Compliance and Ethics: Ideas & Answers. Edition 46
Dear friends,
Welcome back to another edition of Compliance and Ethics: Ideas & Answers.
In edition 46, Marianne Birmingham, MS, MBA, CHC and Matt Sparling, MSED take us through The 7 Elements of an Engaging Compliance Week Activity before I take a look at Compliance Champions, with some advice for HHS OIG (and other government agencies).
Our regular feature, Compliance Lite is also back with a little fun to start off your week.
And as always, there's more content on our website so please do visit us there to read our other articles.
Thank you, Joe.
The 7 Elements of an Engaging Compliance Week Activity
by Marianne Birmingham, MS, MBA, CHC & Matthew Sparling
While companies are spending hundreds of billions of dollars on staff engagement, recruitment, and social media advertising[1] – we at Vivant Behavioral Healthcare took a different approach and spent just $250 on Corporate Compliance and Ethics Week. As a result, our staff engagement increased by 136%, referrals for employment increased by 30%, and staff spread the word about our culture to three times more social media users in one week than our organization had ever impacted in an entire month.
Since inception, Vivant Behavioral Healthcare (Vivant) facilitates a fun competition between local sites for Corporate Compliance and Ethics Week. These competitions commonly take the form of a staff awareness or reinforcement demonstration – dress up days, scavenger hunts, mascot designs, and other insular activities. In the past, we have been challenged with an uneven playing field, with winning sites often benefiting from size and more available resources than competitors. This year, we wanted to do something different, which supported long-term benefits for our staff and simultaneously aligned with our strategy of building brand awareness about our critical treatment services.
As the chief compliance officer, I engaged our head of marketing to assist, which had the bonus of Marketing being a champion for compliance. Plan development started off simply – we generated a list of desired outcomes and experiences for our staff, which included promoting competition, providing a more level playing ground, celebrating pride in our brand, connecting with community, and being thoughtful about budgets.
With those desired outcomes in mind, next, we needed an idea. In order to gain alignment and build excitement, we used internal communication channels like our intranet site, our group chat functions, and good old fashion townhall meetings to create two-way avenues for communication. We acknowledged our staff are more creative than we are, and thus began crowd-souring ideas. Within a week, we landed on the idea of a “Social Media Showdown,” an idea and name provided by two frontline staff. The Showdown would involve the sites using each of their respective social media pages to (1) post compliance/ethics-related content during Corporate Compliance and Ethics Week and (2) to encourage their staff and community members to engage with and share the posts.
领英推荐
Compliance Champions: Here is some advice for HHS OIG (and other government agencies)
by Joe Murphy
HHS OIG has provided a detailed, generally well-developed guide on compliance programs, Department of Health and Human Services, Office of Inspector General, General Compliance Program Guidance, November 2023. In a previous issue of Ideas & Answers I quoted extensively from the Guide’s coverage of incentives because I thought they made some excellent points. In this note, however, I would like to point out a bit of an anomaly in OIG’s Guide and make a suggestion for a revision.
OIG says you need a compliance management committee
The document is, of course, a guidance piece, and OIG is not dictating what healthcare companies are required to do (although anyone contracting with the Federal Government does need to be aware of legal requirements relating to compliance programs as spelled out in the Federal Acquisition Regulation.) But as in the classic book, Animal Farm, where some animals were more equal than others, let’s just say some things are more recommended than others. One item that appears almost a mandatory element is to have a management compliance committee. (My comments here are not directed at board-level committees, just the reference to management ones).
Compliance committees at management level can serve a valuable purpose, and I have used them and see their value. But I have not generally seen governments in the US and globally treat them quite as strongly as OIG. Nor do I think this appreciation for these committees is universal in the compliance and ethics community. So it is striking that OIG takes a tool that many of us would recommend but not see as a requirement and focuses on it so strongly.
If management committees are so important, what about field compliance people?
But my point here is...
From the Devil’s Dictionary:
Litigation, n. A machine which you go into as a pig and come out of as a sausage.
Oct 25, 2017