Donnetta Horseman (donnetta.horseman@moffitt.org) is Chief Compliance Officer at H. Lee Moffitt Cancer Center and Research Institute in Tampa, FL.
How do you ensure your compliance awareness messages are reaching all areas of your organization? We know that every employee may not have time to visit the intranet or read every newsletter. Consider implementing a compliance champions program to expand the reach of your compliance program without increasing your budget. Below are some recommendations for a successful compliance champions program.
Purpose
Design a compliance champions program to create compliance advocates throughout all levels of the organization. After completion of the program, the participants will be able to aid in the continual improvement of the compliance program by serving as role models for their peers, capturing gaps and risks within the individual departments, providing valuable feedback, continuing to open lines of communication between departments and the compliance department, and increasing staff member interest and attendance at valuable compliance trainings.
Structure
Determine the frequency of the program. Consider soliciting nominations for participants from department managers and directors. Survey those nominated to gauge their level of interest in the program. Determine how many participants will be accepted. Since the program will be made up of participants from various departments, the selection process should involve consideration of the nomination from the manager, the nominees’ responses to the survey questions, and the areas of risk identified by the compliance department. Determine how often the selected participants will meet. After completion of the program, each compliance champion should receive a certificate of completion and be recognized by the organization for their contributions to expanding the reach of compliance.
Topics
The first meeting should set expectations for the program and allow the participants time to get acquainted with each other. Consider having members of the compliance department introduce themselves and give a brief summary of their job duties. Determine the future meeting topics based on the highest risk areas of your individual organization. The meetings should consist of interactive education and real-life scenarios to encourage dialogue and discussion. The final meeting should include a celebration of the compliance champions’ accomplishments and include the presentation of a certificate of completion. If possible, have the CEO attend to celebrate the accomplishment and demonstrate leadership’s commitment to compliance.
Participation after program conclusion
After the conclusion of the program, continue to engage the compliance champions with regular communications from the compliance department. Ask the compliance champions to be a conduit for information sharing with those in their respective departments and bring pertinent information and ideas back to the compliance department. It is imperative to keep the compliance champions engaged to ensure an effective program.