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.
