by Steve Shoop
The HHS OIG has called the compliance committee a fundamental component of an effective compliance program.
And, having compliance committees is
certainly recognized as a best practice in the
Compliance field. The difference between
merely having a compliance committee and
having a carefully planned and
well-managed compliance committee
can, however, dramatically affect
your entire compliance program
and your success as a compliance
officer. A committee consisting of
engaged, interested, and committed
organizational leaders will do more
to set your program’s tone at the
top and promote a culture of ethics than
dozens of public statements by your CEO
on “doings things the right way around
here.” The right committee will help give
the Compliance department a reputation
as an enabler of business, rather than the
“Department of No,” and that’s a big win for
any compliance program.
The three main areas that require
careful planning in order to maximize the
effectiveness of the compliance committee are:
(1) The establishment and purpose of
the committee—Documenting the source of
the committee’s authority and the actions it is
empowered and expected to take;
(2) The composition or membership of
the committee—Including a few “automatic”
positions: HR, finance, audit, and legal
counsel. Any optional members should be
included only after careful thought has been
given as to how they will positively impact the
work of the committee; and
( 3) The information architecture and
work flow—Delivering the information
committee members need in a timely manner
and establishing ground rules governing
the way committee members are expected to
Get the most out of your
» Establish your committee formally with written documents.
» Use your compliance risk assessment to assemble the right skills on your committee.
» Get committee members the information they need in order to allow them to contribute at the meetings.
» Have a compliance plan and share it with your committee at every meeting.
» Always show the committee how its work helps to achieve compliance plan goals.
The right committee will
help give the Compliance
department a reputation as an
enabler of business, rather than
the “Department of No.”