Five Basic Guidelines for Compliance Program Education
December 18, 2017
In the October 2017 issue of Compliance Today, the monthly magazine of the Health Care Compliance Association (HCCA), Mary Ellen McLaughlin, MS, CHC, CPC; and Shawn Seguin, MBA discuss the elements that make an effective compliance program. One of the most important, they insist, is education.
Start the Training at Orientation
McLaughlin and Seguin share that “staff education is a significant element in the success of a compliance program.” For them, it is important to start newly hired staff off immediately with an understanding of their compliance responsibilities, and they offer that “compliance and privacy modules must be included in the new employee orientation program.”
Pay Attention to Tone and Delivery
The training program itself should be makes sense to employees regardless of their level and broadly applicable to whatever work situations may arise. The authors insist that healthcare organizations ensure the “training should be comprehensive but easily understood by all employees.” Attention must also be paid to delivery format and tone, to avoid any negative impressions. McLaughlin and Seguin remind compliance officers that any compliance education “should never be delivered as a lecture and should not come off as punitive and harsh.” Better yet, everyone benefits when compliance education is “presented in an engaging and inclusive manner that aligns itself with the organization’s culture.”
Establish an Annual Training Program
The authors remind us that “one hour of annual compliance training is recommended by the OIG.” They suggest choosing an online program that allows for some degree of customization or augmentation to match an organization’s unique environment. Care must be taken, however, to ensure that one doesn’t “inhibit one-on-one interaction between the Compliance department and staff.”
Maintain Training Records
McLaughlin and Seguin insist that “some type of record must be used to account for the staff training” and suggest that “compliance and HIPAA training should be linked to the annual evaluation process.” Perhaps, they offer, an “employee’s monetary compensation should be tied to training attendance to ensure participation” and completion.
Test for Training Effectiveness
The best way to determine whether learning has occurred is to test on the material covered. The authors advise, “you should also provide a short quiz during each training session in order to test the effectiveness of the training.” These test serve a dual purpose—in addition to ensuring knowledge has been gained, “the quiz can also be filed and used to support program effectiveness if a governmental investigation ever occurs.”
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All quotes are taken from:
McLaughlin, Mary Ellen and Seguin, Shawn, “What It Takes: An Effective Program,” Compliance Today, October 2017, (pp. 30-34).