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[Blog Series] 7 Elements of an Effective Compliance Program: Week 4

September 17, 2018
Compliance By Rodney Farley, Director

In this week of our blog series on the 7 elements of an effective compliance program, we will review the importance of conducting effective training and education for staff. Per the Federal Register Vol. 65, No. 52, compliance programs should contain policies and procedures to help employees remain in compliance as they carry out their job duties.

Blog Series: Wee4 7 Elements of an Effective Compliance Program

Just as maintaining licensing and keeping up with continuing education credits (CEUs) is a critical component to measuring an individual's accomplishments and subject matter expertise, compliance training and education serves as a way to measure an individual's understanding of company policies and procedures. When properly implemented, it's instrumental in identifying high risk areas which reduce the likelihood of non-compliant behavior.

Compliance training and education will vary from company to company, but it should emphasize the importance of a company's commitment to conforming to all laws, regulations and guidelines of Federal and State programs.

As outlined in the Federal Register, conducting effective training and education for nursing facilities involves:

  • The proper education and training of corporate officers, managers, and health care professionals, and the continual retraining of current personnel.
  • Sessions that summarize the organization's compliance program, including fraud and abuse laws, Federal health care program and private payor requirements.
  • Specific training on claims development and submission processes, resident rights and marketing practices.
So, let's dive deeper on this element.

Standard 3: Conducting Effective Training and Education

Nursing facilities must take the appropriate steps to communicate organizational standards and procedures to all employees, physicians, independent contractors and other agents. Communication can be accomplished through means of formal  face-to-face training, webinars, e-learning, and disseminating publications and other material that explain policies and procedures in a practical manner.

The OIG describes open communication as “a part of organizational culture and internal mechanisms for reporting instances of potential fraud and abuse.” But, it's important to note that communication goes both ways. While it is the responsibility of nursing facilities to maintain open lines of communication between management and staff, members of staff should feel free and comfortable to report potential compliance issues as they arise. An anonymous hotline aides in the reporting of illegal, unethical or improper conduct when other communication channels may otherwise be ineffective or impractical.

Regardless of the reporting and/or communication channel, nursing facilities should make it clear to employees that retaliation against anyone who, in good faith, reports a possible violation—substantiated or  not—is prohibited.

Why is Compliance Training and Education Important?

Employees, physicians, and other nursing facility personnel need formal and informal training modes of coaching to confirm policies and procedures are correctly delivered and understood. A nursing facility cannot be compliant unless the rules of engagement are effectively taught throughout the organization.

So to wrap up, nursing facilities should:

  • Offer different diverts for learning, keeping in mind the end goal to address all learning styles for everyone in the organization.
  • Provide continuing education to guarantee that the facility and its employees keep current with the laws and regulations.
  • Develop training and communication materials that are easily understood.
  • Ensure that regulatory guidelines are distributed to the right personnel.
  • Create a system and monitor to ensure all employees receive the required education and training.

Watch our video on the seven elements of an effective compliance program and join us weekly in this series as we will discuss each of the seven elements in greater detail, along with implementation recommendations.

Don't forget, HHS-OIG encourages providers to seek help and support as needed from outside experts in billing and coding, legal counsel knowledgeable in fraud and abuse laws, and the comprehensive resources available on HHS-OIG’s website.


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