Imposition of sanctions for violations of compliance policies is a requirement of OIG and HIPAA regulations, but reinforcement of positive contributions to a compliance program are not addressed. In its most recent General Compliance Program Guidance, the Office of Inspector General includes some suggestions for encouraging participation in an organization’s compliance program.
Although the participation and adherence to policies are an expected part of a workforce member’s duties, employers may wish to establish some incentives for the workforce member who goes above and beyond what is expected. In addition, if there are areas of workforce member participation or compliance that you would like to see improve, you might consider incentivizing them specifically.
The OIG guidance lists the following behaviors that organizations may want to incentivize:
- the achievement of compliance goals that are specific to a department or a specific position description;
- achievements that reduce compliance risk (e.g., a team that develops a process that reduces compliance risk or enhances compliant outcomes, or an individual who suggests a method of attaining a strategic goal with less risk); or
- performance of compliance activities outside of the individual’s job description (e.g., mentoring of colleagues in compliant performance or performing as a compliance representative within their department).
Positive contributions should always be documented in workforce members’ employment records so that they may be recognized during regular performance reviews. Excellent compliance performance or significant contributions to the compliance program could be the basis for additional compensation, recognition, or other smaller forms of encouragement. The OIG states that “Through the thoughtful and deliberate use of incentives, an entity may reduce its compliance risk, enhance adherence to the entity’s compliance programs, and develop a positive association with the entity’s compliance culture.”
