Kusserow on Compliance: Effective Compliance Training

There is an increased focus on metrics that evidence effectiveness compliance programs, including education and training. Effectiveness relates to outcome or the results of a process, whereas raw numbers of people receiving training are process numbers that leads to output. Output and outcome are not the same. The HHS Office of Inspector General (OIG) compliance guidance notes that “development and implementation of regular, effective education and training programs for all affected employees” is a critical element of any compliance program. The OIG notes that “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.” The problem is that frequency of training, number of people who undergo training, and even training content is not sufficient to evidence outcome effectiveness. The metrics of educating and training really must focus on what the employees learned and retained, not just what they were told. Two issues need to be addressed: (a) the means of delivering effective programs; and (b) evidencing that they were effective in understanding and acceptance by participants.

Compliance Training Methods

Facilitated Training Using Case Studies. The evidence overwhelmingly suggests that this is by far the most effective method of delivering effective training. It involves a live qualified facilitator and focuses on the active participation of the audience. The facilitator can present the function and operation of the compliance program, including going over the basis fraud laws and regulations, Code of Conduct and key compliance policies. The key to the effectiveness is having participants applying the rules and principles presented to recognizable scenarios or case studies to resolve questionable issues and determine the best way to report suspected problems. The biggest downside is that the approach is the most expensive type of training. As such, it is most often limited to the initial roll out of the compliance program and for new employees. Refresher training may be delivered by more cost effective approaches.

Web-Based Training. Web-based training has been growing in popularity, especially when using professionally developed programs. It offers the best in terms of scheduling flexibility. Other factors to consider when looking at this method of training include whether the training includes tracking participation in the program and testing to evidence understanding of the lessons. Some even offer certificates of successful completion of the course. It is important to find the right program at the right price, or it could prove to be expensive.

PowerPoint Lecture Approach. This is among the more common methods of delivering compliance training, but 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 will necessitate having someone very knowledgeable on the subject and skilled in presentation. 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 also among the least effective means for training and can be expensive in production. Its best use can be to introduce the training program, preferably by the CEO in a personal message. Other than that, it 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.

Written Self-Study. 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 questions 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.

Methods of Evidencing Training Effectiveness

  1. At the end of a training session, ask feedback from participants as to how they viewed the quality of training and whether they fully understood the content. This is useful, but alone provides very limited evidence for determining whether participants will retain the key lesson points.
  1. Have a test at the end of the training to see if key lesson points were understood and retained. This will provide evidence that employees understood the lessons, but it is only a snapshot at time of training and does not address long term retention.
  1. Employ a Knowledge Survey at a later date to find out how much was retained. Such a survey taken apart from the actual training is perhaps the best method to determine whether the lessons of the training programs have been retained by employees.
  1. Use all of the above to gain as much evidence as possible about the compliance training programs.

Richard P. Kusserow served as DHHS Inspector General for 11 years. He currently is CEO of Strategic Management Services, LLC (SM), a firm that has assisted more than 3,000 organizations and entities with compliance related matters. The SM sister company, CRC, provides a wide range of compliance tools including sanction-screening.

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Copyright © 2014 Strategic Management Services, LLC. Published with permission.