The concept of an effective compliance program is one that has gained tremendous attention from the government.  The simple existence of a compliance program is no longer sufficient.  Many organizations and compliance officers are aware of the essential elements of an effective compliance program and are making efforts to continually evaluate and improve their program.  However, often organizations are not digging deep enough to identify the real issues.   Studies have shown and we have also seen, that your entry level employees and middle managers have a much greater understanding of your day to day processes and risks than your senior and executive leaders.  Yet, many organizations overlook the lower level employees and the value they bring to compliance assessments.

For a compliance program to truly be effective, you cannot limit your evaluations to the highest levels in the organization.  Those within a leadership position in your organization can provide valuable feedback regarding what your policies and procedures require but your front line employees can tell you what really happens on a day to day basis.  Compliance officers need to rethink the how and why of their organizational assessments and start moving towards a more visible, interactive and accessible role.  Informal and formal staff interviews as well as surveys of all staff, and especially those conducting the day to day operations, can yield crucial insight into not only compliance risks but compliance successes that should be shared throughout the organization.

HBE is available to assist you with designing and conducting risk assessments, employee interviews and employee surveys.