Have a Merry Compliant Christmas!

‘Twas the night before Christmas, when all through the house,

not a creature was stirring, not even a mouse

All the children slept, with visions in their heads,

of gifts soon to be left, fun toys and sleds

But little did they know, the gifts were not those expected,

for their household compliance program had been sorely neglected

No, sadly, the whole family, kids too, were on the naughty list,

because the grown-ups had stumbled and mistook the risks

On this Christmas morning, there was a surprise,

but it wasn’t the good kind, nor any kind of prize

It was a subpoena from the DOJ, asking lots of questions in every way,

they wondered why the lists to Santa requested so many things for which they’d have to pay

The answer, my friends, is really quite clear,

their compliance program was hollow and not as it appeared

Instead of a program solid and effective,

theirs was squalid so the lists to Santa were awfully defective

The shame of it, really, was it was all very avoidable

preventable and stoppable, with success most probable

But no, the grown-ups had decided they simply did not care

to take the steps and do the things to ensure Christmas cheer

There was no system or process or good way to make sure

that the lists to Santa were checked, reviewed, or the data was secure

So, sadly this Christmas will not be as expected

nor will the new year, as all were left unprotected

It seems some more Christmases will be spent uptightly

as the grown-ups go on litigating, daily and nightly

It is sad because it didn’t have to happen, those unchecked lists,

filled with errors, gaps and bizarre twists

But tonight is Christmas, a time for wishes,

so I will wish for a future less vicious

I will wish for hope, that grown-ups and kids too will learn

that integrity is important, and trust must be earned

But more than all that, I hope everyone will see,

that compliance really matters, if you like Christmas like me

In closing, I will say Merry Christmas to all and to all a good night

enjoy the gifts that Santa leaves because you have been upright!

Reid Pearlman is an independent compliance consultant in Atlanta, Georgia. He advises healthcare entities of all types on best practices to assess, develop and strategically integrate compliance infrastructure, systems and processes. He welcomes comments and inquiries at Reid@MyComplianceOfficer.net.