Guidelines Followed in Developing and Testing Compliance Surveys

Richard P. Kusserow | July 2013

The following guidelines have been followed by the Compliance Resource Center (CRC) for designing and validating their survey tools.

Subject Matter Experts (SMEs). CRC working with its partner Strategic Management Services (SMS) has developed a team of compliance experts with at least 10-15 years experience in providing compliance advisory services to clients.

Collection of Compliance Information Needed for a Survey. SMS collected a very broad-based set of date about compliance programs that could be used in measuring program effectiveness. The task was focused on practical, real life factors derived from working with over 1,000 organizations and entities in the design, management and measuring effectiveness of compliance programs.

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Defining Behaviors and Knowledge Necessary to Measure Compliance Program Effectiveness. The SMEs determined those factors and observed behaviors critical to an effective compliance program. The survey designs included only the most important competencies to be measured by the survey.

Survey Instruments Were Validated by Repeated Testing.  The SMEs solicited input from other qualified professionals and experts outside of SMS and CRC, which lent to revisions of the tools, in order to validate results.

Surveys Were Pilot Tested. Surveys were administered to sample groups with feedback about the survey from the participants in various health care sectors to organizations of varying size and complexity.  Based upon the results of focus group meeting and interviews, the survey instruments underwent revision and improvement.

Since 1993, Periodical Survey Review and Testing. Over time, the requirements and expectations for compliance program have changed.  It was found that the culture survey remained a constant but the expectations for employee knowledge about the compliance program evolved over the years, necessitating a new instrument to be developed following the same process as for the original survey instruments.  

About the Author

Richard P. Kusserow established Strategic Management Services, LLC, after retiring from being the DHHS Inspector General, and has assisted over 3,000 health care organizations and entities in developing, implementing and assessing compliance programs.