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There is an increased focus on metrics that evidence effectiveness of compliance programs, including the education and training components. Effectiveness relates to outcome or the results of a process, whereas raw numbers of people receiving training are process numbers that lead to output. Output and outcome are not the same. The OIG compliance guidance notes that “development and implementation of regular, effective education and training programs for all affected employees” is a critical element of any compliance program, and 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.” The metrics of education and training must focus on what the employees learned and retained, not just what they were told. Two issues need to be addressed: (a) the means of delivering effective training programs; and (b) evidencing that they were effective in understanding and acceptance by participants.
Delivering Effective Programs
Facilitated Training Using Case Studies. A live, qualified facilitator who focuses on the active participation of the audience is the most effective method of delivering training. The facilitator can present the function and operation of the compliance program, including going over the basics of fraud laws and regulations, the Code of Conduct, and key compliance policies. The key to effectiveness is having participants apply the rules and principles presented to recognizable scenarios or case studies to resolve questionable issues and determine the best way to report suspected problems. However, it is the most expensive type of training and, as such, is most often limited to the initial roll out of the compliance program and training for new employees. Refresher training may be delivered by more cost-effective approaches.
Web-Based Training. This method has been growing in popularity, especially when using professionally developed programs. It offers the best in terms of scheduling flexibility. Other factors to consider when looking at this method of training include whether the training includes tracking participation in the program and testing to evidence understanding of the lessons. Some include tests and quizzes to evidence understanding of the training lesson and certificates of successful completion of the course. However, it is very important that the training include a description of the compliance program, how to contact the hotline, and the Code of Conduct. To be cost-effective, it is important to find the right program at the right price.
PowerPoint Lecture Approach. This is not the most effective method of training, especially when presented remotely. The amount of content needed to address compliance program operation, the Code of Conduct, and applicable laws and regulations, may result in dozens of slides that can have deadening results. Using this method to obtain any kind of useful results will necessitate having someone very knowledgeable on the subject and skilled deliver the presentation. This approach is best used to provide more limited information such as updates on laws, regulations, and organization policies.
Talking Head Videos. Video presentations are also among the least effective means for training and can be expensive to produce. Their best use can be to introduce the training program, preferably by the CEO in a personal message. Other than that, they can be counterproductive. If this approach is used, the video should be limited to 8-12 minutes. Evidence suggests that the attention span of participants declines sharply after that.
Written Self-Study. Another method of training sometimes employed is a written self-study program. It is most often used for specialized training. Positives of this approach include using professionally prepared material, scheduling flexibility, and high reproducibility (which is important for the training of new hires). In addition, these materials tend to be update-friendly.
Regardless of the method selected for delivering the training, questions remain as to how effective the training program was in delivering the messages. This has nothing to do with how many people have been to the training, but how much they learned from the training.
Methods of Evidencing Training Effectiveness
- Ask for feedback from participants as to how they viewed the quality of training and whether they fully understood the content. This is useful, but alone provides very limited evidence for determining whether participants will retain the key lesson points.
- Have a test or quiz at the end of the training to see if key lesson points were understood and retained. This will provide evidence that employees understood the lessons, but it is only a snapshot at the time of training and does not address long-term retention.
- Employ a Knowledge Survey at a later date to find out how much was retained from the training. It is perhaps the best method to determine whether the lessons of the training programs are being retained by employees.
- A best practice is employing all the above to gain as much evidence as possible about the compliance training programs.
For more information on this topic, contact Suzanne Castaldo, JD, CHC at email@example.com.
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