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One more thing before you go... Exit interviews as a compliance tool

Posted by Margaret Scavotto, JD, CHC on 10/14/14 8:00 AM

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The Society of Corporate Compliance & Ethics, and the Health Care Compliance Association recently issued a joint survey: Exit Interviews and the Compliance and Ethics Department (the Survey).The Survey evaluated companies' use of exit interviews as a tool to measure an organization's culture and detect non-compliance.

The Survey found that while 82% of organizations use exit interviews, only 52% use them routinely. While the Survey did not evaluate the effectiveness of these exit interviews, MPA put together a list of pros and cons:


PROs - Exit Interviews as a Compliance Tool

  • Put a lid on whistle blowing. If a departing employee is disgruntled, you might have a shot at preventing him or her for blowing the whistle. Many whistleblowers turn to the government when they feel their employer is not serious about addressing a compliance concern, such as over-billing. The exit interview is an additional opportunity to identify non-compliance, and show your employees you are serious about addressing it.
  • Improve your processes. Even if an exit interview fails to reveal illegal fraud, it can still teach you something. Why is this person leaving? Were they poorly managed? Do you have a problematic supervisor on your hands? Was this employee a poor fit from the start--and if so, how can HR prevent a repeat hire?
  • They might level with you. After all, what does a departing employee have to lose by being honest?

CONs - Exit Interviews as a Compliance Tool

  • Time and money. The Survey reported that 13% of employers don't use exit interviews due to a "lack of resources." Exit interviews take time to organize, time to conduct, and time to report and evaluate. Time equals money, of course. Health care providers looking to fine-tune their compliance programs, and providers concerned they might have a compliance culture problem, could easily find it is worth the effort. Providers just beginning their compliance efforts, however, might decide that a triage of resources puts exit interviews on the back burner for now.
  • Uncertain value. The Survey found that 17% of respondents did not conduct exit interviews because they are "perceived to provide little value." The only way to find out how much value exit interviews add to your compliance program is to try conducting exit interviews. MPA believes it's worth a shot.
  • Anonymity is virtually impossible. Exit interviews are typically conducted in person, making anonymity impossible. Some providers conduct exit interviews via anonymous survey--making anonymity equally problematic, unless mass quantities of employees leave your organization on a regular basis. This lack of anonymity undercuts the value of employee responses.
  • They might not level with you. An employee on the way out the door might not see the point in being honest with you.

Make the most of it

Depending on your other compliance priorities and available resources, it may be well worth your while to give exit interviews a chance. If you do, be sure to make the most of it: The Survey reported that only 38% of providers who use exit interviews report the results to the compliance department. If you do gather this data, do yourself a favor and involve the compliance department/officer so this information can be tracked and studied for process improvements--and to identify potential non-compliance.

Finally, don't stop with exit interviews. They can be a useful tool in improving your organization's culture of compliance, and should be seriously considered. But they are not the only tool you have available. Don't wait for an employee to leave before you measure your compliance culture. Anonymous employee surveys can be used to evaluate your employees' perceptions of your compliance program on an annual basisCompliance Training  & Culture Tool Kit


Topics: Whistleblowers

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