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The Beneficial Use of Surveys in the Benchmarking Process

Mary Lundregan

 

The OIGs various Program Guidance documents advise of the need to, benchmark your organizations progress as you implement a Corporate Compliance Program and evidence the Programs effectiveness. In fact, the OIG recommends a "snapshot" be taken of the environment so that a baseline may be established to monitor progress in eliminating areas of risk and vulnerability. That sounds like a great idea, but how does one go about doing it?

The task may sound onerous, but, in fact, it can be quite simple. Consider the option of surveys. Administering a survey to the employee population can help any organization work through the seemingly impossible effort of evidencing the effectiveness of a Compliance Program or simply gaining insight into the culture and environment. Surveys can measure the perceptions and culture of the companys employees on a number of issues relating to them personally, their immediate work group, their supervisor and the management of the company. An objective survey of the employee population takes the OIG prescribed "snapshot" of the workplace environment that will allow the organization to benchmark their progress and note achievements with the use of future surveys. In addition, the results of surveys assist a companys own organizational analysis of its policies and programs.

Today, surveys are available that are specifically designed to monitor the effectiveness of an organizations Compliance Program. These surveys poll employees about their knowledge, awareness and understanding of an existing and maturing Compliance Program. The questions for a survey of this nature should parallel government guidance defining an effective corporate compliance program.

The option of conducting focus groups throughout the organization is another way to survey your organizations employees. Bringing together a peer group to discuss general areas of concern can solicit employee opinions and perceptions regarding compliance matters and identify compliance risks. Following an informal and interactive discussion of this kind, participants may be asked to complete a short, anonymous questionnaire. The results of this type of survey will accentuate a companys own organizational analysis and provide additional data to support and interpret the conclusions drawn from any system-wide benchmark survey.

Corporate Compliance Training is critical to the implementation of an effective Compliance Program and every company should use compliance-training evaluations to document the effectiveness of such a program. At the end of each training session, the trainer should encourage employees to complete an anonymous training survey form. The evaluations should be reviewed after each training session to note any concerns, problems or innovative suggestions. The forms should be kept on file as evidence of the population trained and the level of effectiveness of the training.

Another innovative survey tool to be considered is an exit interview. This involves using a confidential and anonymous survey of departing employees to obtain their perceptions of the compliance environment in their former workplace. The evaluations of departing employees regarding the work environment, equality of opportunity, corporate standards of business conduct/ethics, quality of service and other compliance issues are very helpful in this endeavor. An exit interview provides an additional and important compliance communication opportunity. These evaluations provide insight into the corporate culture and compliance environment and can be contrasted with benchmark surveys of current employees. This process can reduce the likelihood that a former employee will become a whistleblower and provides worthwhile input on compliance risks and employee morale.

Applying the guidance offered by the various authorities and government agencies is easy when you consider the options provided by using innovative survey instruments. However, the benefits of administering a survey go beyond simple adherence to government guidance. Surveys provide organizations with invaluable information about employee perceptions of the work environment, allow an organization to tailor a Compliance Program to the specific needs and areas identified by employees, and demonstrate evidence of the organizations legitimate efforts toward compliance.

 

 

Mary K. Lundregan is the Director of Survey Services for Strategic Management Systems, Inc., a healthcare consulting firm located in Alexandria, VA. She may be reached via e-mail at .

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