Comprehensive Compliance Programs
Internal controls are absolutely necessary for a company. They function as the procedures or systems that a company uses to maintain the integrity, accountability, and efficiency of the company’s financial reporting. Internal controls also help prevent fraud. Due to the major scandals that the financial industry has seen in recent years because of fraudulent behaviour, multiple standards and guidelines have been enacted to combat these issues. One of these guidelines is titled the Sentencing Guidelines. The Sentencing Guidelines have established what is called an ethics and compliance program. This program “seeks to prevent, detect, and respond to fraud and misconduct” (Girgenti & Ben-Chorin, 2021, p. 60). However, for this program to work, there must be effective leadership. There are three key persons responsible for the management and oversight of a comprehensive compliance program: the chief compliance officer, the general counsel, and the internal auditors.
Chief Compliance Officer
The first key person is the chief compliance officer. Regarding the role or function of a chief compliance officer (CCO), Lui et al. (2021) stated that they are “responsible for compliance training and ensuring all the staff adhere to codes of conduct, including anti- corruption rules. A CCO also develops policy updates and assesses potential risks in compliance programs…CCOs are specifically in charge of compliance issues” (Liu et al., 2021, p. 115-116). A CCOs job is to oversee and maintain compliance in an organization. They create compliance policies, investigate violations of these policies, and communicate with the corporate body about any information pertaining to compliance. A CCOs goal is to make sure that the company can properly determine and handle risk. They want to ensure that the company’s internal controls are not only adequate and effective but that employees are complying with them.
General Counsel
The second key person is the general counsel. While a CCO focuses on compliance, a general counsel (GC) focuses on rules and regulations. Brooks et al. (2020) explained that a general counsel would “act as legal and business advisors and are generally involved in strategic and operational decisions, to either review or structure transactions” (p. 40). The role of a GC is predominantly legal work as they function as the chief lawyer of the company. A general counsel serves as a legal representative and provides legal services. They deal with litigations and transactions. They ensure that the organization is aware of all necessary laws and regulations. They also have multiple compliance-related duties. A GC monitors and ensures that programs and systems are in compliance with the law. They react to any legal risk the company may have. They develop policies. They also review the adequacy of the company’s internal control system and ensure that the internal controls are in compliance with the law. Checks and balances for the internal control system are one of the responsibilities of the general counsel.
Internal Auditor
The third and final key person is an internal auditor. “Internal auditing is an ‘independent, objective assurance and consulting activating designed to add value and improve and organization’s operations’” (Institute of Internal Auditors [IIA], 2019, as cited in Seymore & Robertson, 2020, p. 227). An internal auditor deals mostly with the operational and financial functions in a company. They evaluate risks and how management has handled them. They analyze company operations and data. They confirm the data presented to ensure that there is no fraud taking place. They also assess, improve, and discuss internal controls. “Internal auditors have a responsibility to provide independent assurance about effectiveness of internal controls… and can also provide advice on internal controls to the top board and management” (Gramling & Schneider, 2018, p. 319). Internal auditors are necessary to determine if an internal control system is behaving effectively or not. They ensure that the programs are being followed and that they do not contain fraud.
Biblical Application
Each of the three key persons discussed is necessary to have both an effective compliance program and an effective internal control system. Even though they all have different roles or functions in the system, it does not mean that one is more important than the other. They are all needed for things to run smoothly. A similar lesson is taught in the Bible. Romans 12:4-5 says, “for just as each of us has one body with many members, and these members do not all have the same function, so in Christ we, though many, form one body, and each member belongs to all the others” (New International Bible, 1978/2018). An organization is a unified body, just like a church. However, while everything is in unity, it is not in uniformity. We each have our distinct roles in the body of Christ, just like the roles discussed above are distinct. We are called to our own type of work, and our roles are bigger than just us. This work is for the common advantage.
References
Brooks, M. R., Hairston, S. A., Njoroge, P. K. & Ryou, J. W. (2020). Does the Presence of a General Counsel in Top Management Affect Audit Efforts and Audit Outcomes? Accounting Horizons, 34(3), 39-59. https://ezproxy.liberty.edu/login url=https://search.ebscohost.com/login.aspx? direct=true&db=bah&AN=146121851&site=ehost-live&scope=site
Girgenti, R. H. & Ben-Chorin, O. (2021). Corporate Governance & Fraudulent Financial Reporting. McGraw-Hill Education.
Gramling, A. & Schneider, A. (2018). Effects of reporting relationship and type of internal Control deficiency on internal auditors’ internal control evaluations. Managerial Auditing Journal, 33(3), 318-335. https://doi-org.ezproxy.liberty.edu/10.1108/MAJ-07-2017-1606
Liu, C., Xu, C. & Liu, Z. (2021). To control or to compromise? The prominence of chief Compliance officer and foreign corrupt practices act violation. The Journal of Corporate Accounting & Finance, 32(2), 114-128. https://doi-org.ezproxy.liberty.edu/10.1002/jcaf.22491
New International Bible. (2018). Zondervan. (Original work published 1978).
Seymore, M. & Robertson, J. C. (2020). Managers’ Intentions to Share Knowledge to Internal Auditors: The Effects of Procedural Fairness and Internal Auditor Type. Journal of Management Accounting Research, 32(2), 225-241. https://ezproxy.liberty.edu/login?url=https://search.ebscohost.com/login.aspx? direct=true&db=bah&AN=146121872&site=ehost-live&scope=site
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Question 
Your healthcare organization has had several small compliance incidents in the past two years, and the organization is now motivated to update its compliance program. Your executive leadership team asked you to review 2 healthcare compliance programs from similar organizations to determine how they constructed their compliance program and what aspects your organization should adopt.
Comprehensive Compliance Programs
Select the type of healthcare organization you want to be represented in this assignment (e.g., family practice, hospital, urgent care, or nursing home).
Locate 2 compliance program documents from comparable health care organizations using your Internet search engine.
Read both compliance program documents and examine the similarities and differences between the 2.
Create a matrix that compares how both organizations execute the following compliance components:
How internal monitoring and auditing are conducted
How compliance and practice standards are implemented
The designated compliance officer (or a person designated to be the contact for compliance matters), who that person reports to, and their relationship to the organization’s governing board
How employees are trained and educated to model compliant behaviours
How violations or offences are detected, reported, and corrected
How lines of communication with employees are developed
How disciplinary standards are enforced
Write a 525- to 700-word executive summary that informs your executive leadership about the matrix you created and offer your opinion as to which best practices the organization should adopt for its own compliance program.
Cite your sources according to APA guidelines.