Using current events to assess the effectiveness of your compliance program

Brenda Hickernell ( (photo not available) and Frank Ruelas ( are Facility Compliance Professionals with Dignity Health in Phoenix, AZ.

On November 29, 2017, it was announced on NBC’s Today show that Matt Lauer, perhaps one of the show’s most notable and famous hosts, was terminated by NBC in response to a “detailed complaint from a colleague about inappropriate sexual behavior in the workplace.”[1]

Suddenly, someone with a reputation of reporting big news stories on the Today show to its national audience was now the subject of a big news story. Shortly afterward, the news of Mr. Lauer’s termination was aired on other networks and became a topic of discussion on a national level.

Aside from the sensational nature of the story and the allegations directed towards Matt Lauer, this event, when seen through the lens of a compliance program, raises some very important questions that compliance professionals may want to consider with respect to their own effective compliance programs (ECPs).

An event such as this can give us pause to reflect on whether inappropriate behavior of this type could happen, or might currently be happening, in our own organization. Given this possibility, we must then ask ourselves whether or not the victims of inappropriate behavior would come forward and report it.

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