When monitoring a high-risk area shows it was never implemented, what should the compliance professional do FIRST?

When monitoring a high-risk area reveals that a program or protocol was never implemented, the foremost priority is to gather factual evidence regarding the situation. Conducting a probe sample allows the compliance professional to assess the extent of non-implementation and understand the underlying issues. This step is crucial, as it provides a data-driven foundation for further actions.

By conducting a probe sample, the compliance professional can identify specific discrepancies, quantify the impact, and gather necessary documentation or evidence. This information is vital for informed decision-making and will serve as a basis for any subsequent steps, such as creating a corrective action plan or determining if legal counsel must be involved. Without this initial assessment, any further actions could be misdirected or premature, lacking the necessary context to be effective.