What is a practice? When we review the definition, we see that practice can be a noun (a thing) and a verb (an action).
- the actual application or use of an idea, belief, or method, as opposed to theories relating to it. “the principles and practice of teaching”
- the customary, habitual, or expected procedure or way of doing of something. “current nursing practice”
- perform (an activity) or exercise (a skill) repeatedly or regularly in order to improve or maintain one’s proficiency. “I need to practice my French”
- carry out or perform (a particular activity, method, or custom) habitually or regularly. “we still practice some of these rituals today”
In the context of best practices in compliance, we believe that a practice is BOTH a thing AND an action.
As a thing, there is an expectation of physical existence, (generally in paper or digital form, in writing) which can be distributed to others; team members, auditors, customers, vendors, examiners, etc. The documentation exists to instruct on the organization’s understanding of its compliance obligations, and how it intends to conduct itself within those obligations.
As an action, practices are activities that are performed on a consistent and regular basis. Actions are behaviors. These behaviors can only be in alignment with intentions and instructions of leadership if they have been communicated. In the absence of documented practices, the intention of company leadership can only be observed and interpreted based upon the behavior and actions of the company’s staff. This is a common pitfall of many of those companies we see in enforcement actions. The behavior of a few, whether through ignorance or malfeasance, can easily be misinterpreted as the culture of a company and lack of compliance conscious leadership.
In order to have best practices, a company must clearly articulate and memorialize its instructions and intentions, over time, through documentation, and then act in accordance with these directives. These actions generally have a component of documentation as well, in order to demonstrate that staff are acting in accordance with the directives of leadership.
Coupling documentation of intention and instruction with documented actions or behavior, is how a company demonstrates its compliance management efforts. Compliance Departments have the important role of ensuring that intentions and actions of the practices are aligned and consistent.