Have You Created a Compliance Culture?

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Is your organization’s culture complimenting your healthcare compliance program? Does it enhance and maximize your program’s effectiveness? Or, is your culture secretly sabotaging your compliance efforts? These are the key questions addressed in our first ever episode of The Healthcare Compliance Pod:

See Podcast here.

Having a “compliance culture” means that compliance is a central, unalterable, and pervasive part of the organization, combined with enough commitment and leadership to back it up year after year. Organizations with a compliance culture make compliance mission critical. Mission and compliance are inextricably linked. Leadership repeatedly reinforces the message – not just through their words but through their actions – that there is no mission unless it’s done in accordance with legal requirements. When set up properly, compliance becomes an integral part of the provider’s business from top to bottom.

Culture is an elusive concept, but every organization has one. It’s essentially the shared beliefs and values of the people within the organization. The reason your culture is so important to the success of your compliance program is that your culture actually influences and directs the thoughts and behaviors of your employees. Organizations with a strong compliance culture have employees who understand that management wants them to prioritize compliance, the employees respond to situations with compliance top of mind because they also believe it’s the right thing to do, and the employees know they will be rewarded by demonstrating this commitment to compliance. Compliance culture directs employees to think and behave in ways that make your compliance program effective, such as reporting suspected compliance issues, adhering to policies, seeking guidance when a policy or requirement is unclear, and respecting and valuing legal and regulatory requirements.

Your compliance program must be more than a set of policies and procedures that you periodically train your employees on. It must be a core value and shared belief throughout the organization, or it will never be effective. You can have the most comprehensive and detailed set of compliance policies and a dedicated team of professionals to implement them, but if the culture within your organization downplays the importance of those policies, tolerates or accepts non-compliance with them, and minimizes the ramifications of non-compliance, your program isn’t going to be effective because your culture is actively working against it.

Employees in this type of environment are less likely to report suspected compliance issues and more likely to cut corners or justify their own non-compliant behaviors. This type of culture also creates dissatisfaction among those employees who are more compliance-oriented or self-described rule followers. They are likely to become disenfranchised or frustrated by the culture, making it more difficult for you to retain them, as well as creating potential whistleblowers who feel compelled to report suspected non-compliance to regulatory authorities.

You may think you have a strong compliance culture, but do you really? How do you really know if your organization has a compliance culture? Consider:

  • What are you and other leaders in your organization doing on a daily basis to reinforce that compliance is mission critical for your organization?
  • What types of behavior is your organization incentivizing and do they result in decisions and responses by employees that further compliance or hinder it?
  • What values are you and other leaders promoting and do these values tie back to compliance?

It’s also important to look beyond how you and other leaders perceive your culture. Our podcast this week includes a free sample survey to assess how your organization is doing in creating a compliance culture. Check it out here on our free resources page.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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