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Why Evaluate Your Compliance Program?

 
(1) The law makes specific reference to program adequacy and program evaluation.
(2) Quality evaluation should produce information that may be used as evidence for program effectiveness.
(3) Quality evaluation will confidentially help to identify a weakness in compliance, allowing the organization to respond appropriately. Organizations are expected to identify and then immediately fix any actual or potential noncompliance.
 
(4) Quality evaluation will help determine whether an act of noncompliance is random or systematic. Systematic noncompliance involves multiple wrongful acts that are associated with the same circumstances.
(5) Proactive compliance evaluation efforts will demonstrate that management does not act with willful ignorance about behaviors in the organization.
(6) Managerial focus on compliance effectiveness will increase employees' positive perceptions about compliance, thereby making the employees' compliance efforts more effectual. Organizations that do not take compliance programming matters seriously may be tacitly contributing to an organizational culture of carelessness.
(7) Each organization requires individualized compliance evaluation methodologies.
(8) Organizations that have not periodically assessed the effectiveness of their compliance programming may be subject to greater culpability for compliance violations.
   
   
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