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    Matt Tormey
    Matt Tormey, MCJ, JD
    Every healthcare organization that provides goods or services to federal healthcare program beneficiaries is expected to have a compliance program that includes certain core elements that have been described in detail and recommended by the Office of Inspector General (OIG) for the Department of Health & Human Services (HHS), as well as other governmental agencies.

    One of the core elements of an effective compliance program is regular training and education. But a good compliance strategy doesn’t simply check the box on requirements; it has to be baked into the organizational culture.

    Good training is:
    • Applicable to the audience. Associates should be able to recognize the relevance of the concepts from the training and immediately apply them in their jobs.
    • Engaging. Providing associates with compliance training that is relevant to their job responsibilities and engages them through the application of relevant scenarios will help ensure their interest in excelling in this area at work.
    • Written and/or narrated in plain language that resonates with associates. Those building the educational program should be able to translate the legalese from written regulations into language associates use in their jobs and day-to-day conversations.
    Below are five key actions that are essential to an effective compliance training program.
    1. Don’t just check the box. Similar to what a best-in-class marketing team does, a best-in-class compliance team creates fresh, meaningful and engaging training content that is regularly updated. To be most effective, the training should not be limited to once a year; rather, it should address new and updated policies and procedures or relevant regulatory or enforcement in close to real time. One way this can be accomplished is through periodic compliance “lunch and learns” that are held once a month or once a quarter.
      Violations also can provide a good opportunity for training. The healthcare regulatory and payer requirements can be complex, and mistakes will happen. When they do, associates should be required to complete supplementary education to strengthen associate understanding of the complex rules and regulations.  
    2. Tailor education to the organization and its specific compliance risks. For example, since most, if not all, healthcare organizations handle protected health information (PHI), periodic training that includes the applicable HIPAA regulations and is specifically tailored to how the organization handles PHI can be very effective.  
    3. Incorporate scenario-based learning. Training should — to the degree it’s possible — mimic the real-life experience. Training modules should explain the rules and then give associates scenarios where they can apply those rules. Some scenarios can have obvious answers and others can require more thoughtful consideration. Giving associates a safe place to make mistakes can help them avoid serious workplace errors.
    4. Give associates enough time to do the required annual training, but not too much. It can be tempting to present training modules mid-year and give associates six months to complete them, but inevitably most people will either rush to complete them right away or rush to complete them just before the deadline. Giving associates a few weeks to a month to complete one to two hours of training is more than adequate and will create a sense of urgency without forcing anyone to rush.
    5. Incorporate targeted training into progressive discipline. While the organization’s HR team generally determines the appropriate intervals and severity of discipline, integrating targeted training into this process for compliance program violations can be very effective. For example, requiring compliance training in addition to a verbal warning for a basic policy violation will likely be more effective in mitigating the risk of similar mistakes in the future.
    An effective compliance training program, with relevant educational content that can be integrated into workers’ day-to-day job responsibilities, will add value to the organization. But it can be much more than that. An effective compliance training program is an opportunity for a compliance officer to build credibility and trust with the organization’s associates, allowing associates to feel comfortable contacting compliance with questions and concerns. Any experienced compliance officer knows that a culture whereby associates have this level of comfort is perhaps the most valuable element of their compliance program.
    Matt Tormey

    Written By

    Matt Tormey, MCJ, JD

    Matt Tormey is the chief compliance officer at Ensemble Health Partners. He can be reached at Matthew.Tormey@ensemblehp.com.


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