NYSE Governance Services and the SCCE analyzed the responses from nearly 250 healthcare chief compliance officers or persons responsible for the day-to-day operations of the ethics and compliance programs of healthcare organizations. The professionals were surveyed from June to August. Highlights from the surveys include the following.
- More than half (56 percent) of the organizations surveyed give the person with overall responsibility for the compliance and ethics program the title of chief compliance and/or ethics officer or compliance and/or ethics officer.
- Forty-one percent of internal compliance and ethics committees are chaired by the chief compliance and/or ethics officer who typically reports findings and recommendations to an audit committee.
- Seventy-two percent of internal compliance and ethics committees have cross-functional representation.
- Seventy-one percent of the committees have a documented charter.
- Almost all (93 percent) have at least quarterly regularly scheduled meetings.
- Roughly two-thirds of respondents (67 percent) indicate that the same person is assigned both overall and day-to-day operational responsibility for the compliance program.
- Thirty-eight percent of those with overall program responsibility report directly to the CEO, while 19 percent report to the board of directors.
- While 19 percent of those with overall responsibility for the program report directly to the board, the overwhelming majority, 79 percent, have a dotted reporting line to the board.
- When the person with day-to-day responsibility does not have overall responsibility for the program, most (31 percent) report to the chief ethics and/or compliance officer, followed by the general counsel or chief legal officer (21 percent).
