Dealing with Annual or Quarterly Certification “Stragglers”

Every organization that requires employees or other registered people to complete quarterly or annual certifications strives for a 100 percent on-time completion rate. In reality, unless you have just a handful of employees, all of whom are conscientious and dedicated, you will likely have to deal with “stragglers” who fail to meet your initial deadline – and may fail to meet subsequent deadlines too.

Following Up for Late Certifications is a Drain on Compliance Resources – and Morale

Unforeseen circumstances may cause even the most responsible employee to miss a certification deadline. But, all too often, missed deadlines are simply the result of employees who don’t take their compliance responsibilities seriously.

Of course, your firm’s compliance certifications are not optional, so it’s frustrating when employees treat them as such. Frustration aside, spending time following up with people who are late in returning certifications can be time-consuming for compliance personnel, taking resources away from other projects and tasks. Chasing down stragglers is also a crummy task!

Improving Your Firm’s On-Time Completion Rate

There’s no single “best” way to move the needle closer to the 100 percent on-time mark; what works for one firm may not be effective in another. However, implementing one or more of these best practices may help you see an improvement over time:

  • Automate the Certification and Reminder Process. Leveraging the automated workflow capabilities with a RegTech solution can provide significant process improvements. If you know you have a problem with employees missing the deadline, setting up automated system reminder communications can lessen the risk that the initial communication will be buried in the employee’s inbox.
  • Make it Easier to Complete Certifications. Making certifications available on a mobile device can also help you improve your on-time completion rate. When employees have the ability to complete their certification using smartphones or tablets, they can meet their compliance requirements from anywhere.
  • Set the Tone from the Top. When employees know that the firm’s senior leaders stand behind the compliance department’s certification requirements, they may be more inclined to submit timely responses. Enlisting the CEO or the Director of Sales to help be the messenger about compliance requirements may spur more on-time completions.
  • Implement Appropriate Sanctions. While you may want your compliance department to be seen as a carrot and not as a stick, implementing consequences for late completions – and following through on them – can also be an effective measure when trying to eliminate certification stragglers. Of course, the punishment should fit the crime; failing to turn in an annual certification on time shouldn’t lead directly to termination of employment.
  • Start the Process Earlier for Known Stragglers. Use past information as an indicator of future behavior. If you know a certain group of employees is prone to submit late certifications, get in front of it by reaching out to them or starting the certification process sooner for them.

Some firms consider compliance activities like responding to compliance department inquiries and certifications on time as part of the score for discretionary bonus compensation, subtracting points for failing to respond promptly or failing to comply with firm policies.

Other firms get more creative after multiple attempts to obtain completed certifications by turning off access to certain systems or even removing building access privileges until the user completes and submits their form.

Consistency is Key

As with any type of compliance action, it is important to be consistent about how you address instances of non-completion, not giving preferential treatment to any one group of employees. You don’t want Compliance to be viewed as the enemy, but as a partner.

You may need to tweak your follow-up procedures and methods for handling stragglers from quarter-to-quarter, but it is possible to inch closer to a perfect on-time completion rate.