The focus of this element is providing all employees with training and education that highlights the organization’s compliance program and its commitment to compliance with professional standards, laws and regulations.
Employee training and education is a huge and vital component of your program so it is important to be innovative and relevant. In most offices, there are four generations working together in one place. A good tip for the trade is to use blended-learning techniques which means mix it up. Use a variety of training options to address the various learning preferences of your audience and your organization. Develop an overall program comprised of seminars, webinars, classroom instruction, self-guided computer tutorials, videos, surveys, e-mail reminders and so forth. Checking-the-box type training is not effective. The goal is to get the message out and understood by all.
It is not the Chief Compliance Officer’s responsibility to be the only expert on the rules and regulations. In fact, it is the CCO’s function to ensure that the employees are following the rules and actively engaged in correcting deficiencies. The officer is leading an enterprise strategic program which drives a culture of ethics. The more employees are empowered to mitigate risks to the organization through education, the less likely serious problems will occur.
Below is a list to help you assess your current training and education program:
- What are the top training needs?
- Reference results from annual Risk Assessment
- News and association alerts
- Conduct employee survey
- Identify employees by the following educational needs:
- General Compliance Training
- Specific Compliance Training
- Based on department needs
- Based on rule/regulation
- Vendor and Contractor Training
- Customer Training
- Board of Director Training
- Compliance Committee
- Community Training
- Assess, Determine, and Develop content of Training
- Can use canned courses and tailor to company business model
- Mix explanations of rules and regulations with real life or hypothetical case studies along with quizzes
- Determine Frequency of Training
- New Hire Orientation – within 90 days of hire, within 30 days of hire
- Annual – Calendar Year/Fiscal Year, a rolling schedule by department
- Determine Modes of Training and Communication (Must use blended-learning techniques)
- Intranet Alerts
- Town Halls
- Team Meetings
- Broadcast blasts
- Video vignettes
- YouTube or Corporate videos
- Compliance & Ethics Week
- Guest Speakers
- Annual conferences for CEUs or live class training
- Classroom instruction
- Online courses (Self-guided)
- Roll out or update polices/procedures/standards of conduct
- Determine who are your trainers?
- Chief Compliance Officer
- HIPAA Privacy Officer
- IT Security Officer
- Safety Officer
- Human Resources
- General Counsel
- Department Managers
- Third Party Vendor
- How do you track required training?
- Online via Corporate University
- Online via employee self-service – part of performance evaluation requirements
- Collect individual course attestations
- Collect attendance sheets with signatures/title/date/duration of course
- Collect instructor/course evaluations
- Watch for patterns of non-compliance and complaints (indicator of training effectiveness or potential needs)
TIP: Go to your associations for tools and templates. Connect with other compliance professionals for advice. There are many tools, vendors and consultants out there in the field. You are not alone, and this is not an impossible situation. Failure on implementing a compliance & ethics problem is simply not an option. The stakes are too high – Compliance is everyone’s job, and every employee must do their part. NEVER STOP TRAINING….
We hope you are enjoying this building-block series of articles which started in 2013. If you are joining us for the first time, please check out previous compliance blogs. If you are seeking a full comprehensive guideline, Click here to view RevSpring’s webinar – “Building a Transformational Compliance Program.”