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19Journal of Health Care Compliance — September–October 2015 19
How to Get Your Employees Talking about Compliance
and Ethics
Building A Solid Plan, Keeping It Fresh, and Measuring What Works Are All Key to Success
Jennifer Edlind and Kathleen Edmond
It is an inescapable truth that compliance happens across the business. That truth makes employee engagement around compliance and ethics crucial to
effective risk management — especially in a heavily reg-ulated industry like health care.
In the past, those charged with compliance and eth-ics oversight often chose to engage employees with static, one-way communication efforts like annual train-ing, newsletters, and occasional policy updates. But the increasing importance of compliance to the strength and sustainability of the business requires a new approach to keep compliance a meaningful and regular part of employees’ conversations. Specifi cally, success demands a comprehensive, strategic communications plan that makes compliance and ethics communications innova-tive and effective, in addition to traditional, predictable communications efforts. Compliance and ethics profes-sionals who take the time to envision and create that kind of comprehensive plan will change the perception of the importance of compliance within the organization — as well as expand and improve the who, when, and why of the compliance conversations that occur.
STEP ONE: BUILD THE PLAN
Strategy requires vision, and creating a culture where employees willingly participate in and initiate conversa-tions on compliance-related topics will not occur by hap-penstance. In many organizations, achieving this goal requires a resetting of perspectives on strategic commu-nication. That reset begins when compliance and ethics professionals understand — and embrace — the benefi ts of a three-year strategic communications plan that they own and drive throughout the business.
Implementing a three-year strategic communica-tions plan requires groundwork. First, those building
Jennifer Edlind is the Director of Compliance for University Hospitals
Health System in Northeast Ohio. She has worked in UH’s Compliance and Ethics Department since 2008 and enjoys fi nding innovative ways to
engage the UH community in conver-sations about ethical issues. She can be reached at 216/767-8226 or by email at
Kathleen Edmond, a partner with Robins Kaplan LLP, has spent the major-
ity of her legal career in corporate ethics and compliance. Ms. Edmond is probably best known for her leading-
edge communications initiatives in creating a connected, ethical culture
within the organization that supported business strategy, vendor integrity,
and customer engagement. She has won national awards for her innovative and exemplary leadership in her fi eld, and her original use of social media in furthering a transparent, ethical busi-
ness operation is groundbreaking. She can be reached at 612/349-8242 or by
email at [email protected].
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Journal of Health Care Compliance — September–October 2015
How to Get Your Employees Talking
20
the plan need to connect to strategic com-munications best practices. That means understanding an organization’s business operations and the places within the orga-nization where communications already occur. It also requires remaining mindful of current industry issues and trends, as well as specifi c company communications and overall culture. Compliance and ethics professionals will do well to connect with and engage their marketing and commu-nications colleagues to learn what com-munications have and have not worked for the business and partner together to build a compelling plan that will work for their specifi c organization.
In addition, formulating a compre-hensive strategic communications plan should include an honest assessment of compliance and ethics communications to-date. Key considerations include the age and freshness of previous communi-cation offerings and the patterns of when and how those communications have hap-pened. Plan implementers will need to consider what stories have been told in the past and whether or not those stories and other references have stayed or ever were relevant. Evaluations of prior communica-tions efforts, such as annual training, may provide insight into what the expectations are for compliance and ethics communica-tions and when those expectations have been met in the past.
Like it or not, part of the pre-work to creating a strategic communication plan includes an honest evaluation of how com-pliance and ethics communications have dealt with previous crises or changes in circumstances. Understanding how chal-lenging issues have been addressed in the past can help those building the plan con-nect to what is needed to stay fl exible and relevant as the communication plan moves from the brainstorming to the implementa-tion phase. Though not lacking in its own challenges, this groundwork allows those involved to plan for success and employee engagement.
Actually moving to creation of a plan and selection of the tactics needed to imple-ment it requires consideration of multiple factors. These include:
availability of resources;selecting the audience(s) for various communications efforts;message selection;timing the message;opportunities to maximize existing modalities; andneed to blaze new communications trails.Mapping out the answers to these ques-
tions provides the beginning framework for a plan that gets the right message to the right audience at the right time. It also allows those in charge of the plan to coordinate with their organization’s over-all communication agenda and, whenever possible, maximize existing communica-tions vehicles.
High-level needs mapping will also show the opportunities for key, “just in time” communications. Getting informa-tion to the right people at the right time maximizes the effi ciency and impact of compliance communications and can take many forms. One strategy for successful “just in time communications” would be to summarize vendor gifts and entertain-ment policies for the key employees who will represent the business at an annual industry conference where they will inter-act with many vendors. It also can mean revamping the compliance training tradi-tionally provided at new employee orien-tation to stage the compliance and ethics message so that information is provided gradually over the course of the fi rst year of employment rather than overloading new employees on their fi rst day when it is highly unlikely that they will retain all of the information they are receiving on a variety of topics.
Reviewing communications needs also will reveal where and why compliance and ethics personnel should utilize “high touch” communications efforts, such as
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Journal of Health Care Compliance — September–October 2015 21
How to Get Your Employees Talking
live, interactive training sessions with smaller groups of employees, rather than “low touch” communications efforts, such as online training programs delivered to an entire organization via a learning man-agement system. High touch communica-tions are often well-received and effective for the audience, but they are time and resource-intensive for compliance and eth-ics personnel to deliver. Low touch commu-nications are effi cient and can reach more employees across the organization but run the risk of being viewed as impersonal and, therefore, irrelevant.
There are advantages and disadvantages to each method. Building a strategic plan that incorporates an honest accounting of the most important compliance and eth-ics messages and audiences, as well as available resources, will allow compliance and ethics personnel to leverage the best of both methods and customize low touch communications to feel more personal, specifi c, and relevant.
One example of applying this meth-odology to transform communications is reviewing and transforming the content available through a compliance portal on the corporate Intranet page from a static “check the box” communication strat-egy to a relevant, ongoing resource at the employee’s desk. If your program gathers data on the types of questions, complaints, and reports received in the past, one strat-egy is to analyze that data to see what topics generate the most questions or are often misunderstood, as well as whether there are particular areas of the business that need more information to successfully implement compliance policies in their areas.
Dedicating time and effort to creating a robust library of user- and situation-specifi c FAQs can quickly guide employees toward the desired compliant and ethical choices, especially when additional resources and contact information are provided for times when the decisions are diffi cult. Other portal content can create interactive
experiences to continue engaging employ-ees and turn compliance and ethics’ inter-nal home into a reoccurring employee destination.
Whatever specifi c strategies are ulti-mately selected, to succeed the strategic communication plan should clearly iden-tify the action items needed to carry out that strategy, the party or parties respon-sible for each item, the timeframe for com-pletion, and the specifi c deliverable. The result will be a communications plan with a relevant life cycle, concrete goals, and, hopefully, measurable results.
STEP TWO: KEEP IT FRESH
After launch, those implementing the plan will need to look for ways to keep it fresh, alive, and continuously engaging through innovative communication efforts. Technology will prove to be an excellent friend in the furtherance of those efforts. Compliance and ethics professionals need to overcome any lingering hesitations about blogs and social media and learn to use those resources internally and exter-nally to connect with employees. Blogs and social media platforms can facilitate communication in real time as the need for compliance guidance emerges, as well as allow multiple employees to gain direct access to how the organization sees new and evolving rules and policies applying to specifi c situations.
Similarly, as employees get used to consuming content in multiple formats — including video — the use of short videos can jumpstart important ethics conversa-tions and address important new or unex-pected compliance and ethics issues. The more approachable, human, and, when-ever possible, humorous compliance videos can be, the better. Compliance training that incorporates short video sce-narios is particularly effective in engag-ing employees and starting conversations across the organization about whatever themes or issues are featured in the program.
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Journal of Health Care Compliance — September–October 2015
How to Get Your Employees Talking
22
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Journal of Health Care Compliance — September–October 2015 23
How to Get Your Employees Talking
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Journal of Health Care Compliance — September–October 2015
How to Get Your Employees Talking
24
Keeping the compliance and ethics message fresh means remaining open throughout the lifecycle of a strategic com-munications plan to trying something new. Whatever those efforts may turn out to be, they should serve to help building bridges from the compliance and ethics offi ce to the rest of the organization and keep breaking down outdated stereotypes about compliance as the “enforcers” of the orga-nization and the idea that compliance is solely responsible for the ethical success of the business. That may mean having com-pliance messaging turn up unexpectedly in existing communications spaces (think log-in screens) or leaving the compliance offi ce ivory tower to fi nd ways to go be with the people in the organization, especially if that presence can somehow become fun.
STEP THREE: IDENTIFY WHAT WORKS
At its best, communication connects. But fi nding out whether efforts initiated as part of a comprehensive compliance and ethics communication plan have been effective takes discipline — and courage. Collecting available data about communications is one place to begin. If an organization chooses a plan goal of heightening the visibility and content of an Intranet portal, then measur-ing employee use of that resource before and after plan efforts provides a beginning window into the effectiveness of the effort undertaken.
Measurement should not stop there though. Dig into the data to fi nd different ways to approach the problem and improve strategies. Looking at time of use, length of use, and search terms (and whatever else partners from information technology (IT) can provide guidance as meaningful) allows adjustments and refi nements of tac-tics along the way to reach or even exceed original goals.
And don’t just rely on a single measure-ment. Go back for more data, conduct formal and informal surveys, ask around.
Don’t be afraid to fail, but learn to fail fast so that if a specifi c tactic designed to fulfi ll a strategic goal does not work, you can change it to make sure the long-term goal and cru-cial employee engagement happens.
FIGURE 1: THE SAMPLE PLAN
We have provided a sample three-year com-pliance and ethics communication plan as an example of the types of projects you may wish to consider in creating your own strategic plan. The sample plan is orga-nized around the simple goal of increasing awareness of and commitment to compli-ance and ethics. The plan then details fi ve specifi c strategies, with multiple projects supporting each strategy, for achieving the goal over a three-year period. Each project has one or more responsible parties, which is typically an employee within the com-pliance and ethics function but also may include a strategic partner from another area of the business. Importantly, each project also has a deadline for completion and a map to indicate where the project fi ts within the three-year lifespan of the overall communications plan. Finally, each project includes a specifi c deliverable to measure project completion and aid in evaluating the project’s effectiveness.
CONCLUSION
The importance of compliance and ethics organization wide just keeps expanding, and the key role compliance and ethics professionals play has never been greater. Strategic, innovative, effective communica-tions play a critical role in helping those professionals master the increased respon-sibilities and content under their watch. Building a solid plan, keeping it fresh, and then measuring what works and respond-ing to what doesn’t offers an actionable method for getting critical compliance information to employees and keeping them talking about the compliance issues that matter most.
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Reprinted from Journal of Health Care Compliance, Volume 17, Number 5, September-October 2015, pages 19–24, with permission from CCH and Wolters Kluwer.
For permission to reprint, e-mail [email protected].
