Compliance Today - November 2020

Catherine Boerner (cboerner@boernerconsultingllc.com) is President of Boerner Consulting LLC in New Berlin, WI.

• linkedin.com/in/catherineboerner/

I guess this is truly a good topic to help compliance officers exhale! The sooner compliance professionals realize that they will never be caught up, the better. I think it takes a lot of stress off to understand this is the nature of the compliance department. New compliance events and inquiries come in every day; you cannot always plan your day. Some investigations take longer than others. Many compliance events seem much worse or more urgent at first than the reality of what is happening in the organization. Some days, it is easy to get caught up in the emotional stress of wondering how bad it might get.

Here are some tips to help you stay focused and organized:

• Create an annual compliance program infrastructure work plan to keep you on track and your program’s structures and processes effective.

• Keep an inquiry log with responses to questions/inquiries to assist with consistent messaging as different compliance team members respond to inquiries. This also helps with reducing research time if a similar question has been asked multiple times. This is for those questions that come in that are not “events.”

• Create an annual compliance auditing and monitoring plan from the compliance risk assessment to help reduce compliance risk.

• Schedule weekly compliance team meetings/calls with a standing agenda to walk through the status and discuss priorities of each team member at a high level. For example, organize the standing agenda by the element of the program as follows:

  • Opening Announcements

  • Element 1: Policies/procedures

  • Element 2: Compliance officer and compliance team

  • Element 3: Training and education

  • Element 4: Monitoring and auditing

  • Element 5: Reporting and investigating

    1. Staff inquiries: Number, description

    2. Compliance events: Event number, name, brief description, status (number of days open)

    3. Privacy events: Event number, name, brief description, status (number of days open)

  • Element 6: Enforcement and discipline

    1. Disciplinary actions

  • Element 7: Response and prevention

• Learn to reprioritize every day—ask yourself what is important today.

• Set specific times that you check your email (e.g., only check email at 9 a.m., 1 p.m., and 4 p.m.—close email at all other times with no sound alerts).

• Block one full day a week on your calendar for no interruptions.

• If workload is really pilling up and creating compliance risk, it may be time to reevaluate your compliance department staffing needs.