by Neil B. Caesar
January 4, 2016

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 official teaching sessions, you will achieve better comprehension by your people, and they will better appreciate your overall compliance efforts. Thus, it is important to formalize your company's training activities. Following are some best practices for conducting compliance training within your organization.

First, 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 team will get the message that the company takes compliance seriously.

Each session should be planned as a unique occasion. Consider conducting training off-site, away from the workplace, as a refreshing break. Consider providing lunch and small door prizes. Any of these ideas can create a positive, yet professional atmosphere conducive to learning.

Second, establish clear training objectives and explain their practical relevance. Let's face it, compliance training sounds boring and can be tedious. So, explain at the outset why training is being conducted. It is okay to say that training is designed to dispel the myths and misconceptions about what compliance really means. Explain to your team that they do not need to memorize all the rules, but that they need to have an understanding of the regulatory scheme and know where to find the answers to their questions.

Third, formal training should be broken into short, meaningful sessions. If all training is packed into one lengthy event, staff members are more likely to lose focus and training will be less effective. Avoid late afternoon sessions if possible, and schedule the simplest material for the "death hour" right after lunch. Frequent breaks with simple refreshments or even a catered lunch provided at company expense help to encourage employees to attend training sessions and remain focused. Shorter, succinct presentations also lend themselves to smoother structure.

Outlining by topic area is another approach. No matter how technically proficient an instructor may be, a disorganized presentation that \uc0\u8232 rambles and rambles on accomplishes little in terms of education or retention.

Fourth, 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 with one another, generally leads to increased participation—once somebody breaks the ice and answers first.

Fifth, another way to encourage participation is by presenting hypothetical situations or true accounts, and 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. Stories like this stimulate thought and discussion—essential components of effective learning that can build a culture of compliance within your company.

Finally, at times, outside speakers such as lawyers, doctors, accountants or administrators can offer unique and often stimulating perspectives on virtually any topic—compliance included. While it is crucial for employees to receive instruction from their own staff and supervisors to inspire confidence in their leadership and in the organization, it is equally important that they also see their leaders as students who are willing to learn themselves.