Communicating with and educating an organization’s workforce about compliance matters is a cornerstone of an effective compliance program. In their June 2020 compliance-program effectiveness guidance, the Department of Justice (DOJ) states that compliance program information should be disseminated and understood by employees in practice; and training and communications should be appropriately crafted. The DOJ is evaluating compliance programs on how well organizations communicate with their workforce and how effectively they train them on compliance matters.
Many issues that compliance programs run into will affect an organization’s workforce. The communications and/or marketing team can help facilitate delivery of important compliance messages to the organization’s workforce and to the public at-large. For example, when a privacy breach occurs and affects more than 500 individuals, Compliance must report the breach to government agencies and local media. Communications and marketing personnel are trained and experienced in crafting well-written and concise messages of this nature. Compliance should partner with them if and when it is necessary.
Reaching an organization’s workforce and making an impact about the importance of compliance issues must be done strategically. The compliance program needs to be known and its priorities understood to help reduce the risk of noncompliance throughout the organization. One of the first steps in helping employees easily recognize the program is to create a compliance program brand.
Branding a Compliance Program
Having an amazing program is worthless if no one knows about it, sees its value, can understand it, or can figure out how to use it. To help a compliance program succeed, use the powers of branding to give the program a face that employees can recognize. Doing so will help the program receive the attention it deserves. A strong brand is one of the most valuable assets a compliance program can have. It will inspire loyalty, trust, and higher employee engagement.
A strong compliance brand will live in the hearts and minds of employees. The program’s name will have meaning. A motto will communicate a program’s values. For some organizations, a mascot can make a program relatable and personable. Some organizations, for example, often choose superheroes and animals for their mascots. These branding aspects will bring life to a compliance program and promote positive associations with it amongst employees. For example, the mascot can appear in an organization’s compliance training and awareness activities. Some organizations may use the mascot in training comic strips and issue the mascot’s logo on compliance awareness trinkets.
The branding process should be strategic, focused on the big picture and long-term efforts that address the “why” behind the program. Customers include groups such as employees, contractors, board members, and suppliers. The way employees perceive the compliance program’s brand has consequences.
When building a compliance program brand, consider the following:
-
What do you want the compliance department to be known for? What do you want its reputation to be?
-
Do employees currently have positive or negative associations with compliance?
-
Is the compliance department known for being trustworthy, responsive, and innovative? Or is it known for being unresponsive and taking up employee time with meaningless “check the box” tasks?
These are important questions to ask, and it is critical that honest answers are given. If a program’s brand associations are negative, then own up to the negativity. A positive brand association is critical to the success of a compliance program.
Determine Value
Before beginning a branding effort, reach out and work with internal marketing and communications teams. They will be an invaluable resource, and it will help to engage them early rather than face their criticism later on. When ready to brand the compliance program, it’s good to start by answering an important set of questions. The answers will help the compliance professional better understand what the compliance program brings to its customer—the organization’s employees and other key stakeholders. The questions include:
What is the current compliance experience? A brand is what people say it is; the goal is to eventually influence their thinking. Before beginning a branding effort, understand the employees’ and others’ current perception of the compliance program. When employees think about the compliance program, what comes to their minds? Is it good, bad, or somewhere in between? Does it match how you see the compliance program?
What is the program’s mission statement? A strong mission statement (or program charter) will help spell out precisely what the program is trying to accomplish. It should align to efforts around that goal. A mission statement gives the compliance program a distinct identity and purpose and is something to which everyone can hold themselves accountable.
Do you have leadership buy-in? Along with the support from the marketing and communications department, a program certainly needs the support of senior leadership. The leadership team should be authentic advocates for your compliance brand. For the brand to be seen as trustworthy, it has to be embraced by all employees, and that goal must start at the top. Employees need to see leadership’s actions and words aligning with the compliance mission statement before they are willing to do the same.
Who are the primary customers of the compliance department? More than likely employees are the program’s first-line customers, and you may define those customers by department, role, location, and exposure to risk. Great brands are stellar because they don’t take a “one size fits all” approach. Developers take the time to consider what all customers, including stakeholders, have in common and what their unique needs are. For example, what are their most urgent and pressing concerns? Are those concerns consistent across all stakeholders, or do concerns vary based on regulations or policies? Do all stakeholders use the same communication channels to report compliance concerns, or do channels vary based on location or division? You must take the time to know your audiences and their needs for your branding efforts to be successful. You cannot build brand loyalty if your efforts are not aligned with your stakeholders’ needs and desires.
What are the compliance program’s core competencies? The success of a compliance program and how your employees and other stakeholders perceive it is greatly influenced by the competencies of compliance officers and their teams. The core competencies of a compliance team are what bring the compliance program and brand to life and create a connection with employees. A compliance team’s core competencies will help evoke traits such as trust, fairness, and transparency. Ultimately, these competencies enable you to keep the promises you make. Core competencies may include:
-
Strong communication skills and the ability to put things into context
-
The ability to evaluate risk and deliver results with tact
-
Independence
-
Reliance on research and analytics
-
Innovative approaches
-
A strong moral compass; trustworthiness
-
Fairness and transparency
What benefits does compliance deliver to employees? What benefits do employees receive when they use the services or products offered by the brand? For example, the compliance department may provide employees with a safe and secure place to share their concerns and ask compliance-focused questions without judgment. A compliance professional may provide for leadership and the board of directors information about hotline cases and training records that help illustrate how risks are being mitigated and an ethical culture is being fostered. It does not matter if the benefits the compliance program delivers are qualitative or quantitative if they are readily identifiable and valued by the primary target customers.
It is common for an organization to call its compliance function a compliance department. Yet a compliance program’s identity and brand may be influenced by the mission and culture of its organization. For example, some compliance program’s link to achieving the highest quality in healthcare and may include a tagline or motto that includes “quality” in addition to compliance. Other organizations may choose to label their compliance program an Ethics Program to emphasize that reporting issues is an ethical decision. Also, some organizations may feel that the word “compliance” has a negative connotation to its employees and may not create an open and transparent culture. Some common examples of compliance program taglines/mottos follow.
Compliance Program Mottos and Taglines
Here are some taglines/mottos that are often associated with an organization’s hotline/helpline:
-
Act with Integrity
-
Compliance and Ethics Helpline
-
Compliance is Everyone’s Responsibility
-
Do the Right Thing
-
Do: What’s Right
-
Doing What’s Right
-
Inspire Integrity By Speaking Up
-
Make It Right!
-
No to Compromise! Yes, to Respect, Excellence, Integrity, Open & Honest
-
See it...Hear it...Suspect it...Report it
-
See Something, Say Something
-
Speak Up—with Confidence
-
Speak-up!
-
We Care Line
-
Your Concerns Matter
Create a Brand Story
A brand story is an effective way to connect with your audience. This story is what will help you appeal to the emotions of your compliance stakeholders. Internet marketing expert Neil Patel recommends the following guidelines (adjusted here to fit the world of compliance) regarding what a brand story is.[7] Your compliance brand story is:
-
The reason your compliance department came to be
-
What motivates you and your team to come to work each day
-
An “inside look” at your ethics and compliance program
-
The types of stakeholders that find value in working with the compliance department and why
-
A transparent view of the people behind the compliance program
-
A relationship-building tool
-
Subtler than you realize
-
A concept that underscores your compliance program’s entire presence, something that your entire organization embraces
-
A look at who you are as a compliance department
Your compliance brand storytelling is not about the compliance department; it is about your stakeholders and the value you deliver to them. Your employees typically are your focus, and your brand story should prioritize them.
Branding Resources
Check out these online resources, which can help you during the branding process:
Templates and Examples
Free Stock Images and GIFs
-
Raw Pixel: www.rawpixel.com
-
Unsplash: unsplash.com
-
Pexels: www.pexels.com
-
Pixabay: pixabay.com
-
Giphy: giphy.com
Free Fonts
-
DaFont: dafont.com
-
FontSquirrel: fontsquirrel.com
-
Font Space: fontspace.com/popular/fonts
Video, PowerPoint, and Animation
-
Powtoon (video and presentation): powtoon.com/
-
Animaker (animation tool): animaker.com
Case Study: Compliance Program Branding at a Hospice
Kerri Ervin, MS, RN, CHC, CHPN
Avow Hospice: Naples, Florida
Clinical staff members at hospice organizations often choose their line of work to make a difference in the lives of others. Although their primary focus is always on providing patients and their families with the best possible care, they also acknowledge that healthcare is changing and understand that there is more regulatory scrutiny every day. Hospice clinical staff members look for ways to meet the needs of those they serve while remaining compliant, because compliant practice helps to ensure that the organization will continue to fulfill its purpose of bringing comfort, peace, and calm to those in need. My job as a hospice compliance professional is to help our hospice care clinical staff provide compliant, high-quality care. I work to make the connection between compliance and practice easier and more streamlined so that compliance is just a part of everyday thinking and practice.
Hospice is an area of healthcare under intense scrutiny. Not unlike other areas of healthcare, hospice programs operate under a significant number of rules and regulations. The Centers for Medicare & Medicaid Services (CMS), the Office for Civil Rights (OCR), state survey agencies, and accrediting bodies provide oversight. Hospice, unlike some other areas of healthcare, is not required to have a compliance program. However, the Health & Human Services Office of Inspector General (OIG) released compliance program guidance for hospices in 1999, and a hospice would have a very difficult time explaining the lack of a formal compliance program today.
Making It Fun
When I first started my career in compliance, after serving as a hospice nurse for many years, my hospice organization created a formal compliance program. As the compliance officer, it was my responsibility to implement the program within the organization. Knowing that the word “compliance” often caused eyes to glaze over and staff members to zone out, I knew I needed some fun, innovative, and engaging ideas for implementing the program. To gather information and receive inspiration, I attended the 2014 Compliance Institute in San Diego and attended a session on ways to grow compliance programs. There were many fun and innovative ideas presented during the session, but one idea truly resonated with me. The idea was to brand the new compliance program and to hold a program kickoff during Corporate Compliance and Ethics Week. By using a mascot, naming contest, and other fun ways to involve staff members, we would be able to grow familiarity with the compliance program while gathering and maintaining attention over a full week.
After the Compliance Institute ended, I returned home with many good ideas, excited about celebrating Corporate Compliance and Ethics Week at my organization. Thinking strategically, I could see how branding the program would help cement it into the organization’s culture and create long-term engagement. I reviewed the Health Care Compliance Association (HCCA) website and all the great resources on Corporate Compliance and Ethics Week.
I reached out to staff members in our Quality department and Communications department to collaborate on implementing a week of activities to launch the new program. Together, we came up with the idea of creating a mascot to bring awareness and recognition to the program. The idea of a cute, fun, and recognizable compliance owl mascot was an immediate hit with the group. The Communications department used a variety of images of a commercial owl graphic, including different versions for holidays and seasons, and they even paired the compliance owl sitting on a hippo to symbolize HIPAA (Health Insurance Portability and Accountability Act ) compliance.
Getting Everyone Involved
Just before Corporate Compliance and Ethics Week, we presented the owl mascot to all staff members, along with details about an organization-wide naming contest. Team members and departments were asked to create and submit names for the mascot, with the winner to be announced on the last day of Corporate Compliance and Ethics Week. Departments were excited about the contest, and they worked together to create fun and interesting compliance-related names.
When the big week arrived, we continued to promote the contest while increasing awareness of compliance in the organization through daily emails, word searches, crossword puzzles, and prizes. We hosted a large luncheon for all team members and played HIPAA- and compliance-themed games while team members enjoyed a meal and good company. Team members were able to develop relationships with the compliance team members and each other, making the formalized program less intimidating.
At the end of the week, a committee met to review more than 60 submissions for the mascot-naming contest. Although nearly every team and department created and submitted a name, the Admissions department won the contest with the name “Howie Dewitt.” In the weeks and months that followed, team members would often ask when the newest version of Howie Dewitt would be released, eager to see his updated outfit for the next holiday or season.
Celebrating Our Success
Today, Howie Dewitt, our compliance and ethics mascot, is on cards and posters for the compliance program. The mascot shows up weekly in the organization’s employee newsletter, which includes tips on compliant practice, and all new employees receive a card with the compliance hotline and a picture of the mascot. When team members see the little owl, they know that compliant practice is ‘Howie Dewitt.”
Branding and launching our compliance program during Corporate Compliance and Ethics Week was a perfect strategy for our organization. Even a few years later, our clinical and nonclinical team members clearly remember the naming contest, the celebratory lunch, and, most importantly, the information they need to provide compliant, high-quality care to our patients and community members.