We have been discussing my Secrets to Effective Training (“SET”) for your compliance program. Prior columns identified four secrets: 1) avoid leadership by memo; 2) lead from the front (commit your leaders to visible training time and efforts); 3) train for the job description; and 4) avoid the “because I said so” training tool. Secret five is: formal training should be formal. Passing out a policy manual and expecting that personnel will have time to learn it in detail is unrealistic. At best, they may keep it handy and refer to it out of necessity when serious questions arise. Reactive compliance is time consuming and disruptive to work flow—it is far better to train a proactive culture of compliance. If your training tools include well-run...