Kusserow on Compliance: Compliance document management

Controlling and managing compliance-related policies and procedures are among the most challenging areas for compliance officers and are a subject of great confusion. Kash Chopra, MBA and JD, works in assisting Compliance Officers with compliance related problems and has found that most organizations go about development of compliance policies in a haphazard and ad hoc manner that exposes them to a great deal of potential liability. She has frequently encountered organizations that do not properly keep track of policies with the result of overlapping or duplicate policies on the same subject that could create significant liability. The failure to keep track of rescinded or revised policies is another common problem with potential liability consequences. For Compliance Officers addressing this issue, she notes that policy management refers to all stages of document life cycle and is critical to an effective compliance program. This includes:

  1. Controlling all compliance-related documents
  2. Standardizing document form/format
  3. Establishing a need for a new document
  4. Prompting when action is needed
  5. Managing work flow in creation of new/revised documents
  6. Tracking when documents should be reviewed for updating
  7. Maintaining an archive of retired documents and policies
  8. Storing and managing all compliance-department documents
  9. Ensuring document access controls and security
  10. Establishing hyperlinks to related regulators and authorities
  11. Facilitating distribution to employees, vendors, and consultants
  12. Documenting certifications and attestations

For more information on this subject, contact KChopra@strategicm.com or (703) 535-1413

Richard P. Kusserow served as DHHS Inspector General for 11 years. He currently is CEO of Strategic Management Services, LLC (SM), a firm that has assisted more than 3,000 organizations and entities with compliance related matters. The SM sister company, CRC, provides a wide range of compliance tools including sanction-screening.

Connect with Richard Kusserow on Google+ or LinkedIn.

Subscribe to the Kusserow on Compliance Newsletter

Copyright © 2018 Strategic Management Services, LLC. Published with permission.