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A successful compliance program (CP) requires support, which begins at the Board level.  As discussed in Part I of this blog series, Board level support stems from having a CP oversight committee.  The Compliance Officer has the obligation to provide the right type of information that both captures committee interest and leads to empowerment for the program.  Inundating the Board with process related details such as the number of hotline reports received and resolved; the number of employees who underwent compliance training; and results from sanction-screening can lead to Board disinterest.  Although this is important, it lacks the big picture presentation that Board level committees are accustomed to seeing.

Boards are interested in determining whether the overall operation of the CP reduces the likelihood of wrongful acts that may create liabilities, litigation, bad press and loss of community confidence in the provider.  To gain insight into the overall operation of the CP, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) compliance guidance has suggested several methods.  One of these is employing anonymous surveys of employees to gain insights as to the effectiveness of CP.  The OIG noted that “the compliance officer…should consider techniques such as…using questionnaires developed to solicit impressions of a broad cross-section of the hospital’s employees and staff.”   The OIG further reinforced this suggestion by stating that it “recommends that organizations should evaluate all elements of a CP through employee surveys”.  Results from a professionally administered survey can provide a very powerful report to the Board, as well as to any outside authority questioning the program.

Reports from surveys of employees provides the Board the ability to gauge CP effectiveness, identify relative CP strengths, and expose areas requiring special attention, as well as providing a framework by they can better assess the more detailed reports regarding the seven elements of the CP.

Using Anonymous Surveys to Evidence Compliance Program Effectiveness

Employing compliance surveys is easy and relatively inexpensive. They provide powerful independent and credible evidence about the effectiveness of the CP.  There are two general types of surveys that can be employed: the Compliance Culture Survey and the Compliance Knowledge Survey.  Either approach provides great insights into how effective the CP has been in changing and improving compliance within an organization at a relatively low cost.   They can not only signal strengths in the CP, but also expose areas of potential weakness warranting attention.  A survey also can communicate a strong positive message to employees and has the added benefit of signaling to employees that (a) their opinions are valued; (b) their input is being used to make positive changes; and (c) the organization’s commitment to them as individuals. These messages can have a powerful influence on increased compliance, reduced violations, and heightened integrity.

Surveys must be kept to a reasonable length that will take no more than 20 to 30 minutes to complete. If a survey takes longer, the employee may become apathetic and begin to respond in a careless fashion that undermines the value of the data.
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Compliance Knowledge Surveys are recommended for mature CPs to assess the CP’s progress in reaching the employee population.  The survey tests employees’ knowledge of the CP structure and operations, including their understanding the Compliance Officer’s role and how the hotline functions.  The results are useful in providing empirical evidence of the advancement of program knowledge, understanding and effectiveness.  This survey only utilizes closed-ended questions that provide “Yes,”  “No,” or “I don’t know” responses which are extremely easy for respondents to answer.

Compliance Culture Surveys are useful in measuring change in the compliance environment over a period of time.  These types of surveys are derived from very different ontological traditions and perspectives.  The Culture Survey focuses on the beliefs and values which guide the thinking and behavior of employees within an organization. This survey can measure the outcome of the CP and examine the extent to which individuals, coworkers, supervisors, and leaders demonstrate commitment to compliance. The results are extremely useful tools for assessing the current state of the compliance climate or culture of an organization.  Employees’ responses are measured in a Likert Scale format that offers a gradation of answers from “Strongly Disagree,” “Disagree,” “Neutral,” “Agree,” to “Strongly Agree.”

Anyone can draft a questionnaire in a matter of hours.  However, untested questionnaires may not produce reliable, valid and credible results, especially to an outside party.  Internally developed and administered surveys may be questioned as to potential bias or reliability. It is far better to use a valid and independently administered survey that has been utilized by many organizations and is administered through a web-based system that ensures the confidentiality of participants.  Using a professional survey service specializing in health care compliance is surprisingly inexpensive and less costly than developing and delivering a survey in house.  The ideal survey not only provides statistical results but also compares the results to a large universe which allows the organization to see how it compares to all others who have used the survey.

If an organization decides to conduct an annual compliance survey, it is advisable to alternate between the two types, rather than using the same survey each year.  Using the same survey every year diminishes its value. Also, gaining information from the two different types of surveys will provide increased insights about the CP and allow the Compliance Officer to present the board with a well-rounded picture of the overall operation of the compliance program.

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