Development and implementation of regular, effective education and training programs is one of the seven critical elements of a compliance program. The DHHS OIG states, “At a minimum, comprehensive compliance programs should include . . . the development and implementation of regular, effective education and training programs for all affected employees . . . The compliance officer’s primary responsibilities should include . . . developing, coordinating, and participating in a multifaceted educational and training program that focuses on the elements of the compliance program, and seeks to ensure that all appropriate employees and management are knowledgeable of, and comply with, pertinent Federal and State standards.” It further advises that all affected parties “should be periodically trained in new compliance policies and procedures.”
The OIG generally calls for between one and three hours annually for basic compliance training with additional training for specialty fields such as billing and coding. However it provides little guidance as to the recommended or best method for delivering compliance training. It acknowledges that a variety of teaching methods can be used effectively, including using live trainers, as well as computer-assisted training programs. It also recognizes that the use of both internal and external trainers can be appropriate.
Evidencing compliance education and training effectiveness requires addressing two issues: (1) the means of delivering effective programs; and (2) effectiveness in both understanding and acceptance by participants. There are many different ways in which training can be delivered, including the following:
Facilitated Training Using Case Studies
The evidence overwhelmingly suggests that this is the most effective method of delivering effective training. It involves a live qualified facilitator and depends on participation of the audience. This begins with the facilitator describing the function and operation of the compliance program, including going over the Code of Conduct and key compliance policies. The balance of the training can be having participants apply the rules and principles presented to recognizable scenarios or case studies to resolve questionable issues and to determine the best way to report suspected problems. This interactive training is highly effective if a highly trained and skilled facilitator delivers it; however in the hands of someone not properly prepared or equipped for the program, it can have negative consequences. The biggest downside is that the approach is the most expensive type of training. As such, it is most often limited to the initial rollout of the compliance program and to new employees. Refresher training may be delivered by more cost-effective approaches.
Computer-Based or Assisted Training
Computer-based training has been growing in popularity, especially when using professional programs. It offers the best in terms of scheduling flexibility and reproducibility. In addition, many of the companies that provide computer-based training provide periodic updates, which are a significant benefit. Other factors to consider when looking at computer-based training include whether the module comes with assessment tools and its ease of documentation. It is important to shop for the right program at the right price or it could prove to be expensive.
PowerPoint Lecture Approach
Although this is among the most common methods of delivering compliance training, it is among the least effective. The amount of content to address the operations of the compliance program, details of the Code of Conduct, and addressing applicable laws and regulations, almost dictates bombarding people with dozens of slides that can have deadening results. To use this method to obtain any kind of useful results necessitates having someone very knowledgeable on the subject and skilled in presentation. An external lecturer is likely to have higher credibility as an expert, but prove more costly than internal lecturers. In either case, the straight lecture approach has been shown to be among the least effective method and should be used sparingly. This approach is best used to provide more limited information, such as updating staff on changes in law and regulations.
Talking Head Videos
Video presentations are among the least effective means for training and can be expensive in production. Their best use can be to introduce the training program, preferably by the CEO in a personal message. Other than that, they can be counter-productive. If this approach is used, the video should be limited to 8-12 minutes. Evidence suggests that the attention span of participants declines sharply after that.
Another method of training sometimes employed is a written self-study program. It is most often used for specialized training. Positives of this approach include using professionally prepared material, scheduling flexibility, and high reproducibility (important for the training of new hires). In addition, these materials tend to be update-friendly.
Regardless of the training method selected for delivering the training, the question still remains as to how effective the training program was in delivering the messages. This has nothing to do with how many people have been training, but how much they learned from the training. There are two recognized way training effectiveness can be evidenced: (1) have a test at the end of the training, or (2) use questionnaires and surveys taken at a later date to find out how much was retained.
Richard P. Kusserow served 11 years as the DHHS Inspector General and currently is CEO of the Compliance Resource Center (CRC), which provides compliance training and survey tools through the Training Center and Compliance Survey Center. For more information, visit Strategic Management Services, LLC or call him directly at (703) 535-1411.
Copyright © 2013 Strategic Management Services, LLC. Published with permission.