Engaging Frontline Staff: Individual Compliance Responsibility

May 1, 2024

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

Originally Posted on: Compliance Cosmos

A compliance program’s success is seen in its ability to engage each person in the organization—not only senior leaders and managers but all frontline staff—in their individual compliance responsibilities. Compliance is everyone’s job. But how can the compliance program reach every individual in a meaningful way? Staff need more than the knowledge that a compliance program, a code of conduct, and policies exist; they need a personal understanding of how to do one’s job compliantly and a commitment to doing the right thing and speaking up if there is suspected noncompliance. Frontline staff engagement is an organization’s first line of defense against fraud, waste, and abuse. We must instill in all staff that they are critical to our organization’s success, not just in patient care, quality, and safety, but in our organization’s compliance.

Certainly, frontline staff engagement starts with leaders and managers who are both committed to compliance and actively promote the compliance program. Promoting the program includes providing frontline staff with the tools needed for their jobs and underscoring a culture of compliance. The compliance program should also focus its strategy and efforts on instilling the value of compliance in each person in the organization. First, the compliance program staff should be active, approachable, and visible throughout the organization. Visiting departments, being present at operations meetings, and getting to know staff develop rapport. When staff know your name and face, they are more comfortable reaching out if they have a question or suspect an issue.

Second, review your general compliance training. How does it address commitment at an individual level and all levels? Does it clearly communicate compliance expectations, what to report, and how to report? Also, confirm that general compliance training is required for all staff.

Third, regularly survey staff regarding their compliance knowledge and perspectives on the culture. This reinforces that staff have a voice and are essential to compliance. This also displays the compliance program’s commitment to engaging staff. There are many great survey questions to consider in the HCCA–OIG’s Measuring Compliance Program Effectiveness: A Resource Guide.[1]

Finally, consider how to leverage frontline staff in more active compliance promotion. This may be through a compliance liaison or compliance champion model and can be part of a frontline staff person’s career advancement planning.

1 HCCA–OIG Compliance Effectiveness Roundtable, Measuring Compliance Program Effectiveness: A Resource Guide, March 27, 2017, https://oig.hhs.gov/documents/toolkits/928/HCCA-OIG-Resource-Guide.pdf.

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

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