Approximately two-thirds (68 percent) of healthcare organizations maintain an internal committee dedicated to compliance and ethics, according to the Compliance and Ethics Program Environment Report by the New York Stock Exchange Governance Services and the Society of Corporate Compliance and Ethics.
NYSE Governance Services and the SCCE analyzed the responses from nearly 250 healthcare chief compliance officers or persons responsible for the day-to-day operations of the ethics and compliance programs of healthcare organizations. The professionals were surveyed from June to August. Highlights from the surveys include the following.
- More than half (56 percent) of the organizations surveyed give the person with overall responsibility for the compliance and ethics program the title of chief compliance and/or ethics officer or compliance and/or ethics officer.
- Forty-one percent of internal compliance and ethics committees are chaired by the chief compliance and/or ethics officer who typically reports findings and recommendations to an audit committee.
- Seventy-two percent of internal compliance and ethics committees have cross-functional representation.
- Seventy-one percent of the committees have a documented charter.
- Almost all (93 percent) have at least quarterly regularly scheduled meetings.
- Roughly two-thirds of respondents (67 percent) indicate that the same person is assigned both overall and day-to-day operational responsibility for the compliance program.
- Thirty-eight percent of those with overall program responsibility report directly to the CEO, while 19 percent report to the board of directors.
- While 19 percent of those with overall responsibility for the program report directly to the board, the overwhelming majority, 79 percent, have a dotted reporting line to the board.
- When the person with day-to-day responsibility does not have overall responsibility for the program, most (31 percent) report to the chief ethics and/or compliance officer, followed by the general counsel or chief legal officer (21 percent).