General Compliance Topics

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  • 1.  Resolution Transparency

    Posted 27 days ago
    Good Morning All,

    I am reaching out to see how other organizations have handled a portion of section L: Communications about Misconduct (below) from the DOJ Compliance Effectiveness guidance?
    • What communications have there been generally when an employee is terminated or otherwise disciplined for failure to comply with the company's policies, procedures, and controls (e.g., anonymized descriptions of the type of misconduct that leads to discipline)?
    We are exploring strategies to fulfill this section and are curious what ideas have been used by others.

    Thank you!

    Cathryn Pratley
    System Compliance Director
    Bronson Healthcare Group
    SCCE Membership

  • 2.  RE: Resolution Transparency

    Posted 26 days ago
    Edited by Steve Pavlicek 26 days ago
    Hi Cathryn,

    Your prompt seems too important to miss and I have not really heard much chatter on this particular requirement. I am commenting so that I can follow along.

    EDIT: I just found a closely related and recent podcast on compliance exit interviews you may want to check out:

    Shemekia Alexander on Compliance Exit Interviews [Podcast] - The Compliance and Ethics Blog
    The Compliance and Ethics Blog remove preview
    Shemekia Alexander on Compliance Exit Interviews [Podcast] - The Compliance and Ethics Blog Play in new window | Download (Duration: 10:49 - 10.0MB)Subscribe: Apple Podcasts | Google Podcasts | Stitcher | Email | TuneIn | RSSBy Adam Turteltaub Exit interviews can be terrific sources of information for compliance teams, but how do you make the most of them?
    View this on The Compliance and Ethics Blog >

    Thank you!

    Stephen (Steve) Pavlicek | Community Engagement Manager
    Society of Corporate Compliance and Ethics
    Health Care Compliance Association
    Office: 952.567.6219 | Mobile: 612.207.3172
    6462 City West Parkway | Eden Prairie, MN 55344

    SCCE Membership

  • 3.  RE: Resolution Transparency

    Posted 26 days ago
    I will see if I can offer any valuable information.  I take these incidents and use them in my New Employee Orientation and the employee Annual Compliance trainings for examples.  I do not use any names or departments of who was found non-compliant and disciplined.  I start out by saying the examples I am using are either things our organization has experienced or things I have read about with other organizations.  That way they don't know exactly where the incident occurred, but more so that these things do occur.

    We also talk more specifically about these incidents in the Compliance Committee meeting.  We discuss if there is further education that should happen with staff or are there any processes or policies that should be revised to be more clear on what not to do.

    Hopefully this is somewhat helpful.

    Ann Dunham
    Compliance Officer
    Hannibal Regional Healthcare System
    Hannibal, MO

    SCCE Membership