Is All This Compliance Education and Training Really Necessary?

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deann bakerby Deann M. Baker, CHC, CCEP, CHRC

There is a difference between education and training, although they are related. Education provides the knowledge of an area, whereas training provides the skills to apply it. Both are necessary and often go hand in hand. Regardless of what we call it, there are times many of us feel overwhelmed by all the compliance assignments, let alone other training assignments. So is it all really necessary, who decides, and how?

Contemplate how you would feel if you learned that the organization you were doing business with did not require their workforce to complete training, perhaps even training required to convey knowledge of current requirements that had to be maintained? What if that company provided you with the general contractor that oversaw the construction of your home? Would you worry about the quality of work or your safety? What would your response be as a customer?

Many of us maintain licenses or credentials, and with that comes the expectation for us to complete a certain amount of continuing education credits (CEUs) within a period of time. The reason behind that is to ensure we remain knowledgeable about our areas of expertise and to protect those we serve in our professional capacity. The consequence for not completing the correct number of CEUs on time is that we lose our license or credentials. When something is important, it typically has requirements that have to be met and consequences when they are not met.  It’s no different with compliance training. Many organizations have chosen to tie completion of compliance training to employee performance evaluations, because it’s that important.

Compliance training is an element defined by the Federal Sentencing Guidelines (FSG) for Effective Compliance and Ethics Programs. Organizations are sometimes evaluated against these standards to determine whether or not they have an effective compliance program. Each element, including compliance training, has culpability scores that define how well or how poorly an organization met criteria.  The FSG states in Section (4) (A) & (B): “The organization shall take reasonable steps to communicate periodically and in a practical manner its standards and procedures, and other aspects of the compliance and ethics program, to the individuals referred to in subparagraph (B) by conducting effective training programs and otherwise disseminating information appropriate to such individuals’ respective roles and responsibilities.”

If an enforcement agency were to evaluate the effectiveness of your organization’s compliance training program, they would assess the percentage of workforce participation and completion of compliance training. This is why compliance training is often tied to workforce members’ performance; it’s intended to incentivize completion of training. What percentage of participation do you think would be deemed an effective training program by an enforcement agency?

Organizations develop training because they value their workforce and recognize the benefits. A great deal of time and effort goes into identifying, developing, and disseminating education and training to ensure the workforce remains aware of the organization’s requirements that have to be met. Some industries are more regulated than others, and thus require more training. Most organizations develop education and training that is role based and for new and existing workforce. Sometimes training may be assigned to address compliance findings. Compliance training helps us be more successful in our roles, because we are able to provide higher quality services in alignment with standards, and this assists our organization in fulfilling its mission. Essentially, everyone benefits from completing compliance training.

Y-Comply, a service of the Society of Corporate Compliance and Ethics, is a compliance-related article delivered quarterly to subscribers via email.

Y-Comply is intended to help communicate the value and purpose of compliance and ethics to the general workforce. You are free to copy this article to your organization’s website or electronically distribute it to your workforce; no attribution to either SCCE or the article’s original author is necessary.