MINNEAPOLIS; May 11, 2017---- Compliance teams typically do not have a role in reviewing incentive programs to mitigate risk prior to its role out, according to the latest Society of Corporate Compliance and Ethics (SCCE) and the Health Care Compliance Association (HCCA) survey report. The report— Incentive Programs and Compliance—reveals that 52 percent of survey respondents never review incentive programs for management and that 46 percent report never review incentive programs for rank and file employees.

“This incentive study might shock some board members. There may be no greater return on your time and effort to build a compliant and ethical culture than to align the organization’s incentive program to it. Chief Compliance Officers have been exposed to this best practice.  However, they can’t help you gain this advantage if they are not in the room when your incentive systems are developed.  This may be the single greatest missed opportunity I have seen in compliance and ethics programs,” said SCCE/HCCA CEO Roy Snell.

A recent document from the U.S. Department of Justice demonstrates that it may be prudent for organization’s to include the Compliance Department in their incentive programs review. The survey report notes that, “The Department of Justice Fraud Section’s recently-released questions for evaluating compliance programs specifically calls out the need to review the risks in the incentive plan:  ‘How has the company considered the potential negative compliance implications of its incentives and rewards?’ This survey indicates that most compliance programs would fare poorly on this assessment point.”  

https://www.justice.gov/criminal-fraud/page/file/937501/download

In addition, organizations may benefit from a new tool —“Measuring Compliance Program Effectiveness:  A Resource Guide” released by the U.S. Department of Health and Human Services Office of Inspector General and the Health Care Compliance Association.  Link no longer available

This survey was conducted among compliance professionals in April, 2017 by the SCCE and HCCA and received 400 responses.