Best Practices for Creating a Healthcare Compliance Training Program
January 22, 2019
This post excerpts our article, “Building an Indestructible Healthcare Compliance Training Program,” based on a webinar led by experts from HCCS, A HealthStream Company.
Many healthcare organizations consider compliance to be a major headache and ask themselves why they spend so much time and energy on this function. That’s the reason it is important to remember that compliance programs are mandatory; Section 6401 of the Affordable Care Act (ACA) states that every “provider of medical or other items or services… shall establish a compliance program as a condition for enrollment in Medicare, Medicaid, or the Children’s Health Insurance Program” (CHIP). Training and education makes up one of the seven essential elements of an effective program, as stated in the U.S. Sentencing Guidelines, with additional guidance available from the Office of Inspector General (OIG). Also, training is typically a key requirement in an integrity agreement (IA) or corporate integrity agreement (CIA) that results from the government settlement of an organizational healthcare compliance violation.
Effective compliance training that incorporates the four key principles below can help employees understand their obligations and make every staff member an extension of the compliance team.
Principle 1: Create a Culture of Compliance
Christine Thomas, Manager of Content Development at HCCS, shared that compliance training “helps to communicate the tone from the top, especially the commitment to compliance, which influences the overall culture of your organization.” Compliance training can foster better communication between staff and your compliance office, particularly if training occurs face-to-face. Even in online training, learners can get a sense of who your organization is and that you welcome their input. In this way training helps staff to become your eyes and ears—you train staff to detect suspicious behaviors or activity and to know what to do when that occurs.
Principle 2: Understand the Power of Proof
Thomas mentioned earlier that many healthcare organizations make the completion of annual compliance training and review of the code of conduct a requirement for pay increases and sometimes for continued employment. A system that tracks completion of required training plays a strong role in effective compliance programs. Thomas offered that anyone who has had to work under an Integrity Agreement or Corporate Integrity Agreement can attest to the power of proof of training, especially if the OIG wants verification of training completions. She suggested, “Maybe you're getting audited or suddenly receiving subpoenas from the government and suspect there may be a whistleblower case—that is where all your hard work with training is going to pay off.” Robust training as part of a proactive compliance program can help to lessen the damage in the event that there's an enforcement action.
Principle 3: Incorporate Adult Learning Principles
Debbie Newsholme, Senior Director of Content Development at HCCS, reminded us that “the first element of any kind of adult education or training is to ‘Know Thy Audience.’” That means we must take into account the huge variety of individuals working together in any kind of healthcare setting. Newsholme suggested that we “think about the literacy level of your learners and that the average reading and literacy level is about the seventh or eighth grade. “ Other audience attributes that merit attention are the five generations currently working in healthcare and their different learning styles, as well as different cultures and ethnicities that bring different sensitivities to the workplace.
Principle 4: Make Compliance Training Engaging
HCCS Compliance Courseware Developers Debi Hinson and Kathleen Greene-Batt had plenty of advice for making compliance training more engaging, and emphasized new ways to think about the training experience. They suggested using the following key elements:
- Adaptive Learning Relatable Characters
Download the full article here.