Over the years I have observed that there is one reason that stands above all others as to why compliance programs fail and why they are never effective. This reason has nothing to do with what should be done but rather in how it should be done. It has everything to do with the means rather than the ends.
Traditional road maps to implement compliance programs focus on steps that start with low hanging fruit and often the closing of procedural gaps. The premise is that you need to address these basic steps before you can effect real change. It is only in the last step where real transformation begins when optimization and continuous improvement processes are introduced. This is where effectiveness is finally the focus.
However, most never get there.
Is there a better way? Let's find out.
The Traditional Approach
This traditional approach, which some may notice is similar to the waterfall approach in project management, almost always takes too long to reach the end. This results in fatigue setting in, funds running out, and leadership losing interest. Rarely do companies ever reach the last step where effectiveness is finally evaluated and improved. These compliance programs never reach operational status let alone effectiveness. Organizations have parts of a system but never a system that actually works.
At this point companies start over again having never gained ground of any significance.
A Better Way
Instead, a capabilities improvement approach such as Lean Startup evaluates effectiveness at each stage of implementation defined by successive Minimal Viable Performance (MVPs).
This approach ensures that you have all the essential behaviours and capabilities in place to be operational while you ramp up performance over time. This is more akin to an agile approach where you always have working code. The same is true here, you always have an operational compliance system – a compliance system that works. Perhaps at the beginning it looks more like a bicycle but over time it becomes a motorcycle, car, a train, and perhaps even a plane. You always have more than just parts – you always have something that can get you from here to there.
However, many companies still create their compliance road maps based on building more parts rather than on building a system that can be improved over time. That is why these companies will never have an effective compliance system. In fact, many will never have a compliance system that works and that can get them to better outcomes.