On some level, I applaud your organization's approach in trying to raise awareness of compliance policies by having you, the compliance pro read them. Notice many people will push back and use words like "memorize", etc, etc. Sounds to me that they wanted you to not only be aware these policies existed but to become familiar with them on some level. Nice...as I know compliance pros that may know where policies can be found but have no idea about the content of the policies. Not saying this is good or bad...just sharing.
One thought to think about is if you are tasked with identifying the important policies for each department, consider having a manager, supervisor, department lead, or someone at the front line level as part of this review and identify effort. I am often amazed how much assessment or evaluation types of activity are done with little or no direct input by those directly involved. I get it...it happens.
As for orientation....stick to the most critical and basic. What does one do if one suspects non compliance...how to reach the compliance person...and the company's position on non retaliation. If you can get those 3 done...you have established a good base on which to build. You can always throw in where to find policies but that can also be done when new employees complete their dept specific orientation.
Good luck!
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Original Message:
Sent: 07-01-2020 08:42 AM
From: Brian Haines
Subject: New employee orientation/Compliance
What Great timing for you to ask this question. I too am looking into this. We were requested to go one step farther and document the important policies for each department not just Compliance. In a previous job, i was required to sit and read all compliance policies (about 50) and attest that i read them. We discussed putting policies into an employee handbook, however, if audited we would then have to supply the entire handbook rather than just the policy. In other words, giving the auditors more information than required. We suggestion we came up with was to utilize our policy program and assign those important policies for each department and have employees attest that they read their department policies. I'm wondering if anyone has created a policy on department checklists for new hire orientation that they would share.
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Brian Haines
Corporate Compliance Manager
Original Message:
Sent: 06-29-2020 10:25 AM
From: Savannah Knuettel
Subject: New employee orientation/Compliance
I am working with HR to restructure our orientation and training. I am trying to figure out the best way to accomplish this specifically covering all of our policies. Currently, HR meets with new employees for a day session which include going through the employee handbook, benefits, and completing thier online training. In regards to each policy we have (privacy, security, quality, compliance policies, etc.) are you doing a brief overview of each policy in person? Are you doing a brieft overview of each policy through your online training? Do you have a system where they go in and look at the entire policy as a whole and sign off that they have read and reviewed? I want to make sure the employee is aware of all of our policies, but at the same time is it overkill that they go through 60 plus policies and check off they have reviewed each one? Would a handbook or electronic pdf with all current policies (this would be a ton of pages) and a signed statement at the back of the book be the best option (similar to employee handbook but a policy handbook)? Open to all ideas and what others are doing?
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Savannah Knuettel
Compliance Officer
Galen Medical Group
Hixson,TN
The views expressed herein are my own and do not represent those of my employer or clients. They are not meant to constitute legal advice or create an attorney-client relationship.
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