To Maintain a Culture of Compliance in a Crisis Environment, Communicate

Creating a culture of ethical behavior and compliance is a key component of an effective Compliance Program. Few situations challenge an organization’s ability to achieve this more than the COVID-19 crisis. Organizations are faced with figuring out how to ensure that they continue to operate in a way that is aligned with regulatory requirements, that prevent fraud and abuse, and that continues to identify and mitigate compliance issues.

Compliance professionals spend time communicating the importance of preventing fraud and abuse. They focus their efforts on creating an environment where people feel compelled to do the right thing and feel safe bringing bad news forward. Historically, early detection of compliance issues resulted from regular internal auditing and monitoring activities. Sometimes, issues are reported directly to compliance professionals; other times, an anonymous message is left on a hotline or in a lockbox. How do we maintain a culture of ethical and compliant behavior while working remotely? How do we ensure that best practices are being maintained when so many are experiencing heightened stress and anxiety? Here are some helpful communication tips to ensure that your Compliance Program remains effective.

Communicate, Communicate, Communicate

• Given the seemingly “new normal” of remote and virtual teams, regular and consistent communication is vital. Keeping people informed is a fundamental function of leadership and of compliance professionals. Maintain staff morale by publicly recognizing their efforts and commitment, and provide staff with regular feedback, recognizing their hard work and celebrating success, however minor.
• Stay in constant contact with staff and ask them how they are managing, what concerns they have, and what help they need to keep things going. Then listen, really listen to understand. Communicating a message through your actions that conveys “we’re all in this together” speaks volumes. When staff raise an issue or concern, genuinely thank them for contributing to a positive environment of compliance.
• Staff may become overwhelmed with the ever-changing guidelines. Keep them informed by providing targeted, specific detail about regulatory changes and their potential impact on workflow. Let them know how information will be disseminated and where to access updates. Keep staff engaged by including them in collaborative discussions about how to remain in compliance. Not only will you convey a message of “I value your input,” but you’ll also gain their buy-in and increase their sense of ownership.
• Recognize how an ongoing crisis might affect you. What messages are you conveying through your actions and responses? Be mindful of potentially flooding a person’s “Inbox” with a flurry of emails to address an issue. Instead, periodically pick up the phone to brainstorm or iron things out with someone. Remember that words in an email do not contain the softened delivery of face-to-face communication and can lack the immediacy of clarification.

The “secret sauce”: communicate, communicate, communicate.

The information and advice we are providing for this matter relates to COVID-19 legislative relief measures. Because legislative efforts are still ongoing, we expect that there may be additional guidance and clarification from regulators that could modify some of the advice and information provided to you, after the conclusion of our engagement. We, therefore, make no warranties, expressed or implied, on the services provided hereunder.