By Shawn Willey
From Compliance Today, a publication for HCCA members
As a compliance officer, arguably the most important task on your calendar is the company’s annual compliance training. It’s an ideal time to educate and review laws, regulations, and company policies that apply to day-to-day responsibilities. As compliance officers, we’re giving everyone the tools necessary to help maintain a respectful work environment and to be able to detect and avoid violations that could lead to legal issues.
Spectrum Medical Group’s 2015 Annual Compliance Training was my first go-around as the champion of the training. Many things went right, but there were also many ways to improve. 2015 was certainly a “live and learn” year for me.
Whether your training has been a success in the past or not, it is a good idea to assess whether your training process still makes sense. Is the way you are handling the training the best way to reach everyone? There is no “one size fits all” way to conduct your annual compliance training, but here are some things you might consider.
Has your company grown in the last year to the point where the training method you’ve used for years isn’t feasible? Was your company, at one point, small enough to gather everyone at one place at one time? Is it possible to do a little bit of both? Some organizations, such as Spectrum, have a mixture of office and hospital-based practices. It may be worthwhile to visit the facilities you can, to keep that personal interaction as much as possible, but conduct the training online for the practices that are spread out.
Multiple sites and hundreds of employees make face-to-face gatherings with everyone difficult (like “not enough hours in the day” difficult). It’s easier and more time effective to send out trainings via email. One drawback to emailing the training is confirming that everyone completes the training. Due to the lack of personal interaction, employees could be simply casting your email aside with the dozens of emails they receive each day, thinking they’ll get to it eventually; but, in the end, you’re reminding them weeks later to conduct the training (Yes, I am speaking from experience).
If online training is the best route for your company, a possible way to minimize the chance of your email getting ignored was given to me via HCCAnet’s site. I was running into the problem of some employees dragging their feet in regard to reviewing the training. After multiple reminders, by both myself and the practice managers, I decided to try making a post on HCCAnet to see if anyone else has run into the same issue. Sure enough, a short time later, I received a response from Donna Gosselin, Director of Corporate Compliance and Quality at Maine Veterans’ Homes, that gave me this idea: Have a designated individual (per site or specialty) who is responsible for 100% completion for their group. Donna told me it worked quite well for her organization with six sites and 1,100 employees. An extension of that thought would be to find someone you know is well respected within a certain facility or specialty (i.e., physician or support staff) to champion the compliance message. If that person is well respected among their peers, they may be more successful in getting the training completed on time. An added bonus is “elevating” the importance of compliance training and supporting the message that compliance starts at the top.
Timing is everything
There is no right time conduct your compliance training, but you want to get the most bang for your buck, in regard to getting the word out with the least amount of time and effort. Is the release of the training time-appropriate (e.g., right before a holiday or a popular school vacation)? These time periods won’t get the quickest return, leaving your email buried in employee’s inboxes upon return from time off. A time that makes the sense is if your company celebrates Corporate Compliance and Ethics Week.
Releasing the training during this time makes sense for multiple reasons, one being that you’re talking about compliance for a week straight, whether it is face-to-face, online, or by email—people’s minds are in compliance mode.
No matter how you handle the training, if the employees think they are on an island in regard to understanding compliance and the guidance of company policies, the whole point of the training will be wasted. Right from the start, it needs to be conveyed that everyone necessary, from the Compliance & Risk departments, all the way to the upper management, is available if someone wants to voice a concern or report an incident. If you are conducting the training online, at the end of each subject, add a section for the employee to ask questions, or list contact names, titles, and links to their emails. This will ensure that the trainee is given ample opportunity to contact those in the know for any question or concerns. Another way to help would be to get someone from upper management (e.g., the president or CEO) on video (or even in-person, if possible) to do a short speech prior to the training that can be shown online or during in-person trainings. Have them introduce themselves and mention how important the training is and why everyone does it. This shows that everyone in the company, even top management, understands the importance of compliance and participates in the trainings. After all, people are more willing to buy into an idea or culture if it is practiced from the top down.
There are the basics to be put in every training—HIPAA Privacy & Security, False Claims Act, Conflict of Interest Policy, etc.—but does the training need to stop there? Including risk topics (e.g., disruptive behavior) as well as including billing and coding and OIG updates (directed to those who need to review it) for the approaching year would be an efficient way to include everything employees need to be aware of, without sending multiple trainings an employee’s way. It also saves you from having to keep track of multiple trainings annually.
The training, whether it is in person or online, can be presented in many ways. Everyone’s learning style is unique. PowerPoint, online training sites, hand-outs, demonstrations, and real-world examples are all good ways to get your point across to everyone. If your training is computer-based, and if you have the time (and a volunteer to do it), using a voice-over training style much like a webinar could work. Some people like to go at their own pace and would simply turn down the volume, while others feel as though they still have that personal interaction.
Post –training review
Once the training is complete, a great way to review the process is to connect with everyone who had a hand in producing the training and discuss what were successes and what can be improved upon (also referred to as a “lessons learned” meeting). It’s best to have this meeting shortly after the training, when the process is still fresh in everyone’s mind. You can also ask a few well-respected people within the company for their opinion and what the views heard from others were. If you only hear from those who assembled the training, you are potentially missing out on some great ways to improve it.
A company’s annual compliance training may be the most important task on a compliance officer’s calendar. Creating and presenting the training the right way takes planning and a group effort. If done correctly, you will be providing employees with the proper tools to be proactive and mindful in the workplace.
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Shawn Willey (email@example.com) is a Compliance & Risk Specialist with Spectrum Medical Group located in South Portland, ME.