A key to climbing the second rung on our ROPE Ladder is to formalize your company's training activities. If your training tools include well-run teaching
by Neil Caesar

A key to climbing the second rung on our ROPE Ladder is to
formalize your company's training activities. If your training
tools include well-run “official” teaching sessions,
you will achieve better comprehension by your personnel, as well as
their appreciation for your overall compliance efforts.

Passing out a memo or policy manual and expecting that personnel
will have time to learn it in detail is unrealistic. At best, they
will keep it handy and refer to it out of necessity when serious
questions arise. But reactive compliance is time-consuming and
disruptive to work flow. It is far better to train a proactive
culture of compliance.

If at all possible, conduct training in a formal setting
conducive to learning. Adequate seating and lighting, effective
visual aids and written reference materials are essential. Your
employees will get the message that the company takes compliance
seriously.

Establish clear training objectives, and explain their practical
relevance. Tell employees that they don't need to memorize all the
rules — but that they do need to have an understanding of the
regulatory scheme, to know where to find answers to their questions
and to understand how it all fits within your ongoing
operations.

Formal training should be broken into short, meaningful
sessions. If all training is packed into one lengthy event, staff
members are likely to lose focus. Outlining by topic area is
another approach. A disorganized presentation that rambles on
accomplishes little.

Consider ending each session with a short quiz. A simple, oral
quiz at the end of a session fosters participation without the
stress of an actual graded exam. True-false questioning, where
students can shout out answers and even disagree, generally leads
to increased participation (once somebody goes first).

Another way to encourage participation is by presenting
hypothetical situations or true accounts, then asking the audience
to offer criticisms and solutions. In one real pre-HIPAA incident,
a student attending school away from home had an HIV test in a
private physician's office that was billed to her father's health
insurance policy. When the father questioned the charge, the office
staff confirmed that it was for an HIV test. The student reported
the physician to her state medical board. Such stories stimulate
thought and discussion, essential components of effective learning
that can build a culture of compliance in your company.

Each session should be planned as a unique occasion. Consider
conducting training off-site, away from the workplace, as a
refreshing break. Provide lunch or even small door prizes (other
than your policy manual). Any of these ideas can create a positive,
yet professional at- mosphere conducive to learning.

It is crucial for employees to receive instruction from their
own staff and supervisors to inspire confidence in their leadership
and in the organization. But it is equally important that they also
see their leaders as students who are willing to learn
themselves.

At times, outside speakers such as lawyers, doctors, accountants
or administrators can offer unique and often stimulating
perspectives on virtually any topic, compliance included.

The ROPE Ladder

Rung 1: Articulate the way you want things to run, and
note how they run now. Then, tweak your systems as necessary to
comply with “The Rules.”

Rung 2: Teach your operating systems to your
employees.

Rung 3: Implement a clear and simple method for dealing
with problems — identify them, report them, investigate them
and fix them.

Rung 4: Give your compliance staff resources to help them
keep up-to-date with internal and external changes that may
sometimes require you to refine your operating systems.

Rung 5: Monitor your operating systems to make sure they
continue to run as you intended.

Neil Caesar is president of the Health Law Center (Neil B.
Caesar Law Associates, PA), a national health law practice in
Greenville, S.C. He also is a principal with Caesar Cohen Ltd.,
which offers compliance training, outsourcing and consulting and
the author of the Home Care Compliance Answer Book. He can
be reached via e-mail at ncaesar@healthlawcenter.com or by telephone at
864/676-9075.