Chapter 3: Running an Effective Compliance Program

Educating Management and Physicians on Accountability

Even the seminal 1998 Publication of the OIG Compliance Program Guidance for Hospitals emphasized that “proper education and training of corporate officers, managers … and the continual retraining of current personnel at all levels are significant elements of an effective compliance program.”[7] Arguably at least, the failure to provide effective targeted education and training to supervisors, managers, directors, and executives is likely to have a negative impact on all other programmatic elements. Having well-crafted and well-designed policies and procedures will have no positive impact on the establishment and maintenance of an ethical corporate culture if leaders are not aware of the policies and how they apply from an operational perspective and if they do not ensure that downline employees understand their application.

Employees will also be unlikely to report observed misconduct if they aren’t regularly informed about the types of issues that should be reported and options for reporting. If reporting through the chain of command is the preferred reporting option and an employee perceives that his or her upline leader is disinterested or fails to act upon a reported concern, the employee’s willingness to report known or suspected issues suffers. Word travels quickly if investigation of a reported concern is not handled in a respectful manner that protects the involved parties. Worse yet, if employees observe a known reporter experiencing retaliation as a result of making a report, knowledge of that outcome will quickly become an embedded obstacle to building a transparent culture where issues are brought forward and acted upon appropriately.

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