare compliance surveys since 1993. The Center’s work has resulted in a vast database of surveys compiled from hundreds of organizations. Compliance officers can compare and benchmark results of their organization against this data. Without such comparison, it is difficult to understand the significance of compliance survey results. The reports identify both strengths and weaknesses in the compliance program, and offer in-depth analysis with suggestions for improvements. Mr. Peake cautions that although anyone can draft a survey in a matter of hours, it does not mean it will be reliable, valid and credible to an outside party. Invalid surveys are severely limited in their utility. Also, internally developed and administered surveys provide room for potential bias and unreliability of results, making it far better to use a vendor with a proven and validated survey tool. Professionally developed, administered and validated surveys are not only superior from a reliability standpoint, they also cost less than trying to develop and administer one internally. Additionally, the ability to benchmark the organization’s survey results against a universe of results from others who have used the same instrument is invaluable. Mr. Peake notes that a valid and reliable survey provides a number of benefits, including the following:
- Survey results meet the OIG standard of having periodic independent program review;
- The cost is only about 10% of a full field compliance assessment;
- A Survey provides empirical evidence of compliance program knowledge, understanding and effectiveness;
- It highlights areas of strength upon which a compliance program can be anchored;
- A Survey identifies areas that warrant attention, with an effort towards improving the overall compliance environment;
- It establishes benchmarks by which a compliance program’s progress can be measured;
- It measures employee perceptions related to management and leadership;
- It flags issues affecting attitudes and morale;
- A Survey has the added benefit of signaling to employees that their opinions are valued.
For more information, Daniel Peake is available at email@example.com or (703)-236-9854.