To assess compliance, look beyond the rules


I recently moderated at an interactive discussion on evaluating compliance programs at Deloitte’s Cross-Industry Compliance Leadership Summit, where compliance executives from a variety of industries compared notes on the methodologies and metrics they use to measure their efforts.

“If my compliance program prevents, that’s great,” one attendee stated. “If it fails to prevent but detects, that’s okay too. Where it ultimately fails is if there’s management inaction.”

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Building relationships with regulatory agencies


Posted by Peter Reynolds on February 19, 2015.

When a number of C-level compliance officers joined me recently for a discussion about their relationships with regulatory agencies, it was more than a meeting, it was an education. That’s because we had two regulators with us, and the give and take between them and among the other Compliance officers—the candor, and constructive input—could serve as a model for regulatory interactions all year round.

The occasion was Deloitte’s Cross-Industry Compliance Leadership Summit. Chief Compliance Officers from energy, healthcare, finance, retail, and other sectors all took part, as did Jim Sheehan from the New York State Attorney General’s office and Carlo di Florio, Chief Risk Officer of the Financial Industry Regulatory Authority (FINRA).

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In compliance data, quality rivals quantity

Energy companies eye compliance monitoring; panel advises close ties with businessPosted by Paul Campbell, Principal, Deloitte & Touche LLP and Howard Friedman, Director, Deloitte & Touche LLP

“Our best metric is still a gut feel.” That’s how one panelist summed up his company’s approach to making sure its compliance program provides the most useful feedback.

That comment was part of a panel discussion on compliance data benchmarks we facilitated on October 2, 2014 as part of Deloitte’s Dodd-Frank Compliance Leadership Academy. The participants were eager to get in front of compliance trends so they could apply the indicators today they’ll need to report on tomorrow. And while many of those indicators arise directly from the compliance function, we found it’s just as important to keep abreast of operations-related data, such as the management of physical assets.

But first, back to that “gut feel.” One theme that ran through our discussion was the need to take a broad view of what constitutes useful compliance data.

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2014 Compliance Trends Survey Report

2014 Compliance Trends Survey ReportPosted by Tom Rollauer, Executive Director, Center for Regulatory Strategies, Deloitte & Touche LLP

Deloitte and Compliance Week magazine recently released a joint survey report on key compliance trends in 2014. The annual survey, which is in its fourth year, included 209 responses representing a wide range of industries from America and around the world. Questions focused on three major issues:

  • Do compliance executives have the appropriate authority and resources to do their jobs?
  • Are compliance executives addressing the right risks?
  • Do compliance executives use the right metrics to measure progress?

This year’s survey found some level of improvement in all three areas; however, the results were a mixed bag and overall there is still a burning need for organizations to improve how they handle their compliance activities — particularly in light of today’s increasingly demanding compliance environment and the complex new requirements associated with laws such as the Dodd-Frank Act and Affordable Care Act.

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Responding to Medicare’s New Short Stay Rules

Responding to Medicare's New Short Stay RulesPosted by Kelly Sauders, Partner, Deloitte & Touche LLP

The issue of short inpatient stays is probably the biggest Medicare challenge that hospitals currently face. This issue has been an ongoing challenge for years, but until now many hospitals didn’t know how to tackle it ¬ or didn’t think they had to. That all changed on October 1, 2013, when the Centers for Medicare & Medicaid Services’ (CMS) new ‘2 midnight rule’ went into effect. Now, it’s clear that a hospital stay must include two midnights in order for associated services to be classified as inpatient. This rule change has tremendous financial and operational implications and should be addressed immediately. Hospitals that continue to ignore the problem are at significant risk of facing more and more Medicare denials. Here are five steps hospitals can consider taking to help address this risk:

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