MAIL BAG: OUTDATED, UNUSED COMPLIANCE MANUAL WORSE THAN NOTHING AT ALL

Alert reader A. Grande of Petoskey, MI writes, “During our company’s recent move, I found a document titled, “GSA Schedule Compliance Manual – 1998”.  I’d never seen it before, even though we’ve had a Schedule for years.  Should I update it, or just buy it a drink since its over 21?”   Very funny, A., but outdated compliance manuals are no laughing matter.  Indeed, any auditor would take it as a sign that your company isn’t serious about following the terms and conditions of your contract.  Compliance manuals and processes only work if they’re followed, trained to, and maintained.  Both rules and your workforce change over time.  Training needs to be consistent, part of the on-boarding process for every new hire and annually for your team.  Many contractors also have an annual review process in place to catch potential issues before they become problems and update any written policies that need it.  Current compliance manuals and training aren’t a 100% guarantee that your company won’t run into a compliance issue.  Like a flu shot, though, they do reduce the chances that you will get sick and, if you do, that the case will be milder.  Not getting a shot, or keeping your compliance program up to date, can make you sicker and cost your company plenty in terms of fines and lost productivity.  Whether a good compliance program will make you feel like the “King of Staten Island” is problematic, but it is definitely a best practice to reduce risk and cost.