1.0 Purpose

The development and imposition of corrective action plans to follow during compliance-related issues.

2.0 Scope

This policy applies to all FinGoal employees, contractors, and temporary workers.

3.0 Policy

The FinGoal leadership team may develop and, in consultation with Human Resources, impose a corrective action plan upon noncompliant staff or other persons subject to the FinGoal Compliance Program as a means of facilitating the overall goal of full compliance.

Corrective Action Plans should be designed to first assist the noncompliant individual(s) to understand specific issues and reduce the likelihood of future noncompliance. Corrective action, however, shall be developed to effectively address the particular instance or issue of noncompliance and should reflect the severity of the noncompliance.

3.1 Elements of a Corrective Action Plan

The following constitute the minimum action which shall be taken in response to noncompliance with the Compliance plan. A Corrective Action Plan for a first violation of noncompliance shall include these elements:

  1. A clear statement of the specific problem(s) to be corrected.
  2. A summary of the method used that discovered the problem.
  3. A summary of the findings that include a root cause analysis of the noncompliance that will determine the extent and content of the Corrective Action Plan. The root cause may be found to include system or human error, negligence, reckless disregard of FinGoal policies or procedures, and applicable laws and regulations, or willful misconduct.
  4. Remediation, which at minimum, shall include additional education or training by the leadership team if a root cause analysis indicates that education or training is appropriate.
  5. Within ninety days after the remedial education is completed, a followup audit of the corrective action implementation to determine whether the Corrective Action Plan is being followed and is effective.
  6. A statement that the failure of an individual who is subject to a Corrective Action Plan to adhere to the plan shall be grounds for further corrective action that many include disciplinary procedures and/or actions.
  7. A statement that if a root cause analysis shows that the source of the problem was a reckless disregard for FinGoal or facility policies or willful misconduct, the Corrective Action policy shall yield to all appropriate provisions of the applicable Human Resources corrective action plans or policies.
  8. Documentation regarding Corrective Action Plans will be maintained by the leadership team for a minimum of 6 months after the completion of the plan.

4.0 Revision History

Untitled Database