Effectiveness Through Investment in Compliance Program Team Members

July 1, 2024

By Sarah Couture (Principal at Couture Consulting LLC in Indianapolis, IN.)

Originally Posted on: Compliance Cosmos

In the June 2024 issue of Compliance Today, our column, “Successful engagement and integration of new compliance program staff,” discussed intentional assimilation and development of new compliance professionals and/or those new to our institutions.[1] While a meaningful approach to onboarding newer team members is obviously an essential component of an effective compliance program, it is also important to develop a strategy of ongoing investment in compliance program team members. No one has “arrived”; we all need to keep learning, growing, and developing for our own sake and for the health of our organizations.

Regarding the evaluation of a compliance program’s effectiveness, the U.S. Department of Justice’s Evaluation of Corporate Compliance Programs discusses compliance program staff experience, qualifications, and investment, as well as the turnover rate.[2] An intentional approach to team member growth will not only help promote compliance program effectiveness through having a more qualified team to implement the program but will also help safeguard the program through retention of great talent.[3]

Ensure you have a compliance program people strategy that outlines development goals and investment measures as well as communication approaches. First, make sure there is a clear career progression path for your team members. Communicate this to your team and regularly discuss progress toward goals. Good people are more likely to stay if they can see how they can grow in your organization over time. Second, secure budget money for continuing education and other development opportunities. This resource allocation communicates a commitment to compliance, and the organization values compliance team members. Third, expect, or even require, relevant certifications from your team members that will be beneficial to their specific roles. While all healthcare compliance team members should pursue a general certification like the CHC (Certified in Health Care Compliance), other function-specific or risk-specific compliance roles may benefit from additional certifications related to investigations, auditing, privacy, coding, research, etc. Finally, clear communication regarding team member expectations and performance should be prioritized. Promote transparency and ensure clear communication from the program’s leadership so that team members know what is expected of them. Develop a “clear but kind” communication approach that promotes personal development and team retention.[4] Address concerns in a thoughtful but straightforward way. This approach—rather than avoidance or negativity—promotes team member growth and prevents workarounds and other inefficiencies.

1 Sarah M. Couture, “Successful engagement and integration of new compliance program staff,” Compliance Today, June 2024, https://compliancecosmos.org/successful-engagement-and-integration-new-compliance-program-staff.

2 U.S. Department of Justice, Criminal Division, Evaluation of Corporate Compliance Programs, updated March 2023, https://www.justice.gov/criminal/criminal-fraud/page/file/937501/dl.

3 Chauncey Crail, “15 Effective Employee Retention Strategies In 2024,” Forbes Advisor, updated April 30, 2024, https://www.forbes.com/advisor/business/employee-retention-strategies/.

4 Brené Brown, “Clear Is Kind. Unclear Is Unkind,” Brené Brown, October 15, 2018, https://brenebrown.com/articles/2018/10/15/clear-is-kind-unclear-is-unkind/.

Copyright 2024 Compliance Today, a publication of the Health Care Compliance Association (HCCA)

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