No-Nonsense Advice for Tackling Internal Enforcement Discipline

Disciplinary action gives everyone an uneasy feeling. It’s one of those things that nobody likes to talk about. Nobody likes to be the person charged with disciplining their co-workers and absolutely nobody likes to be disciplined. But whether we like it or not, it’s one of the 7 elements of an effective compliance program. So we have to get comfortable with it and learn how to do it and do it well no matter what.

Why and how should we implement disciplinary action in our compliance programs? The “why” is somewhat straightforward: It’s one of the required elements of an effective compliance program. But the how? Well, that’s where things get interesting.

In their compliance guidance, the OIG recommends making compliance an element of an employee’s performance evaluation. When it comes to training and education, the OIG recommends that attendance and participation in training programs be made a condition of continued employment and that failure to comply with training requirements should result in disciplinary action, including possible termination, when such failure is serious.

Download my free eBrief, How to Properly Discipline Acts of Non-Compliance, to learn how to incorporate disciplinary action into your compliance program, use discipline to change employee behavior, and roll compliance into performance evaluations.

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