Written by: Sam Jones
Having a Compliance Officer and a manual with policies and procedures is important, but it only goes so far. The only way a compliance program is put into action is through regular training and education throughout the organization. So, what are the expectations when it comes to training and education for an effective compliance program?
One of the first aspects to consider is the audience being trained. There is a lot of compliance information in policies and procedures, but not all of it directly pertains to each employee on the organization chart. When training frontline employees, it is important to instruct them on the steps in documentation. This is a task they perform repeatedly throughout their day and can easily be a place where mistakes are made. These mistakes can result in coding errors, which can, in turn, cost the organization fines and penalties.
Now, when it comes to training the board, do they need to know the ins and outs of documentation? Probably not. An awareness would be important, so they have a full scope of compliance understanding, but their training will be different. The board’s training may entail more information about conflicts of interest, such as it pertains to the organization looking to make a real estate purchase or hiring a new contractor. By providing compliance education that directly impacts the decision-making process of each segment of the organization, it has a stronger effect and is more engaging for the particular audience.
When conducting training regularly, we recommend a total of an hour each year, but it can be broken into bite-sized pieces, so to speak. This keeps it top of mind and contributes to the culture of compliance in an organization. It is important to document and check the pulse of compliance within the organization regularly as well. Be sure to document when training was conducted, what information was covered, and who attended the training. This information provides clear documentation if OIG were ever to come knocking on the door to see if an organization is being proactive with compliance. Additionally, surveying the staff regarding compliance on a yearly or biyearly basis can provide direction on what areas need greater attention for education or what levels of the organization need more training.
Training and education are the means to translate compliance program policies and procedures into knowledge and action. It is easy to be complacent and repeat the same material over and over again, so stop and think about how these training sessions can be enhanced. Add fun by branding your program (see our blog post on a sticky compliance program), bring in a speaker, or make the training interactive with prizes or incentives. By making compliance training and education something to look forward to on the calendar and not dread, the greater the impact of a compliant culture will be seen.
Most business leaders get frustrated when employees don’t do the right thing. You shouldn’t have to convince people to do what is right. MCA builds a compliance program and a culture where employees do the right thing, the right way, at the right time so you can focus on taking care of the people you serve.
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Midwest Compliance Associates