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Don’t Wait for the Next Compliance Shoe to Drop

A guest who checked into a motel one night was warned to be quiet because the guest in the room next to his was a light sleeper. As he dressed for bed, he dropped one shoe and sure enough, awakened the other guest. He managed to get the other shoe off in silence, and got into bed. An hour later, he heard a pounding on the wall and a shout: “When are you going to drop the other shoe?”

If you are like me, you might be in a semi-constant state of anxiety wondering when the next compliance shoe is going to drop and where it will come from. It’s bound to happen sometime, right?

One area that I’m always fearful about hearing the other shoe drop is the compliance monitoring and/or audit program. After all, it is one of the critical cornerstones of a good compliance management system. Is it comprehensive enough? Can you make it easier and still do what is required? Will your examiner think it’s sufficient?

So, let’s say that you have a monitoring program in place and you think it’s probably working pretty well. But, could it be better? Chances are it could. Maybe it’s time to think about what you can do NOW to beef up your monitoring program. Here are some ideas to get you started.

Tame the Beast
The idea of ALL those regulations you should be monitoring can be overwhelming! But, as the old saying goes, you can eat an elephant one bite at a time. Break down all the monitoring you want to accomplish this year and get it on a calendar, spreading them out over the entire year. By scheduling even just one review a month, you’ve got 12 areas covered without breaking a sweat.

Keep it Simple
One of the best ways to simplify the monitoring process is to spend just a little bit of time creating a consistent approach. Use standardized checklists so you don’t have to remember what you are trying to look at and accomplish. And, if you can create a checklist where you can also record the monitoring results, you’ve managed to get a double use from one document, thus saving time. Use a standard format for logging findings and preparing a report of results. Not only will this make things easier for you, the recipients of your monitoring results will appreciate your consistent approach to a sometimes unpleasant task.

Share the Secrets
Sometimes when the results of monitoring are shared or a report is provided, the recipient can feel that there is some secret mathematical equation being used to rate risk or findings, or even worse, that your findings on based on whether you’ve had your coffee for the day. It saves a lot of headaches down the road and keeps the troops happier if you provide explanations of what you look for and how you determine the severity of what you find. A simple definition of terms used can be provided to recipients. For example, a finding rated “Low” might mean ‘Darn good job, guys! Just a little glitch, but nothing a little training won’t help.” Or, Moderate might mean “Hmmmm, I’m a little worried about that. How about you beef up your procedures?” And, High might mean “I’m not saying we are going to shut our doors, but you really need to spend some time on this one.” By sharing this information, it helps everyone understand how the process works and provides consistency to the monitoring program.

Watch the News
Sometimes we spend so much time creating the perfect monitoring program we forget that it isn’t a one-and-done proposition. It is critical that the program and checklists be kept up to date. As we know, things are always changing and that means our monitoring program needs to change as well. When a new or revised regulation comes out, pull out your monitoring checklist and make those changes. Don’t wait or put it off to “when I have time”. That never happens, as we all know. Make updating those checklists part of the rule revision process of things you need to do when those final rules are published. This will actually save you time down the road.

So, these are some ideas to make your monitoring program more efficient as well as providing more value. While you may not be able to avoid the other compliance shoe dropping, you just might be in a better position to avoid the anxiety of waiting for it to happen.

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