At the center of an effective compliance program is a clear compliance work plan, inclusive of core compliance activities, accountabilities, and due dates. While the development of the actual plan is often led by the compliance officer or compliance department, the responsibility for assignments and reporting progress within the plan should extend far beyond the compliance team into all departments across your organization.
Within the healthcare industry, there’s some variability amongst what is most important and applicable to track and report within, but the following core factors are critical to keep in perspective despite the specific sector of healthcare you work in:
Compliance Committee Oversight- The compliance committee should be weighing in on the content and priorities and taking an active role in ensuring those assigned projects are actively keeping up with their accountabilities and that any variances or concerns are called out and reviewed. Many organizations even require quarterly reporting of project outliers to the committee to encourage collaboration and to drive ownership over the plan and, more importantly, the work being conducted and reported within. “Living” Plan- The work plan is often referred to as a “living” plan, which means a plan that requires continuous updates and additions throughout the calendar year as new risks and areas of concern are identified, which need monitoring or review.
Overall, despite the fact that most compliance work plans are developed and refined annually, the management of the plan should be an iterative process involving regular updates and changes in response to industry dynamics and newly identified risks impacting the organization.
Board of Directors Approval- The official stamp of approval to launch the compliance plan should come from the organization’s board of directors. It’s best practice if the compliance committee reviews and approves first, after which the compliance officer presents the plan, usually at a high level, for board approval, calling out that updates and changes to the plan are expected. Furthermore, progress toward project completion within the plan should be communicated to the board, and any concerns identified should also be shared in an effort to keep them apprised. After all, when the structure within the organization is accurately set, the compliance officer is accountable to the board, which owns ultimate responsibility for the organization’s compliance program.
In summary, the compliance work plan is vital to ensure your organization is monitoring risks and actively reviewing core business controls. When done well, the plan and the process of regular review and reporting can help ensure effective lines of communication are taking place within the organization and robust auditing and monitoring are happening, which are two of the seven core elements of an effective compliance program.