Compliance Program Effectiveness Assessment

Each Assessment generally consists of five phases:

Phase 1 – DOCUMENT REQUEST AND REVIEW

Campbell Legal will request the compilation and uploading of various documents pertaining to your organization’s structure, compliance program, effectiveness, board oversight, and the like. Campbell Legal consultants will review the documents and become familiar with your organization’s compliance program prior to on-site interviews. This will enable Campbell Legal consultants to utilize on-site time most effectively. During the request and review period, it is requested the organization does not formulate any documents for the purpose of the assessment; we simply will review what is in place at the commencement of the assessment.

Phase 2 – ON-SITE KICKOFF AND INTERVIEWS

On-site interview time is determined by the size of the organization and scale of number of interviewees. This part of the process generally includes high-level interviews. Various positions (when applicable) may include CEO, COO, CFO, CCO, COs, CNO, General Counsel, Administrator(s), Board Chair, and other key personnel. Interviews are conducted individually and confidentially.

Phase 3 – STAFF COMPLIANCE ACCESSIBILITY SURVEY

While the input of high-level personnel is imperative to the successful evaluation of the compliance program, equally important is the general staff’s view of your organization’s compliance program. Campbell Legal will work with your Information Technology Professional to receive a database of employees. Campbell Legal will then utilize a random sampling program (RAT-STATS) to select the survey sampling, and the electronic survey will be distributed accordingly. The findings from this survey will beb included in the final assessment, and your organization’s contact will have the ability to modify survey questions before dissemination to staff.

Phase 4 – FINDINGS AND RECOMMENDATIONS WRITTEN REPORT

Upon completing Phases 1 through 3, Campbell Legal will compile its findings analyzed under the Federal Guidelines with an emphasis on program effectiveness. If the organization requests the program be analyzed under state guidelines, this must be brought to the attention of Campbell Legal prior to Phase 1, and additional counsel with legal licensure within the state of operation will be retained for assistance on state recommendations.

Phase 5 – PRESENTATION TO THE BOARD

Organizational leadership will have the opportunity to view a report draft to ensure accuracy. Thereafter, a Final Report and presentation will be made to the Board of the organization.