Whitepaper

How to Meet the Challenge of Evidencing Compliance Program Effectiveness

Richard P. Kusserow | November 2025

The DOJ and OIG have been direct: a compliance program that exists on paper but can’t demonstrate effectiveness is no longer sufficient. Regulators expect independent evaluation, and they’re looking for evidence of continuous improvement, not a one-time checkmark.

The challenge for most compliance officers isn’t knowing that an evaluation is needed; it’s knowing which type of evaluation to use and why.

This whitepaper clarifies the distinctions between the three most common evaluation methods: Compliance Program Effectiveness Evaluation, Gap Analysis, and Compliance Knowledge Survey. It explains what each one actually involves, what it produces, and when it’s the right fit for your program. It also addresses a critical, frequently overlooked point: internal evaluations don’t carry the same credibility with Boards and enforcement agencies that independent ones do. You’ll explore:

  • When a Compliance Knowledge Survey adds value and how to benchmark results
  • How to match the right evaluation method to your program’s maturity
  • Why independent evaluators produce more defensible findings