While It Is Important to Have a Robust Program, Don’t Forget That It Also Needs to Be Effective
The development and implementation of regular, effective education and training programs is one of the seven essential elements for an effective compliance program. Effective is underscored for emphasis, inasmuch as the Office of Inspector General (OIG) uses this term often. In fact, the term and its root form are used 19 times in the OIG’s original compliance guidance for hospitals.
Effectiveness is a factor of outcome. As such, using process data such as the number of people trained is not a measure of outcome but of output. The key question is what the employees learned from the training. This article focuses on evidencing effectiveness of compliance education and training programs.
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The OIG reserves a separate section in its compliance guidance for “Conducting Effective Training and Education.” It states that “the proper education and training of corporate officers, managers, employees, physicians and other health care professionals, and the continual retraining of current personnel at all levels, are significant elements of an effective compliance program…At a minimum, comprehensive compliance programs should include…the development and implementation of regular, effective education and training programs for all affected employees.” It goes on to state that “the compliance officer’s primary responsibilities should include…developing, coordinating, and participating in a multifaceted educational and training program that focuses on the elements of the compliance program, and seeks to ensure that all appropriate employees and management are knowledgeable of, and comply with, pertinent Federal and State standards.”
For live training, the foremost consideration is whether training should be provided internally or by outside experts. To make this determination, factors to consider are level of expertise and understanding of compliance issues by the trainers, level of professional experience in delivering programs of this type, fee charges, travel expenses, and flexibility in scheduling. Notwithstanding the cost factor, buying the program has the advantage in terms of expertise and acceptability by participants.
The means to evidence compliance education and training effectiveness requires addressing two issues: (1) delivering comprehensive compliance training programs; and (2) evidencing that they were effective in gaining understanding and acceptance by participants. In addressing the first part of the problem, it is worth considering not only program content but also identifying the best method to deliver a meaningful training program. The OIG provides little guidance as to recommended or best methods for delivering compliance training — although the OIG does acknowledge that a variety of teaching methods can be used effectively, including using live trainers as well as computer-assisted training programs. The OIG furthermore acknowledges that the use of both internal and external trainers can be appropriate.
Compliance Education and Training Delivery Methods
Facilitated Training Using Case Studies
Experts believe the most effective approach involves a two-tier live presentation by a facilitator. The first part of the program is delivering background information on why and how the organization has proceeded in developing a compliance program. Part of that message must cover why the program is good for employees and management alike. The facilitator then should continue to lay the ground rules of the compliance program, including discussing the development and content of the standards of conduct.
The second half of the program should be devoted to taking recognizable situations and developing them into scenarios or case studies in which participants can apply the standards of conduct to resolve questionable issues and determine the best way to report suspected problems. This interactive training is highly effective if a highly trained and skilled facilitator delivers it. In the hands of someone not properly prepared or equipped for the training, it can have negative consequences. The downside is that the approach is expensive and involves scheduling issues. Such programs also should include lesson quizzes and tests to evidence how well the lessons were learned.
Lecture Approach Using Slides
Another live presentation approach is the straight lecture, often using slides to convey information and lessons. Organizations may chose to either use internal personnel to present the training or turn to outside professionals for assistance. The credibility of the trainer in the eyes of the employees is likely to be higher with outside experts that also provide up-to-date materials. Internal lecturers can draw from their compliance personnel to conduct the training in a lecture/course format. In either case, the straight lecture approach has been shown to be among the least effective methods and should be avoided.
People involved in health care do not react well to someone lecturing them on proper behavior and conduct in the workplace. Particularly deadening are presentations and slides that detail the elements of various laws and regulations that go beyond what most employees would be reasonably expected to understand. Presentations that are not specifically related to workplace issues or to participants’ daily routines are not very effective in communicating how certain rules, regulations, and laws would apply. It is advisable to have someone independent of the presenters administer a test at the end of the program to evidence how much of the lesson was retained by participants.
Talking Head Videos
If live lectures have limited value and appeal to participants, then video presentations can only be worse. Their value and purpose is primarily as a basic orientation or introduction to the compliance training, especially when it includes a personal message from the chief executive officer (CEO). Other than that, it can be counter-productive. If this approach is used, the video should be limited to 8 to 12 minutes. Evidence suggests that the attention span of participants declines sharply thereafter.
Roll Playing Videos
There are a number of advantages of using training videos that involve role playing. It allows you to communicate your message quickly and effectively while holding your viewers’ interest. Unlike talking head videos, roll playing videos present case studies as stories that can hold participants’ interest. It is a convenient delivery method for training because it allows the participant to access the program at anytime and proceed at their own pace, wherever and whenever they want — including at home.
This medium can help the participant to understand issues by observing how others deal with them. Because role play can involve both emotional and cognitive issues, participants can better understand others and the positions of others that are confronted with compliance problems, as well as guide participants on how to analyze and handle a potentially difficult compliance issue. Using professional actors to develop such programs can be very effective but can be very expensive. Having a number of different programs teaching different aspects of compliance further multiplies the cost. It is also important to have some means to test how well the lessons were learned.
Computer-Based or Online Training
Computer-based training is likely to have high perceived credibility from the trainees. It has many of the benefits of role playing videos but at a much lower cost. It is available at any time the participants wish to access the program and proceed at their own pace. It offers the best in terms of scheduling flexibility and reproducibility. In addition, many of the companies that provide computer-based training also provide periodic updates to the content, which is a significant benefit.
In most cases, there are several programs that can be used for target audiences. Other factors to consider when looking at computer-based training include whether the module comes with tools that measure participant understanding of the lessons and ease of documentation. Computer-based training can be very expensive, especially where the charge is on a per-participant basis. It is better to use vendors that offer fixed rate charges for training programs as it allows better control over expenses and will stay within budgeted guidelines. Many such programs offer as part of the program quizzes and tests that not only score and track participants but provide analytical data useful for evidencing the training effectiveness to outside parties.
Another method of training to consider is a self-study program, using recorded and written materials. This is a difficult method of delivery and is normally limited to selected persons. The general workforce is not likely to do well with this approach, especially in populations where English is not the first language or where education levels are low. Care must be taken that the course materials may be so generalized as to be of limited value. Any self-study program will have to have quizzes and tests to confirm that participants actually understood the lessons. The major advantages of this method are scheduling flexibility and ease of assignment to the training; however, evidencing that the training was effective would require a separate testing protocol.
Evidencing Training Effectiveness
No matter how substantive the compliance training materials may be for a training program or the means selected for delivering the training, the question still remains as to how effective the training program was in delivering the messages. This has everything to do with how much participants learned from the training.
You can evidence training effectiveness in two ways. As was noted above, one way is to have a test at the end of the training that evidences participant understanding of the lessons. Care must be taken to ensure the test addresses key compliance concepts and is administered in a credible fashion. It is worth keeping in mind that if the same test is used time and again, it may be compromised and lose all credibility; therefore, if the training uses paper documents, be sure to keep control over them to avoid others having the test questions in advance of the program. Many experts also suggest quizzing participants after each lesson in the program, followed by a test at the end of training. The results of the tests should be kept as part of the participant’s permanent record and maintained by the compliance office and/or human resource management.
A second way for evidencing compliance training effectiveness is through questionnaires and surveys. This can be disseminated separately from training or in conjunction with training as further confirming evidence. The OIG in its compliance guidance makes reference to this type of evidence when it recommends that compliance officers take a “snapshot” of their operations from a compliance perspective.
A knowledge survey asks employees about their understanding of the compliance program and related concepts, as well as other key issues that are included in compliance training programs. As such, knowledge surveys can provide valuable evidence of compliance training effectiveness.
The OIG calls for organizations to not only evidence that the training is received by employees but that employees understand compliance concepts presented in the programs. They advocate no single method for delivering training that is appropriate for every organization or situation. Choosing the appropriate training approach must fit the culture, composition of the workforce, and training needs of the organization. Just as important as selecting a training approach that best delivers your compliance message is identifying a method to measure the participants’ understanding of the training message. This is the key to effectiveness of the training.