Response #1 to the articles
In this exercise, we are assigned the task of identifying the long-run effect of the Organizational Sentencing Guidelines on our organizations. These guidelines have provided the foundation for the development of our ethics program and have provided us the generally accepted guidelines for determining whether these programs are effective. As such, they have had, and will continue to have, significant effect on my organization.
One of the most significant benefits of an ethics program is the trust that can be its’ result. In our organization, like others, we are interested in the trust of our employees, our customers, our suppliers and the public. These elements are essential to organizational success and can be the result of an effective ethics program designed after the requirements of the guidelines. The guidelines help us achieve that trust in a number of ways; it allows us to set forth our values, assigns a high-level person to oversee compliance, communicates the program, requires us to monitor the program, to respond promptly to allegations and consistently discipline employee violators. If we as an organization are successful in meeting these steps, and even more importantly, communicating our actions, then we will develop the trust of the groups noted above.
A question that I am often asked by my site executive is how is our ethical health? When I was first posed this question, I was not immediately sure how to respond. My executive, like most, wants facts, not just my opinion. While I often use metrics from our program to determine the answer to that question in part, I am beginning to understand that the answer to that question is more complete when viewed in conjunction with the steps outlined in the guidelines. If we are doing those things promulgated in the guidelines, we are well on the way to being able to answer the critical question, how is our ethical health.
Response #2 to the articles
These guidelines have already had a tremendous change on my organization. I have been with my organization for just over 3 years now and represent the organization’s first ethics and compliance officer. My program is designed based on ethics as the foundation and the requirements of the sentencing guidelines. As a matter of fact, should you have a meal in our main hospital’s cafeteria, and you look at one of the information kiosks present, you will see a large poster with the elements of our compliance program based on the guidelines.
One of the hardest things in a compliance program (my opinion) is to determine whether it is an “effective” program. As stated in one of the articles, there are several groups working on this. I have provided input into the project the Health Care Compliance Association, Pricewaterhouse Coopers and UCLA have been working on for a while now. I look at success of my program as being synonymous with the long-term effect on my organization. The fact that employees, board members and physicians at all levels of the organization stop me in the halls, cafeteria, set up meetings and even stop me when they see me in the community to talk, seek guidance or bring an issue to the table, tells me that the program has made an impact in the way we work and think.
I, of course, cannot say that many of the issues I have and continue to address would not have been raised anyway, but we, through the sentencing guidelines recommendations, have a formal process to ensure we are using “best efforts” to be compliant with the myriad of difficult to comprehend laws, rules and regulations that impact healthcare today.