I learned long ago the importance of saying no. Saying no to lavish dinners paid for by vendors or potential vendors. Saying no to “free” tickets to sporting events. Saying no to gifts or anything with a value of more than $100.
Several years ago, I was in the Army stationed in Qatar and oversaw commissioning vehicles. “Sgt. Brown,” my battalion commander said to me. “Your role is important. We have to have vehicles, but you have to protect yourself from any perceived quid pro quo relationships.”
I wasn’t sure exactly what that meant, but I learned quickly after beginning the assignment. Calls started coming in from suppliers wanting the Army’s business or wanting to keep their existing contracts. I was thankful for the wise words of that officer. It saved me from making a lot of mistakes.
Starting a compliance program and building it into the organizational culture
Every organization – from the U.S. Army to small businesses to nonprofit organizations – needs a solid compliance program. It has to be more than a page in the employee handbook that gets shoved to the back of a desk drawer.
An effective compliance program needs to be woven into your organization’s culture. That’s what we are doing at CICOA Aging & In-Home Solutions.
In fall 2021, our long-time Meals and More Director, Lisa Schneekloth, was named CICOA’s first chief compliance officer. Since that time, she has worked with our board of directors, our leadership team and healthcare attorneys to develop a Corporate Compliance Plan.
To me, this plan is like having an extra blanket of security that protects us from fraud, waste and abuse.
Since rolling out our Compliance Plan to our over 400 employees, we’ve had more inquiries than ever. Reading this, you probably think this is awful. Quite the contrary.
Seeing more people coming forward asking questions and even filing complaints means we’re creating a culture where our employees feel safe about raising concerns. It means when we said, “if you see something, say something,” they took this to heart. It means I am surrounded by a staff of conscientious, caring people who want to do the right thing.
The week of Nov. 6 is Corporate Compliance & Ethics Week. We’re going to celebrate the strides we’ve made while also continuing to educate staff.
The Seven Elements of a Corporate Compliance Plan
CICOA’s Compliance Plan is made up of seven elements:
- Compliance Program Administration. This is the person responsible for implementing, monitoring and evaluating.
- Written Standards of Conduct. Everything in the plan is in writing, and we’re working to make sure this isn’t something that gets shoved to the back of a drawer.
- Training and Education. Organizations too often make the mistake of spending time and resources developing a compliance plan, but then they don’t share it. To be effective, you must promote compliance throughout your organization.
- Open Lines of Communication. No organization I know wants to be a victim of fraud, abuse or waste, so having an open-door policy with multiple lines of communication for people to report concerns is the best way to address issues promptly.
- Auditing and Monitoring. We’ll have annual reviews of our policy and adjust as needed.
- Publicizing Disciplinary Guidelines. Our plan includes a clear outline of how we handle disciplinary action. And because we work with so many government entities, such as Medicare and Medicaid, we conduct monthly monitoring to ensure anyone we do business with (including board members, doctors, subcontractors and vendors) are in good standing with the state and federal government.
- Response to Detected Deficiencies: Investigation & Corrective Action. We have a written and clear process in place to ensure timely, fair and objective response to any allegation or inquiry.
You may be thinking your organization isn’t large enough to have a compliance plan, or that you don’t have the time or resources to put one in place. I can tell you from experience that you can’t afford not to have a compliance plan. It’s given me a sense of freedom and security that we’re doing everything we can to protect ourselves, our clients and our stakeholders from fraud, abuse and waste.
As President and CEO, Tauhric Brown uses his strategic vision and experience in the elderly and disability service industry to expand CICOA services and collaborative partnerships to better meet the needs of the vulnerable populations we serve. Before joining CICOA, Brown served as the chief operating officer for Senior Services, Inc. in Kalamazoo, Mich. His career started in the U.S. Army, and then he became a successful owner/operator for a multi-carrier wireless retail company. Inspired by his family and upbringing, he made the switch to the nonprofit world to fulfill his dream of improving the lives of others.