In an ethics crisis, it is not enough to know what happened; you need to know why it happened. Most organizations can survive a single ethics crisis. But if the same conduct is repeated, even if by different individuals, this will fix the negative impression of the organization in cement. Organizations tend to want to keep changes to a minimum, as big changes seem to be a further admission of culpability. But you need to be sure that you have changed personnel and systems sufficiently that the same conduct does not recur.
Publications of Interest
March 22, 2015 — MarkI have found two recent publications that may be of interest. The first is on ethics and business success and pretty much follows the discussion here. It can be read at http://tinyurl.com/q55rash. The second is on a new topic which is how to build ethics into a start-up. This one is by Martin Zwilling and can be read at http://tinyurl.com/nb6jdug. Enjoy and comments are always welcome.
In an Ethics Crisis Assume the Government Will Be Involved
March 7, 2015 — MarkWhen an organization does something viewed as unethical, the public wants someone to do something about it. And that someone is likely to be “the government.” Most organizations are open to some level of government oversight. When the government comes knocking, you can expect to hand over most everything you know about the crisis. Why? Even though some of the material may be covered by legal privilege, the government will find you uncooperative if you “hide” information. Your reasoning about the crisis needs be premised on when the government finds out rather than whether the government finds out.
ethicswhisperer.com- 4 Myths about Compliance Program Assessment February 16, 2015The first myth about compliance program assessment is that it is an optional part of an effective compliance program. The same sentence in the Sentencing Guidelines that mandates a hotline also mandates compliance program assessment. And, even if program assessment were not mandatory, it is would be incumbent on your organization to undertake assessment. Org […]Mark Pastin
- Compliance Headhunters September 21, 2014We are contacted by headhunters because we know a lot of compliance officers and we know whether they are available. However, it is extremely difficult to help these folks as they often have no idea what a compliance officer does. They are generally working from a job description written by someone in HR who also has little idea what a compliance officer doe […]Mark Pastin
- Keeping up September 8, 2014While there will continue to be new posts on longer topics on ethicswhisperer.com, I also encourage you to follow markpastin.com, which is updated more frequently and focuses on issues of the day. Of course, your comments are always welcome on any of our sites.Mark Pastin
- The Next Hot Word in Compliance July 13, 2014Hear yea! Hear yea! Hear yea! The next hot word in compliance will be UPQUALING. This, of course, is on the model of UPCODING. Healthcare reform is a gamble on the idea that incentives can be given to lower the cost of care while maintaining or improving its quality. This has been tried before with limited success under the rubrics "managed care," […]Mark Pastin
- A Big Compliance Mistake February 9, 2014Secretary of the US Department of Health and Human Services Kathleen Sibelius recently announced that health plans offered through exchanges will not be considered Federal health plans – and many breathed a huge sigh of relief. Not so easy.What the Secretary's announcement means is that plans purchased through exchanges will not be administratively unde […]Mark Pastin
- 4 Myths about Compliance Program Assessment February 16, 2015
Mark Pastin 