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Corporations have a responsibility to their governments, employees and customers to operate using ethical practices. Employees have an obligation to their employers to perform their duties competently and honestly. Today’s pharmaceutical industry appears to have these two groups locked into conflict in the form of compliance interviews. Compliance interviews are delicate situations that can be helpful to employers in managing the workforce and treacherous to the employees. The nature of these proceedings and the effect of these interviews on the employees are explored in this project through social science research methods that will be used to highlight the employee experiences and set forth several hypotheses. The effect of the environment, the nature of the compliance interview, and targeted strategies for the employee are detailed in order to improve the communication in this particular setting.
Table of Contents
Abstract……………………………………………………………………………………………………..…… …ii
Table of Contents…………………………………………………………………………………………....iii
Introduction…………………………………………………………………………………………………… …1
Statement of the Problem……………………………………………………………………………….2
Goals and Objectives………………………………………………………………………………..…….2
Significance…………………………………………………………………………………………………… ..5
Literature Review…………………………………………………………………………………..……….6
Environment……………………………………………………………………………………………….7
The Compliance Culture……………………………………………………………………………17
The Compliance Interview………………………………………………………………………..23
Legal Issues………………………………………………………………………………………..…….32
Case Studies……………………………………………………………………………………..………34
Methods and Design…………………………………………………………………………..……….…36
Results…………………………………………………………………………………………………………….3 8
Areas of Future Research…………………………………………………………………………….…46
Discussion………………………………………………………………………………………………………. 45
References………………………………………………………………………………………………………4 9
Introduction
The largest economic downturn since the Depression has the United States in a tailspin. Most industries are feeling the pressure, including pharmaceutical companies who are losing money as patents on blockbuster drugs like Lipitor and Prilosec expire. During the blockbuster heyday, pharmaceutical companies used sales representatives to increase the sales of these drugs. These blockbusters are increasingly available as generics (Woolard 2009). Healthcare reform promises sweeping changes to marketing practices for pharmaceutical companies and these companies have sales representatives they no longer need. Terminating employees at minimal cost is now the goal for most of these companies (Klein 2008). Sales representatives have received severance packages and turned in company cars in ever increasing numbers.
This downsizing is usually managed systematically but posts on a pharmaceutical blogspot called CaféPharma suggest that an increasing number of employees report termination for minor infractions or clerical mistakes (CaféPharma 2007 Merck). An audit is conducted on representative sample forms and they are reviewed for any inconsistency. All mistakes or infractions are noted. The representative is then questioned in person about these infractions. These compliance interviews or compliance audits have been referred to in legal filings (Dotson v Pfizer 2009) and at CaféPharma.com. A post entitled “Meeting with the Compliance Manager” received 60 responses and 5,499 views on CaféPharma (CaféPharma 2008 Glaxo). The evident employee interest and concern highlight the need for a unique study into the use of interviews and audits by the pharmaceutical compliance department in conjunction with the human resource department to relieve the company of an unwanted employee.
The Problem
Mystery has grown surrounding compliance audits and employees actively seek information from informal communication sources. In “Stress, Cognition, and Communication in Interpersonal Conflict”, Sillars and Parry maintain that anxiety undermines cognition. Meaningful, researched information about compliance audits will provide transparency and minimize fear and anxiety that could lead to misinterpretation (1982).
Goal and Objectives
Effective communication strategies and preparation are essential to employee success in these compliance situations. The scarcity of published material addressing these interviews and the resulting outcomes indicate the need for information set forth in this project. This project will explore historical and background information and briefly address the current pharmaceutical industry environment to include both legal issues and precedents. Additionally, social science research methods will be used to highlight the employee experiences and set forth several hypotheses. Lastly, employee strategies will be devised to help navigate a compliance audit.
As noted above, sample compliance audits and interviews are not well documented, and they may be unique to the pharmaceutical industry. Small infractions or clerical errors are routine in every industry, yet some pharmaceutical companies appear to be targeting representatives and using unrealistic standards to terminate employees in an effort to reduce an over-abundant workforce. The employee’s experiences detailed in web postings indicate that the “zero tolerance” standard is applied inequitably (Café Pharma 2007 Merck).
This termination technique has been reported by employees on blogs, and in district and regional meetings. A great deal of frustration and anger is expressed by former employees terminated in this manner. Employees are requesting information from colleagues about navigating audit interviews, avoiding being targeted and gleaning tips on preparing for the interview. The advice shared is inconsistent and often inaccurate. Representatives report varied degrees of success navigating the audit interview and most report that the process ends in termination. Furthermore, published literature regarding employee preparation is scant.
Since these small infractions or clerical errors are routine in every industry, the pharmaceutical companies are aware that sales representatives are capable of errors and have devised strategies to minimize these errors. Sample accountability departments and compliance departments are devoted to helping the representative manage samples issues. These issues include missing samples, missing signature cards, inaccurate signature cards, missing computer records, and incomplete data on any number of forms. Although these errors are commonplace and are usually not considered intentional or malicious, these errors can be evaluated as fraud by employers looking for cause against employees. The industry blogs support that most representatives make these small clerical errors but some seem to be held to a higher standard and terminated for the same clerical errors that do not even merit a mention to other employees (CaféPharma 2007 Novartis). The blog indicates that an audit of virtually any consultant would produce some aspect of behavior that may be construed as inconsistent, but certain circumstances lead to representatives being audited, questioned and verbally pursued in a police-style interrogation. Sometimes, this interrogation is focused on insignificant clerical errors. Furthermore, these interrogations are discussed by the bloggers of the five largest pharmaceutical companies and appear to be commonplace throughout the pharmaceutical industry (Café Pharma 2007 Merck).
This termination technique, that has been reported by employees on blogs and discussed among colleagues, reveals that no official records of these audits are available to employees at the time of the interview. Additionally, employees typically fail to take notes themselves. Furthermore, the human resource departments may resist providing a copy of the document to the employee unless requested by an attorney when a grievance has been filed and failed and mediation or litigation is pursued. The company grapevine, as defined by Argenti, in his book Corporate Communication, is the primary mode of unofficial communication. This type of communication is important because information is widely distributed to employees and is believed by these employees. These online company grapevines produce a descriptive representation of the pharmaceutical compliance audit. Some employees are still seeking support and understanding years after the event and are interested in providing support and information to others (1998).
These described compliance interviews are uniquely interesting in the context of the human resource department. The aggressiveness of this termination procedure is inconsistent with human resource best practices that recommend utilizing a humanistic termination procedure (Mathis and Jackson 2006). A great deal of frustration and anger is expressed by former employees terminated in this manner. The law and legal ramifications are poorly delineated in these situations and create more confusion. The interrogative nature and “surprise attack” method of approaching an employee can appear to be intentionally abusive.
Significance
The available literature that specifically addresses the needs of an employee compelled to participate in a compliance interview is extremely limited. The article “Compelled Cooperation and the New Corporate Criminal,” states that since new laws are in place to make the employee and corporation equally accountable for actions, internal investigations and interviews may increase as corporations seek to lessen their exposures (Griffen 2007).
There are, however, helpful resources that included legal writings, human resource procedures, and communication research. Research of particular interest to this project focuses on conflict in various communication settings including interpersonal, intrapersonal, negotiation, mediation, listening and bullying. Additionally, organizational communication topics including organizational learning, trust in organizations and compliance are consulted.
The ubiquitous nature of the problem as evidenced by a comprehensive literature review, reiterates the need for timely education and strategies to allow for employee preparation and subsequent success in these compliance situations.
Literature Review
This literature review will be considered in distinct sections: the
environment, the organizational climate, the interview content and process, and case studies.
The Environment
The current environment in the pharmaceutical industry provides a rich breeding ground for troubling compliance activities. The environment is significantly impacted by several factors including, but not limited to, the nature of the sales force, government regulations, and economic instability.
Pharmaceutical companies have built huge sales forces around the world. In Business Week, Amy Barret, reports in her article, “Pfizer’s Pfunk,” that in 2005, Pfizer alone had 38,000 representatives tasked with encouraging doctors to prescribe Pfizer products to patients. Pharmaceutical companies are self described sales organizations (Barret 2005). Individual representatives are held accountable for sales in a given territory and receive evaluations, performance reviews and bonuses based on performance numbers. The sales representative must produce above expectations and meet quotas to be considered for promotion. One blog explains that Pfizer uses a document known as the GAR (goal attainment report) which nationally ranks its representatives (CaféPharma 2008 Pfizer). Other pharmaceutical companies have similar systems.
Although the emphasis on and demand for sales performance is the primary predictor of success for the employee, Carlyle and Womble note that these sales representatives are legally classified as administrative employees (2008). Pharmaceutical representatives can be classified as such because they do not take an order or directly provide a product. Their goal is product promotion with the aim of influencing prescribing behavior, but they do not directly sell the product. Since they are not “salesmen,” they cannot be terminated for poor sales results. This employee classification reveals the seed of the compliance audit in that pharmaceutical companies must find other criteria on which to terminate targeted employees.
Managing, motivating, evaluating, and terminating the pharmaceutical representatives are difficult. These representatives exist to sell product but legally they cannot be fired for poor sales results. Performance reviews attempt to incorporate behavior in the evaluation. A manager may consider certain activities and behaviors of a representative either negatively or positively depending on the overall impact of such behavior on the sales results produced by the entire territory. Excellent behavior is only excellent if sales increase, and unfavorable behavior is only unfavorable if the sales numbers are below expectation. Unfavorable behavior may even be considered as praiseworthy if sales increase. The perception of the manager may be influenced by his own bonus concerns. Industry blog posts indicate that district sales numbers must be positive for the manger to be successful and receive bonuses and promotions (CaféPharma 2007 Sanofi-Aventis).
Krawiec explains, in her legal review, “Cosmetic Compliance and the Failure of Negotiated Governance,” that the perception of a situation depends on the individual’s need at the time when the judgment of the situation is made: “A large body of psychological research indicates that desires often dramatically impact information interpretation, even by those who consciously strive for objectivity and impartiality. Self-serving bias is particularly likely to emerge when information is ambiguous and thus subject
to differing interpretation” (2003 18).
The environment is also complicated by governmental regulations. According to Doug Lankler, the assistant general counsel for Pfizer, the pharmaceutical industry is “possibly the most highly regulated industry” in the country (2005 7). He further asserts that the FDA partners with pharmaceutical manufacturers to manage and assure compliance from the pharmaceutical manufacturers (2005).
Recently, these companies have found it impossible to maintain the mandated marketing compliance and will literally have to “pay the price.” Alex Berenson, of the New York Times, reported that 33 states will receive 62 million dollars from a Zyprexa case settlement. Eli Lilly Pharmaceutical Company was accused of marketing “off-label” and will be required to pay a fine. “Off-label” marketing is described as marketing for a drug use that is not FDA approved for that particular drug. Typically, the FDA will not approve a use for a drug if studies indicate a lack of efficacy, potential harmful side effects, or if insufficient studies are available (2008). This settlement indicates the extent that internal and external compliance failures have occurred. These failures most notably include the pitfalls of promoting “off-label” uses of marketed drugs. On the blog “Fierce Pharma,” the author “tracy” reports that Glaxo Smithkline Pharmaceutical Company received a four hundred million dollar fine for “off-label” marketing. She further reports that GSK reported to stock holders that this 400 million dollar fine will be taken as a fourth quarter loss. “tracy” also mentions that Pfizer will pay 2.3 billion dollars for “off-label” promotions. Many other incidents in which pharmaceutical companies, such as Roche, Pfizer, Eli Lily, Merck, Schering Plough and GSK, are paying fines are also documented in her posts. These awards are prime examples of compliance failures and lead employers to want and need to share exposure from these failures with the employees (2009).
These regulatory measures may indeed provide significant benefit for the reduction of noncompliant behavior. However, there is concern that these laws will only implicate mid-level employees as scapegoats. Mr. Kerdell, an associate professor at Methodist University’s Dedman School of Law, states that this exposure will lead to what he calls “equal opportunity career threat.” He speculates that these new laws may encourage corporations to insulate themselves and provide lower level managers as “sacrificial lambs.” An employee’s non-compliant activity that is identified and addressed will serve as proof to the regulators, consumer advocates, and the public in general, that these compliance issues are being addressed by the corporations. Kerdell speculates that many more employees will find themselves negotiating internal investigations and interviews (Staff 2008).
A harbinger of things to come may already be seen in the pharmaceutical industry as the government is already involving itself in managing day-to-day operations of these companies. Government regulations already govern the training of pharmaceutical representatives on proper management of pharmaceutical products, called starters or samples. The court case regarding Dotson v. Pfizer describes the Prescription Drug Marketing Act, 21 U.S.C. § 353 et seq. (PDMA). PDMA describes the appropriate distribution of and marketing of pharmaceutical drugs. PDMA requires pharmaceutical companies to track and account for any starters given to physicians. Companies may use paper or electronic tracking to fulfill its responsibilities under the statute. Health care providers must sign to acknowledge receipt of the samples. Violations can result in sanctions ranging from fines and the loss of drug distribution rights to imprisonment for some criminal violations of the statute (2009).
In a recent interview with this author, Dr. Meganne Walsh, a practicing physician, confirms that pharmaceutical representatives in her area adhere to PDMA regulations in their daily responsibilities. She also confirms that these representatives manage extensive paperwork and forms (2009). This interview supports the CaféPharma posts that allege PDMA regulations and paperwork requirements increase the likelihood of clerical errors or unintentional oversights. These errors fostered by PDMA regulations are an area of particular interest to employers when auditing a representative for non-compliance (2009).
In fact, according to Don Moore, a former Ciba-Geigy Pharmaceutical Company representative, compliance audits were developed to deal with a few employees engaged in illegal merchandizing and/ or handling of the samples that pharmaceutical companies entrusted to them, an overtly illegal practivce. The PDMA laws require tracking of samples and reduce the incidence of pharmaceutical representatives selling samples outside of standard channels to United States pharmacies or over the border in Mexico. This practice is known as drug diversion and was problematic for drug manufactures and the United States government. Drug diversion has the potential to risk patient’s health due to inappropriate use and/or corrupted product integrity. Tracking and compliance activities reduce the pharmaceutical company’s legal exposure from the rogue representative and discourage the “entrepreneurial” representative (Moore 1991). Although PDMA was instituted to address this drug diversion, it is now being used to criminalize clerical errors and inadvertent omissions.
Obviously, the current legal environment encourages compliance activities to flourish as employers seek to share the burden of regulations and liability exposure. While some of this behavior is legitimate and appropriate, the lack of transparency surrounding these internal grievances may not provide the employee with a safe work environment.
This failure of the compliance audit system has the ability to produce a hostile workplace. Interestingly, an entire website, Bully Online, discusses this phenomenon. Field, the author of the site, suggests that the grievance process fails because of the fraternal relationship that the supervisor and human resource manager share. This relationship may prejudice the human resource manager and therefore, the employee may not receive fair treatment. In addition, the employee is not allowed to bring the support of an attorney or any witnesses. Justice may be further frustrated by an unethical presentation of the facts by the supervisor (Field 2009).
The American employee is vulnerable as many corporations are making huge lay-offs to address the declining economy and the expansive use of generic pharmaceuticals. The loss of employment can be devastating on its own, but the stress is compounded if the job loss is accompanied by harsh, punitive, or abusive treatment. Griffen discusses a Supreme Court ruling and states that the threat of a job loss is as significant to the employee as the corporation losing sizable contracts is to the employer (2007). These corporations assure that they will treat employees fairly and this assurance is presented in the employee handbook.
Often these companies will publicize these benefits to enhance their image as good corporate citizens. These termination practices are at odds with their public image and contribute to the non-transparency detailed above.
Despite these corporate aims to treat employees fairly, hostile terminations resulting from compliance surveillance occur. Aggressive, unethical and potentially illegal termination can impact the employee so severely that they are unable to function or seek new employment and this behavior represents corporate bullying. Hodson, Roscigno and Lopez in “Chaos and Abuse of Power in Organizations” state “that between 10% to 20% of employee’s are bullied annually” (2006 383). The psychological impact on employees is devastating and is comparable to the emotional distress of war camp prisoners (2006).
Workplace bullying is defined as ”repeated attempts to torment, wear down, or frustrate another person; it is treatment that provokes, pressures, intimidates, or otherwise causes discomfort” (Hodson, Roscigno and Lopez 2006 384). Bullying is classified as a sub-heading of organizational communication under conflict. The defining characteristics of bullying are the supervisory position of the bully and the intent of the bully to do harm. Bullies thrive in organizational chaos and they cause significant damage (2006).
Literature describing bullies in the workplace is growing. The current literature recommends using the term bully to describe the abuser and using the term target to describe the bullied. Naming this abuse at work provides context for the employee so that they can frame the experience. To meet the definition of bullying, the behavior must be repetitive, occur over time, escalate and be aimed at employees (2006). In bullying, the target believes that there is intent to harm and they experience feelings of anger, hopelessness, helplessness, frustration, injustice and betrayal (Lutgen-Sandvik 2005). Shock, anger, and injustice leave targets speechless and they are unable to describe and articulate the abuse with coherence. This incoherence is a symptom of the distress and is related to the abuse of trust. Employees may develop significant somatic ailments attendant to stress such as chronic fatigue, body ache, insomnia and impaired immunity. Targets may be forced to leave or may be terminated from employment (Tracy, Lutgen-Sandvik, Alberts 2006).
Targets are not necessarily weak and are not to blame for the abuse. The bully acts to abuse. The specific target may be bullied for various reasons. Bullies prey on people with varied characteristics. The target may be anyone. The old are targeted, as are the young. The innovators are targeted, as are the team players. The optimists are targeted, as are the pessimists. The empowered are targeted, as are the disenfranchised. The loners are targeted, as are the popular employees. Bullies may target different members of a group and cycle through the individual members of the group randomly. The target may change, but the pattern of abuse by the bully will be consistent (Harvey et al 2006).
Organizational factors can minimize the power and control that bullies have in the workplace. Transparency, accountability, and capacity will prevent workplace abuse. Transparency will reveal the bullying behavior. Accountability will ensure that abusive behavior is punished. Capacity will provide positive motivation for employee since performance is measured with clear standards for reward and achievement (Hodson, Roscigno, and
Lopez 2006).
Additionally, competence and coherence create work environments that are civil and professional. Although every organization suffers through chaotic times, a work environment that provides clear coordinated activity reduces interpersonal conflict. Chaotic environments promote depression and discontent and will produce bullies. Pharmaceutical sales organizations provide a rich environment for bullies. Hodson etal establish that job insecurity and chaos breed bullies (2006).
Insecurity is prevalent as pharmaceutical companies are downsizing and the correlation between effort and success in employee evaluation are not clear. Chaos abounds within pharmaceutical companies due to many factors: 1) Influence, not product per se, is pedaled. 2) The degree of influence or sales success is not immediately measurable. 3) The sales data is not transparent and the employee must trust that the reports are correct. 4) The organization cannot fire administrative employees for poor sales results and most sales representatives are unaware of this.
5) The manager is the sole judge of the employee skill and ability. 6) The manager uses subjective behavioral criteria to evaluate the employee’s sales performance. 7) The manager is directly rewarded by representative sales results and this may prejudice the evaluation. 8) Insurance, Medicare and Managed care formulary have a significant impact on the sale representative’s success. These formulary decisions are made on a national level and the representative has no control over the decision (CafePharma 2007 Sanofi-Aventis).
A representative may work diligently and expertly and not attain sales results because of outside influences. Conversely, a representative may not expend effort but due to formulary changes, positive sales results occur. The lack of correlation between effort and results, the potential for subjective evaluations, the intangible nature of sales results, and the unique administrative designation of the employee serve to create an environment of chaos (CaféPharma 2008 Eli Lilly).
The Compliance Culture
An active compliance department is required to maintaining the standards of and responsibility for government regulations, to protect the interest of the share holders, to implement employee governance and to advocate for the safety of the consumers of the product. Claybrook, in “Viewing Organizational Trust,” contends that compliance officers must be aware of the myriad requirements and insure that the corporations maintain and adhere to standards necessary for proper compliance. Ideally, compliance officials maintain the integrity of the company (2004).
Claybrook also discusses that the role of corporate compliance is the responsibility of everyone in the organization at every level. A commitment to compliance maintains the integrity of a product or service that a company provides for the public. She further explains that the compliance office may have internal investigators or auditors that review issues as they occur. The compliance officer’s focus is on maintenance of standards, regulations, and procedures in an organization (2004). The compliance department is afforded a degree of trust as it is given the task of legitimizing business practices. Claybrook quoted the definition of “Trust” by Young, Ybarra and Wiersema: trust “is based on three components: expectation that the partner will act in the alliance’s best interests, consistency of actions and the partner will not act opportunistically” (2004 15). This expectation should encourage an employee to meet with the compliance officer honestly and be able to communicate freely.
Breaux et al, in “Try a Little Tenderness,” detail the detrimental effects of accountability when coupled with abusive supervision and discuss that corporate and individual accountability refer to the need to justify actions. Employees and corporations are held accountable for rules, laws, policies and procedures. Breaux et al further stipulate that ideally, corporations that have compliance departments should maintain the law and be good corporate citizens (2008). Proper compliance should provide a benefit for the organization and the employee.
Claybrook indicates that compliance departments and human resource departments are primarily concerned with providing legal protection. These departments, therefore, may quickly develop a culture in which employee concerns are disregarded and employee complaints are considered without merit. Also, the culture may deem the task of dealing with the concerns of the employee as bothersome. Claybrook, who herself is a compliance auditor, elucidates the relationship between compliance and trust:
“Moreover, personal and organizational trust interacts as employees
and managers learn what kind of behavior is rewarded (punished) in
their organizations. Both observe, and learn from their peers and each
other through discussion and stories. Organizational culture
(coordination, communication and decision-making) encourages or
discourages employee (and internal auditor) along with managerial
trustworthy behavior, this dynamic relationship, if either one
deteriorates it will negatively impact the other” (2004 7).
Corporations with wholesome compliance practices legitimize the corporation, limit corporate exposure, and enhance trust in the market place
(2004). The employee and the consuming public may be at risk if
Compliance activity only legitimizes organizational goals.
Krawiec explains the corporate hierarchy of the corporate departments
concerned with compliance activities. The human resource department, compliance department and middle management receive communication and guidance from executive management. The compliance and human resource departments are designed to be a deterrent to and investigator of illegal and unethical behavior; to provide the corporation with protection; and to mediate and manage conflicts with employees (2003).
Compliance and human resource departments, if corrupted, lead to mistrust and corporate instability. Institutionalized disregard for appropriate treatment of employees may become common (Krawiec 2003).
With new laws in place to increase employee and corporate adherence, employees may find themselves more frequently the target of internal investigations and interviews. Krawiec is concerned that increased compliance structures may not bring the intended results. Increasing compliance structures and monitoring for compliance may not lead to legal and ethical behavior. Much of the new compliance adherence rests with the employee. Corporations may obtain adherence by investigating and blaming employees. She further argues that this obligation may penalize employees unfairly. Her chief concern is that internal investigations will place blame on the employees even if the company or its officers are truly responsible. The company runs the investigations and is not in the best position to provide unbiased, meaningful decisions (2003).
Krawiec acknowledges that most American corporations intend to abide
by compliance regulations. Most use their internal compliance structure ethically, and manage external and internal matters that need internal review. She stipulates that although significant time and money have been invested in compliance programs, the evidence does not support that these activities inhibit unethical behavior (2003).
Several studies suggest internal compliance measures may be primarily
cosmetic and do not reduce non-compliance. Internal compliance investigations of employment infractions, while providing corporations with reduced liability, in fact, frustrate the intended public policy and have not reduced the number of complaints filed as was the hope (Krawiec 2003).
Rarely is one side completely innocent in conflict issues. Every organization has supervisors and employees that model inadequate behavior. Additionally, every organization has the right to terminate an employee. However, an employee under abusive supervision may be harassed and terminated unfairly. Breaux et al explain that employee reviews are highly dependent on the supervisor’s evaluations. Promotions and raises are determined by the feedback of the manager. Just one negative evaluation can create a career challenge. This is significant, and Breaux and his colleagues state that the “abusive supervisor can capitalize on the crumbling environment and significantly cripple future employment opportunities” (Breaux et al 2008 113).
This same research supports that performance evaluations should be
related to job performance and employees that receive evaluations unrelated to job performance will become passive. Employees that do not receive credit for job performance will eventually see no connection between outcomes and effort and will feel defenseless. The unethical use of compliance activities “may represent a violation of interactional justice, which stems from the employees perceptual judgments of the quality of interpersonal treatment they receive from organizational authority figures” (2008 113).
Krawiec explains that internal investigations of employee grievances have failed. Internal grievance proceedings were established to reduce the number of external employee complaints. They have not provided the expected result. In fact, these compliance activities act primarily as legal insulation for corporations. She acknowledges that the employee is vulnerable to abusive behavior in this compliance culture.
One manager describes the pharmaceutical culture and the potential for abuse.
“As a manager, I would say that the majority of people who work in this
environment (sales) were lured into the field for the money and not the
job itself.
Also, it is true that Merck and other Pharmaceutical Co's treat "some"
employees with discriminatory actions. You will find that most of the
injustices are geared towards employees that are not in a protected
class. Merck receives tons of government funding. Merck also distributes
this funding to many organizations that will support its political agenda.
It's easy for Merck to flood money into vulnerable groups that they can
potentially "sway" a political vote in their favor. At-Will employment
allows a lot of room for unprofessional and "sometimes" illegal behavior
on the part of an employer. Good documentation will be the only thing a
rep can do while enduring the process of being falsly accused of
something he/she didn't do. It won't save your job. It will allow you to
present the FACTS as they are during an employment dispute. It is very
true that many "good" "ethical" and "hardworking" employees are
mistreated. It is true that the activities that occur in Pharma (the
bullying, constant turnover, subjective bonus allocations resulting from
bogus IMS data, and the similarities expressed by reps on this board)
reveal the nature of the Industry. There's no need to bash an employee
who presents a concern and a desire to take medical leave to recover
and sort out some options” (CafePharma 2007 Merck).
The Compliance Interview
Pharmaceutical compliance investigations are described as convenient tools for termination. Pharmaceutical companies cannot fire sales representatives for sales numbers and the compliance interview lacks transparency and is aggressive. The lack of transparency may indicate an illegitimate use of power (Claybrook 2004). Compliance interviews, as described in court cases and CaféPharma, go beyond the legitimate communication expected from a compliance officer and could be described as an interrogation. The respondents on CaféPharma describe intense interrogatory interviews. Court documents, specifically Wagoner v Pfizer, agree and reveal the aggressive nature of these compliance audits (2009).
The preferred method of police interrogators is the Reid method. The
Reid method is an interrogation technique that combines questions, responses and behaviors of the interviewer to intimidate the interviewee and elicit admissions of guilt. Similar methods are reported by pharmaceutical representatives. King and Snook examine the Reid method in their article “Peering Inside a Canadian Interrogation Room.” This method consists of two phases: the interview and the nine-step interrogation. The interview is nonaccusatory, and it allows the interviewer to gather investigative and behavioral information. During an interview, the interviewer will seek to develop a rapport and provide language to the interviewee that will allow for an admission of guilt with an excuse for the behavior. Words like “might,” “could,” “would,” and “perhaps” are offered by the investigator. The interview seeks answers and guilt is not assumed (2009).
The CaféPharma posts support that these compliance audits are not interviews (CafePharma 2007 Merck). King and Snook also contend that if the investigator deems the interviewee guilty, then the communication becomes an interrogation. They further state that the assumption of guilt is made and the auditor’s goal is to force agreement. The auditor will begin questioning with the tone and attitude laden with the presumption of guilt. The auditor may initially provide a gentle road to admission, but if the interviewee does not capitulate the communication becomes increasingly persuasive and interrogatory (2009).
In the first step, the auditor will communicate to the employee that the
auditor believes the employee to be guilty and then prolonged silence will be held by the auditor. The auditor will then provide the employee with a reasonable explanation “Is it possible that you made a mistake?” The third step discourages any protest or explanation as to why they were incapable of the behavior and at this step the auditor may present sample signature forms, expense reports, or phone bills. These may be offered as proof of non-compliant behavior. King and Snook detail Step Six as the time that the employee may feel increasingly upset, and may cry. The employee also is passive but may show signs of emotional upset or depression. King and Snook support that the auditor will use pressure and encourage the employee to agree to non-compliant activity. Active persuasion is used to encourage feelings of anxiety.
Step Seven is a reiteration of the techniques described above with further insistence of guilt. The auditor provides the employee with two admissions. The first a face saving admission of guilt and the second an insistence that the act was premeditated and intentional. The interviewer will continue to adamantly insist on employee guilt.
In Step Eight, the auditor may get the employee to verbalize the auditor’s assumption. The use of questions such as “If you were going to do it, how would you do it?” may encourage verbalization of the auditor’s assumptions.
The Ninth Step discussed by King and Snook entails the documentation.
The auditor may record an “’if’ admission” as an “actual admission” and the employee, being overwrought and motivated to leave the uncomfortable experience, may trust the compliance officer. This trust would lead the interviewee to believe that the compliance officer will represent the communication accurately and so the employee may not read the record carefully and mistakenly sign a document that is inaccurate. The employee typically will not receive a copy of the signed statement and may, in fact, never see a copy (2009). Kasson and Gudjonsson discuss this phenomenon beautifully:
“For innocents who are initially misjudged, one would hope that
interrogators would remain open-minded and reevaluate their beliefs
over the course of questioning. A warehouse of psychology research
suggests, however, that once people form a belief, they selectively seek,
collect, and interpret new data in ways that verify their opinion. This
distorting cognitive confirmation bias makes such personal convictions
resistant to change, even in the face of contradictory evidence. It also
contributes to the errors committed by forensic examiners whose
judgments of handwriting samples, bite marks, tire marks, ballistics,
fingerprints and other "scientific" observations are often corrupted by a
priori expectations, a problem uncovered in many DNA exoneration
cases” (2005 28).
The Reid technique may be especially effective on the individual who
tries to perform well and is unaware that they are suspected of any wrongdoing. Kassin and Gudjonsson, in their article, “True Crimes, False Confessions,” state that trusting individuals are more suggestible to interrogation techniques. Distrust reduces suggestibility. The levels of anxiety also affect suggestibility. The threat of job loss and security is terrifying for most individuals and the Reid method is designed to create this anxiety (2005).
The employees trust that the Human Resource Department is compliant with the spirit and letter of the law. Compliance procedure inherently implies fair treatment. Employees are encouraged by a company’s “open door policy” to bring issues and concerns to the attention of the compliance department. This may result in self-implication of the employee, who is now at increased risk for a compliance audit (CaféPharma 2009 Novartis). Once in a compliance interview setting, the trusting individual is more suggestible to coercive interrogation technique (Conti 1999).
“In 1967 Schrodler et al found that high levels of stress reduce the individual’s ability to process information” (Sillars and Parry 1982 202). The employee’s ability to process and communicate clearly may be impaired by the anxiety and stress brought about by the audit interview. Recognizing potential deficits and limiting miscommunication is paramount to appropriate presentation of the truth (1982).
Compliance audits can cause anxiety and fear in even the most careful
pharmaceutical representative. “The very nature of verifying the value of one’s decisions or actions to an external audience has the potential to cause apprehension and its subsequent manifestations” (Breaux et al 2008 112). The uncertainty, speed and clandestine nature of these interviews create anxiety and fear and this reaction is justified. He states that eliciting anxiety is calculated (1999).
The aggressive and hostile nature of these compliance audits is deeply concerning. The employee must attend these interviews even if they have no hope of real communication. The employee must focus on navigating the interview adeptly so that the employee remain employed with an undamaged career.
The interviewer will cover past events. King and Snook state that the need to rely on recall of past events puts the interviewer at a disadvantage. As the situation may have occurred in the past months or years, recall memory becomes inaccurate and unreliable. As an example, a representative may visit the same doctor every two weeks for seven years, so pinpointing one particular encounter would be implausible. Therefore, the most accurate response that a representative can give is to explain that visit records must be consulted to aid recall (2009).
The adamant presentation using proven interrogation techniques and documents presented as proof may leave the employee flustered and feeling guilty. Admission of a clerical error may be just cause for termination. The employee may have no warning that a compliance activity is being planned (King and Snook 2009). Additionally, these audits are not necessarily preceded by corrective communication from management known as a performance improvement plan. Many employees called to compliance interviews have been top performers and contributors to their sales district’s success.
Pharmaceutical representatives tend to be law abiding because company policy allows for immediate termination of any employee convicted of any felony. These company policies, as examined by this author, indicate that a pharmaceutical representative must have a “clean driving record” (Pfizer 2009). Since most representatives have little exposure to the law or interrogation techniques, they are less likely to have knowledge or experience that would aid in interview preparation. Furthermore, the pharmaceutical employee is trained in compliance and the importance of compliance, and will expect to be treated in a legal and ethical manner (CaféPharma 2008 Eli Lilly).
In his article, “The Psychology of False Confession,” Conti describes personality traits that are used to enhance individual suggestibility to an interview. These factors are unique to interrogative suggestibility. Certain personality and character traits are more suggestible than others. Awareness of these characteristics may help the employee maintain a locus of control when manipulated by the auditor (1999).
Similarly, Conti points out that certain personality traits are more responsive to coercion then others. Any of these character traits or beliefs makes the employee more susceptible to interrogation and its manipulation. These characteristics include: being an extrovert; being trusting; being a pleaser; having low self esteem; having anxiety; having poor ability to recall; and lacking assertiveness (2005).
Blog posts support that many women are targeted by the compliance process (CafePharma 2008 Eli Lilly). Women tend to internalize guilt more then men. Women have been programmed to avoid conflict, and may feel more pressured to agree with interrogation (Forest, Wadkins, and Miller 2002). This will make women less likely to have a favorable outcome if called to a compliance interview.
“Personal issues such as low self esteem and lack of assertiveness may also effect ability to deal with an interrogation” (Conti 1999 24). Unfortunately, individuals returning to work from short-term disability or FMLA may be especially susceptible. Illness, death in the family, and divorce or other personal issues, may threaten the employee’s sense of well-being and lead to low self-esteem and a lack of assertiveness. Having the information that interrogations are an attempt to actively persuade and having the insight into the interrogation process may prevent false confessions (Conti 1999).
In addition to interviewee characteristics, interviewer characteristics also
affect the outcome. Zak and Zak-Dance describe “Crazy makers.” “Crazy
makers” are auditors that employ certain strategies during the interview that are designed to make the interviewee “crazy.” The interviewers may surprise the interviewee with last minute requests. They may pressure employees to commit to something about which the employee is unsure, without appropriate time or data considerations. The interviewer may leverage the relationship (auditor assumed legitimacy) and the interviewee may feel obligated to comply with any and all interviewer requests. Zak and Zak- Dance explain that the interviewee may feel isolated and pressured without access to external consul or data. The interviewer may cycle between understanding and accusing, causing the employee to remain emotionally off-balance (Zak and Zak-Dance 1996).
Although these compliance audits are presented as random examinations, the bloggers indicate this may be incorrect (CaféPharma 2007 Merck). The posts support that the employee is often notified after business hours. The employee is instructed to present him or herself for the compliance audit by 7 am the next morning. This timing prevents consultation with an attorney (2007).
The audit is designed to leave the employee at a disadvantage in every area. They are disadvantaged legally, emotionally, and psychologically. They are presumed guilty and coerced, manipulated and verbally assaulted. They expect reasonable treatment and trust the interviewer and the system. Instead, the employee becomes the target of a corporate sanctioned bully (Field 2009).
In the article entitled “Conducting Administrative Investigations,” the author states that internal investigations may occur for many reasons. Employees may be asked to participate in an administrative, non-criminal interview related to employee misconduct or actions. The employee is required by company policy to participate in the interview. Experiential research supports that this stipulation on employment is usually included in the Employee Handbook. The employee does maintain some rights during an interview and these will be briefly covered. Many employee rights are specific to the state in which the employee resides. Laws that apply to public employees and union members do not apply to employees in the private sector (2005).
Legal Concerns
A brief review of the responsibilities and laws as they apply to pharmaceutical representatives requested to respond to an investigation by their employer is detailed by Mathis and Jackson in Human Resource Management. The rights are few. Namely, the employee does not have the right to an attorney during an administrative audit. However, if the representative is threatened with a fine, the employee should ask if this is a criminal or administrative audit; if it is criminal, the employee has the right to an attorney along with both Fourth and Fifth Amendment rights (2006). Not only is the employee prohibited from having an attorney present during the administrative interview, but also the employee may not bring any other consultant or witness. Parry, Gillespie, and Segrest suggest that the employee handbook may provide information regarding employee investigations. Additionally, employee handbooks may also describe management’s investigation procedure and internal review process (2008).
In addition to information specific to the company, Mathis and Jones explain the “at-will” doctrine that may be helpful to an employee facing a compliance audit. The “at-will” doctrine is a rule of contract law and is determined by each state. The “at-will” rule explains that an employee can quit at any time and an employer can fire an employee at any time and for any reason. Because this is a contract rule, the employee can be discharged without warning, without a hearing, and without a reason. Furthermore, Mathis and Jackson discuss that there are exceptions to “at will” employment that protect the employee from termination (2006).
These exemptions may provide the employee with additional rights and legal recourse in certain circumstances in which it can be proved that violations of prescribed employer behavior have occurred. National law prevents termination consideration in regard to race, color, age, sex, national origin, religion, or disability. Most of the states provide specific EAW exemptions in regard to public policy, implied contract, and good faith and fair dealing. Since the fine points of employment law are particular to each state and every state dictates their own exemptions to stimulate commerce and protect employees, the employee must educate him or herself on the applicable laws (Mathis and Jones 2006).
Case Studies
The literature details a few recent case studies which further inform the state of the compliance activities. One court case highlights the potential for abuse of the compliance systems. Court documents from Dotson v Pfizer describe a Pfizer employee that took FMLA (Family Medical Leave Act) in order to adopt a child in Russia. He had recently received an unfavorable review, and had contacted human resource to discuss it. The human resource manager additionally voiced concern over some samples that Dotson had received. He was terminated on Nov. 11, 2003, less than three weeks after returning from his FMLA absence. Pfizer stated that Dotson was terminated because of the sample starter issue. However, the policy regarding the samples was unknown and Pfizer did not report the sample issue until 2005. Dotson was awarded $733.000.000 and the sample issue deemed pretextual (Dotson v Pfizer 2009).
In this case study, compliance was provided as cause to terminate the
employee. The court upheld the plaintiff’s argument that the cause was pretextual (Dotson v Pfizer 2009).
The second case study, Wagoner v Pfizer, demonstrates the style and
aggressive nature of the compliance interview process. The summary is provided exactly as recorded in the court document:
“On June 28, 2006, Marjorie Wagoner was suddenly summoned to a
meeting at Pfizer’s regional offices near Chicago, Illinois. The meeting
was scheduled for the following day. Ms. Wagoner was not apprised of
the purpose of the meeting. When Marjorie Wagoner arrived at the
meeting, four representatives of Pfizer management were present: Clark
Mohar; Joann Yeksigian, Regional Manager; Larry Guess, Assistant to the
Regional Manager; and Elizabeth Chaudhari, a human relations
department representative. During that meeting, Marjorie Wagoner was
berated and accused of changing and altering dates of certain starter
(drug sample) forms to balance out her daily sales activities. She was
humiliatingly interrogated and browbeaten for hours regarding the false
charges. Ms. Wagoner repeatedly and adamantly denied the accusations,
but that did not stop Pfizer from continuing the attack. At one point,
Elizabeth Chaudhari angrily exclaimed that she did not believe Ms.
Wagoner, though she never explained why. The interrogation was so
intense that it caused Ms. Wagoner to vomit and feel faint at the airport
as she was leaving Chicago that evening” (2008 3).
These important court cases and the available literature support that concern over compliance activities and their repercussions are warranted. To gain further insight into the problem, an internet blog site-based survey
was conducted.
Methods and Design
A survey consisting of five questions was administered via CaféPharma, a six year old blog for drug and medical device sale representatives (Feder 2007). The posts were anonymous and voluntary. The survey was posted randomly on ten company boards: Abbott, Acorda, Amgen, AstraZeneca, Merck, Novartis, Pfizer, Sanofi-Aventis, Schering-Plough and Sepracor. The survey received 108 responses. The Merck site was the most active and had 31 responses at the time the survey was concluded for the purpose of this project. The reported demographics for CafePharma reveal that 94% have at least an undergraduate degree, 38% have some graduate work or a graduate degree and 56% are male and 42% are female (CafePharma 2009 Advertisement).
The survey questions were developed to gather experiential data that
can inform an employee as he/she navigates a difficult interview. The survey sought qualitative data that could be elicited via the use of open ended questions designed to gather a broad range of input as recommended by Rosenfeld. The survey questions used neutral language. The survey included questions on handling the interview, what to avoid, the perceived goal of the interview, and what might be done differently.
These questions asked for experiential recommendations. The questions were developed from research at CaféPharma. Employees actively seek and exchange information about compliance interviews, the survey was developed to answer those questions and address what to expect and how to respond. The survey questions articulated and organized that information. Responses were evaluated on content and frequency. Employee attitudes toward the audit were examined. The grounded theory was used to evaluate the respondent’s attitude to the audit. The responses were coded and attitudes were determined.
Grounded theory is a systematic qualitative research methodology in the social sciences emphasizing generation of theory from data in the process of conducting research. According to the Grounded Theory Institute, Glaser Grounded Theory is “the systematic generation of theory from systematic research. It is a set of rigorous research procedures leading to the emergence of conceptual categories. These concepts/categories are related to each other as a theoretical explanation of the action(s) that continually
resolves the main concern of the participants in a substantive area.”
The first step in this method is data collection. From the data collected, the key points are marked with a series of codes, which are extracted from the text. The codes are grouped into similar concepts in order to make them more workable. From these concepts, categories are formed, which are the basis for the creation of a theory (Glaser 2009).
In addition to the survey, data was gathered for the research project
from other chat room posts and interviews. The complete data set was then
evaluated using the Glaserian comparative method
Results
The data revealed predominately emotional codes such as aggressive mistrust, fear, and feelings of victimization. The data also revealed a large number of responses that could be coded as helpless, hopeless, and powerless.
Chat room posts also produced a small but substantial collection of codes that indicated anger at the posters who had unpleasant dealings with a given company. Other codes relevant to the “counter-posters” included sarcasm, blaming, and compassionless.
Posts and responses concerning solutions and recommendations for those called to compliance interviews were coded as empowered, informed, legalistic, and evasive.
Evaluating these codes highlights that individuals participating in compliance
interviews are very emotionally stressed and this stress leads to feelings of being overwhelmed and ill-prepared to present one’s case in a compliance interview setting. The participants feel helpless and threatened. They feel like they are in an adversarial relationship with their company and that these processes are punitive and designed to intimidate and terminate the employee.
The codes indicate that “counter-posters” are hostile towards the
employee and express the point of view that a person being called to a
compliance interview gets what he or she deserves.
Solution and suggestion coding reveals that being well-prepared for these compliance interviews is empowering. Suggestions such as obtaining legal counsel, not signing any documents, and not admitting wrongdoing again speak to the mistrust reflected by almost all respondents.
Glaserian comparison supports that compliance interviews are high stress procedures that glean power from intimidation, isolation and lack of transparency of the process. The process triggers strong emotional reactions that lead to feelings of victimization and powerlessness.
Glaser research further suggests that the conclusions of a grounded theory regarding these posts about compliance interviews should include details of how that theory has implications for participants in a compliance audit. A grounded theory has implications for participants in the substantive area of research because it emerges from the experiences and emotions of participants in the interviews. The theory is directly aimed at finding the main concern of these participants in a compliance interview and generating a theory of how they behave to resolve that main concern. The research found that within the context of compliance interviews, the main concern of participants was how to prepare for this audit within an environment which constrained them by not being transparent or supportive.
The process which resolves this main concern is that of informing and
supporting participants. This theory has several important implications for
participants within compliance audit settings.
First of all, the observation is that the actions of the interviewer significantly impact the perceptions, emotions and behaviors of the participants. Interviewers, therefore, have a major responsibility for setting the tone or climate experienced by participants within the audit. Through their actions, interviewers exert enormous influence over the attitudes and emotions such as respect, trust, confidence, and credibility. Interviewers can easily contribute negatively to issues or problems if they are unaware of or do not care how their actions effect the perceptions of the participants. Interviewers can directly improve the positive, respectful performance of the audit by being aware of and modifying their interaction and interview style.
Additionally, participants expect that their employers will behave in a respectful and ethical manner thus using the compliance interview as a proactive, educational and corrective procedure, not a punitive, blaming process perceived to end in certain termination. The participants desire more emphasis on a feeling of concern by the employer and wanting to work in a partnership to identify issues and resolve problems.
Thirdly, the participants expressed symptoms that could, if not addressed appropriately, lead to Post Traumatic Stress Disorder (PTSD). Participants note having bad dreams, feeling fearful or numb, and finding it difficult to stop thinking about what happened. Several of the feelings expressed, such as having difficulty concentrating, feeling distant from others, being angry, and losing interests in usual activities, can lead to more problems on the job, even if the participant is not immediately terminated after the compliance audit.
The information gleaned from the participants has generated a comprehensive set of strategies that participants can use in order to prepare for and competently perform in a compliance interview. These strategies are detailed below and are designed to provide the knowledge, behaviors, actions, and best practices to empower participants in a compliance interview. These strategies will enhance the interview experience by providing participants with additional ideas of how to act within the interview setting. Even though participants in compliance interviews may perceive that they may have only limited freedom and ability to devise and implement various kinds of interviewer and environment centered strategies, they should still be aware that they have complete control over participant centered strategies. Preparation for the interview is possible and therefore gives the participant a certain amount of control which may lead to decreased anxiety. A less emotional approach on the part of the participant may lead to a more competent and therefore less devastating experience.
Tips on Managing the Interview
The experiential research and the formal literature review lead this author to formulate the following strategies which are designed to aid an employee called to a compliance interview. The recommendations are based on the survey and communication theory. They seek to minimize exposure to manipulation and limit the potential for abuse. This information seeks to ensure equitable treatment. These recommendations are specific to pharmaceutical sales reps but may be used in any employment situation that has become interrogatory or any stressful communication setting where undue pressure is applied.
1. The sole goal for this communication interchange is to determine the
issues, so the employee should record information, maintain a
responsive and cooperative attitude and only communicate on topics
of which there is a high degree of recall and certainty.
2. All responses should be carefully considered with the knowledge that
any statement may be reflected in a context that could be used
against the employee.
3. The employee should recall interviews seen in the media and borrow
techniques from skilled interviewees such as: Don’t bluff; keep
answers short to reduce the chance for misunderstanding or
misreporting; stay calm; be as natural as possible; regulate voice and
gestures; do not get angry or frustrated; smother emotions of
negativity or acquiescence; remain detached and de-centered (Dance
and Zak Dance 1994. 300).
4. Sarcasm can sound careless and humor can be misinterpreted
5. Request an opportunity to review records and continue the discussion
once documentation is available.
6. Keep in mind that the contents of the interview will not be kept solely
between the employee and auditor.
7. Be prepared for an interview that is psychologically and emotionally
tough.
8. Cope and build a position for future negotiation.
9. Manage emotions, remain calm, listen and respond carefully.
10. Try not to commit to anything (Dance and Zak Dance 1994).
11. Do not sign a document.
12. Request repeatedly: “I need time to review the material.”
13. Make clear the expectation and commitment to review the concerns
identified. Remain firm and calm in the commitment to review the
documents at a later date (Dance and Zak Dance 1994).
14. The secretive and pressured nature of this interview is intentional and
should be interpreted as potentially corrosive (Conti 1999).
15. Prepare to represent yourself as an attorney with no personal
knowledge of the situation (Dance and Zak Dance 1994).
16. Do not consider the information presented, its validity or falsehood of
the claim. This is the time to listen and record, evaluation is later
(Spangle and Isenhart 2003).
17. Respond with genuine interest and concern, because the audit is a
cause for genuine concern.
18. Maintain the “I do not recall” response. Do not struggle to recall.
19. Recall the exact events later with the aid of phone bills, calendar and
other notes.
20. This interview is about clear, complete, accurate data collection:
listen and record.
20. Respond pleasantly and cooperatively.
21. Request any and all documentation they may have in the interest of
clear communication.
22. Politely ask to make copies. If they are provided take them but do
not look at them. If they are not provided, indicate that fact in your
notes.
23. Review the notes immediately after the interview and add anything
that might have been missed.
24. Be a good employee. You will still be stressed, but a good work ethic
and personal integrity will provide the conviction to succeed.
Anonymous
#2 02-03-2010, 04:17 PM
Anonymous
#78 05-27-2010, 10:02 AM
Anonymous Posts: n/a
Re: OEC INVESTIGATION TERMINATIONS- HOW MANY OF US ARE THERE????
--------------------------------------------------------------------------------
HERE'S THE POST FROM GSK:
I am sure that some compliance interviews are for cause- just as many are run for unethical reasons. In any case the individual should protect themselves as much as possible. I thought this may help anyone in this position. Certainily GSK corporation should not get by with a misdeamnor (for improper marketing) and employees interogated like criminals. Best of luck to all.
Abstract
Corporations have a responsibility to their governments, employees and customers to operate using ethical practices. Employees have an obligation to their employers to perform their duties competently and honestly. Today’s pharmaceutical industry appears to have these two groups locked into conflict in the form of compliance interviews. Compliance interviews are delicate situations that can be helpful to employers in managing the workforce and treacherous to the employees. The nature of these proceedings and the effect of these interviews on the employees are explored in this project through social science research methods that will be used to highlight the employee experiences and set forth several hypotheses. The effect of the environment, the nature of the compliance interview, and targeted strategies for the employee are detailed in order to improve the communication in this particular setting.
