Measure your effectiveness with employee surveys
Measure your effectiveness with employee surveys
Compliance officers everywhere face a similar challenge: how to demonstrate their programs are actually working. But unlike most other executives, there is no bottom-line measurement that can prove whether or not a program is actually working.
That fact was underscored at the recent Government-Industry Roundtable sponsored by the Health and Human Services Office of the Inspector General and last month’s General Accounting Office study on the effectiveness of compliance programs (see Compliance Hotline, May 3, page 1). Both highlighted this problem but neither one offered any easy answers.
Roy Snell, senior manager at Deloitte & Touche in New York City, says that it’s tough but not impossible to get a handle on effectiveness. "I can learn in a heartbeat whether a program is working by asking the employees of that firm two simple questions," he says. "First, I would ask them if they are aware of a companywide hotline. And if they say they are, I would ask them what the number is."
Employee surveys that formalize a range of similar questions on a companywide basis are gaining favor among compliance officers. The basic goal: to measure the consistency between the compliance standards that a provider establishes and the real-world familiarity that a company’s employees have with these standards as well as the protocols designed to prevent fraud and abuse.
For example, a typical survey might ask employees if they believe a commitment to compliance has been clearly communicated to all employees and whether or not they feel comfortable reporting misconduct. The survey might also ask employees what types of violation they might have suspected in a given situation and how they might have responded.
While employee surveys can be a useful tool, several compliance experts who have tested this method warn they are not a panacea. Employee surveys vary greatly and some are far more sophisticated than others, says Joe Murphy, executive vice president at Compliance Systems Legal Group in Haddonfield, NJ. "They do have a purpose because they provide a sense of how people perceive different situations, but they do not tell you how effective your program is as a self-policing mechanism," says Murphy. "Moreover, a survey won’t reveal if one person is ripping you off to the tune of $100 million.
Murphy also warns that, although employee surveys can be very useful, they can also be misused and misinterpreted. "If employees guess that one answer is going to be more attractive than another they will almost always select the right answer," says Murphy.
Because of the time and resources required to develop and administer employee surveys, a growing number of hospitals and other health care providers are turning to third-party programs to help accomplish these tasks. Jeff Marr, president of Walker Information, a global research firm headquartered in Indianapolis reports that this year his company will administer employee surveys to roughly 20 hospitals and health systems.
Marr explains that providers are turning to standardized surveys developed by a third party largely because they are far more cost-effective than individualized surveys. In addition, standardized surveys let providers benchmark against national study data that have used most, if not all, of the same questions.
Marr says his firm helps providers determine the scope of the survey they require, and he reports on average a 50% response rate for self-administered surveys. Based on these data, his firm runs two sets of tabulations. The first is an executive survey that graphs key questions and measures the response rate against national data for similar health care providers. The second is a far more detailed breakout that includes question-by-question results for each facet of the organization.
According to Marr, providers use these data to identify their strengths and weaknesses, allocate training resources, and investigate emerging problems. This also lets providers set a benchmark to start measuring the impact of their compliance program in terms of awareness and problem-handling.
Mark Koepke, director of government compliance at Blue Cross and Blue Shield of North Carolina, says his organization has been using this method for over a year now. "We realized very early on that we needed to put a stake in the ground and see where we were in terms of compliance," he says.
Koepke’s organization began by administering a two-page survey to each of its 2,800 employees. "That gave us a baseline of how we were doing in terms of compliance primarily in terms of our code of conduct which had been in place since 1994," he says. "Basically, we were trying to determine how people handled ethical dilemmas and how aware they were of the code of conduct as a resource to draw on for business-related ethical decisions."
Koepke says his organization then fashioned a compliance program around that data. "We were able to identify our soft spots and target our training based on the results of our surveys." Koepke was also looking for any increase in the percentage of observed code violations being reported through the organization’s hotline or human resources department. "I’m not sure if we will do a survey every year," he adds, "but we will certainly do one at least every other year."
Murphy points out that while employee surveys are presently the most widely used survey instrument being employed, some providers are also experimenting with other qualitative measures, such as focus groups. "The most important point is that none of these programs can remain static," Murphy concludes, "because the methods people use to scam the system are always changing."
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