Creating a Culture of Compliance

Creating a Culture of Compliance

Parallon’s compliance program is grounded in the outstanding legacy of our Ethics and Compliance Program.  As such, our compliance standards and Code of Conduct were developed using our provider heritage and a keen understanding of industry regulations that apply universally.

“Our clients and their patients need to know that we take compliance seriously, and that it is a priority to do the right thing all the time,” says Mary Jette, VP of Compliance and Ethics and Compliance Officer at Parallon.

The first and most fundamental step to create and sustain a culture of compliance is to have a purpose and values statement that resonates with colleagues. For Parallon, this means that our values of integrity, unity, service, learning, accountability and respect underpin everything we do.  And our purpose of serving and enabling those who care for and improve human life in their communities, serves as a solid foundation of the why behind what we do. Our Code of Conduct is founded on this purpose and values and serves as the foundational guidance for colleagues regarding workplace conduct. The elements of a successful ethics and compliance program which are necessary for a good culture of compliance include:

  1. Setting standards.  Grounded in our provider legacy, Parallon created a set of policies and procedures that govern all aspects of compliance and operational processes.  Additional guidance, compliance alerts and support from corporate and local Ethics and Compliance Officers help to further clarify and support these standards.
  2. Communicating the standards.  Mandatory training for all employees serves to encourage and re-enforce key elements of an effective compliance program. Training on the Code of Conduct, privacy, billing and other areas of compliance risk are fundamental to ensuring a compliant culture. 

Referring to the Code of Conduct Training, Jette says, “The annual code of conduct training brings to life the topics covered in the code of conduct and related policies. By using realistic scenarios, our colleagues have an opportunity to see how our values can be lived out in our daily work.”

Beyond the code of conduct training, Jette underscores the importance of routine communication and education to instill those standards in employees.

  1. Provide a mechanism of reporting potential issues or concerns.  Even organizations that prioritize a culture of compliance can experience potential instances of non-compliance. When this happens, it is important to have a process in place to allow employees to report concerns without fear of retribution.  Implementing an independent ethics line where concerns can be reported anonymously if desired is an important step in establishing this process.

“Our employees are the eyes and ears of our compliance program,” says Paul Daniels, AVP of Compliance and Privacy Officer for Parallon. “We emphasize the importance of sharing what they are aware of, so we can address concerns at the earliest point possible.’” It’s important to us that employees feel comfortable raising issues.”Part of ensuring that comfort is investigating any concern in a pragmatic and unbiased way.

“At the end of the investigation, we may not have found any wrongdoing, but for the employee who raised the concern, the process helps to establish trust and further promotes our culture of compliance,” Daniels says.

  1. Monitoring and auditing.  Having a Code of Conduct, policies and procedures and a great training program is wonderful, but without a process to measure, audit and monitor there is no way of knowing if the program is actually effective.  Parallon has developed a set of compliance functional standards that are monitored by local Ethics and Compliance Officers.  As another layer of monitoring, Parallon’s Internal Audit department routinely audits these standards as well as a myriad of other compliance risk areas.
  2. Maintaining an organizational structure that supports the furtherance of the program. Because of the ever-changing nature of the regulatory environment, Jette recommends organizations have a team dedicated to compliance, including personnel who are focused on monitoring regulations. This also includes having committees, local ethics and compliance officers and responsible executives who are the subject matter experts in their areas of compliance risk.

While there may be some who are seen as leading the program, such as the ethics and compliance officer, it is important for everyone in an organization to have a commitment to compliance “Compliance is not what we do, it’s who we are,” says Daniels. “In order to be able to say that, everyone has to have that mindset and culture ingrained in them.”