Measuring and monitoring your program is the only way to know if your program is truly effective. Effectiveness measurements can come from a variety of sources. In fact, using as many sources as possible is the most accurate way to get a "grade" for your program. Use the following chart as a list of where to go internally and externally to find measurements and benchmarks to improve your program.
The Importance of Benchmarking
Benchmarking is an important part of the assessment process. Benchmarks can be used to justify your budget or other resource requests, to create a prioritized list of improvement opportunities and to inform the timeline for incorporating those improvements.
Most importantly, benchmarking helps you understand whether your program is within the norms for your company’s size and industry—and where the program as a whole (or individual elements) may land on the continuum from substandard to best practice. In addition to using benchmarking to measure your program against peers, it is a critical step in designing your program for effectiveness that can withstand the scrutiny of external, governmental or regulatory parties.
An Approach to Benchmarking as Part of Your Assessment Process
» Determine the standards/guidelines on which your program is built. Are you using the U.S. Sentencing Guidelines framework? Or the model provided by ISO? Are there industry regulatory standards that apply to your business such as the OIG guidance for healthcare companies?
» Identify your program’s operating goal or the goal for each program component. For example, do you want your training and audit elements to be best practices and all other elements more aligned with common, effective practices?
» Select a program element or process to benchmark
» Identify the key structure, performance and effectiveness metrics
» Choose target organizations of desired size/industry to benchmark
» Collect and analyze data from target entities and published reports/surveys
» Identify opportunities for improvement based on your operating goal(s)
Ongoing Monitoring
The Guidelines require that organizations “take reasonable steps – to ensure that the organization’s compliance and ethics program is followed, including monitoring and auditing to detect criminal conduct.”2 The Guidelines also provide that organizations should evaluate periodically the effectiveness of the ethics and compliance program. This requirement is in addition to auditing and monitoring for violations. Here the audits are of the program processes (e.g., whether the Code is distributed or whether training takes place as required and so forth). As with every assessment, a key step is evaluating the effectiveness of your assessment process to ensure your program is having the desired impact on the culture at your organization.
