The Culture of Compliance

Corporate culture begins with the tone set by leaders and disseminates throughout the organization. It is demonstrated in all aspects of facility operations, including QA meetings, nurses' rounds, and in the daily practices of CNAs. It is evidenced by such characteristics as employee punctuality, work ethic, and responsiveness to management and policies. Encouraging active staff participation enforces values, such as cooperation and teamwork. 

Developing a sense of employee ownership in the facility's practices works hand in hand with the facility's Compliance Program, which aims to facilitate staff members' abilities to voice concerns and address compliance violations. Through the implementation of the Compliance Program, stakeholders, such as managers, staff members, residents, and residents' families, participate in quality improvement by identifying concerns before they escalate into larger and more expensive challenges. This way, the facility minimizes its risk of lawsuits and penalties related to compliance violations. A culture of compliance is essential to make the Compliance Program effective and successful.

Fostering a Culture of Compliance

An employee's compliance performance can be measured by the extent to which they follow the code of conduct and policies, assist with compliance audits, and report violations. Active alignment of incentive systems encourages a culture of employee compliance. Three ways to incorporate compliant behaviors into incentive systems include: adding compliance to employee evaluations, considering employees’ compliance performance during promotions, and aligning reward systems with compliant practices.

Misaligned incentive systems can encourage unethical or illegal conduct. For example, exchanging money and gifts for the referral of healthcare services may seem like common practice for marketing a healthcare business.  However, state and federal laws have specifically indicated that it is illegal to give or receive remuneration for the referral of healthcare goods or services that are paid for in whole, or in part, by federal funds.  Therefore, skilled nursing facilities that receive Medicare or Medicaid money must actively adjust their incentive systems to ensure that illegal practices are discouraged and that compliant practices are rewarded. 


Ways to Promote Compliance at the Facility

Employee Evaluations

Include compliance performance in employee evaluations to measure employees' adherence to the facility's code of conduct in their job functions. Inclusion in employee assessments can be simply adding the following metric in performance evaluations:

Has this employee supported the code of conduct and acted ethically in work decisions?

__Yes __No

A deeper evaluation may consider the degree to which the employee does the following:

__Uses the code of conduct and encourages subordinates to do the same

__Attends appropriate compliance training, and makes sure subordinates get appropriate training and know the rules that apply for their jobs

__Is willing to challenge questionable conduct or proposals

Evaluations can address performance related to the Compliance Program in general, or the program as it deals with specific risk areas, such as HIPAA, quality of care, medication management, or environmental safety.


Consider employees' compliance performance in determining their eligibility for promotion. This not only serves to meet legal standards, but also sends a strong message to employees at all levels that advancement requires serious attention to doing the right thing and setting a positive example. Communicating that compliance is a part of the selection criteria for promotion fosters the idea these values are an essential part of job performance.


Integrate compliance into facility rewards by considering compliance performance when choosing Employee of the Month, or providing a compliance award at the annual holiday party. Recognition of good work can also be as simple as managers providing visible praise when employees demonstrate compliant behavior. For instance, when a Charge Nurse reviews resident records and notices a marked improvement in CNA documentation legibility and clarity, praise should be delivered to encourage this type of compliant behavior. Identify, reward, and communicate good examples of compliance and shape a culture of compliance at your facility.