Your Compliance Plan is Finalized… Now What? By Cindy Pittmon, CHBME taff training is one vitally important component of any effective compliance plan. Beyond conveying the needed information, effective compliance training should communicate management’s commitment to the letter and spirit of the law. Everyone, but especially owners and managers, must understand that compliance is an ongoing process and not a topic thought of only when a training session has been scheduled. If this compliance culture is achieved, violations will be reduced and managers will be better able to deal with them if they do occur. To Gauge How You’re Doing, Ask Yourself: • how many training sessions have you conducted or attended since the office of inspector general (oig) guidelines for billing companies were established in 1998? • do you do just enough to say, “i did it,” or is compliance ongoing and thorough? • is the training boring and flat, or is it an experience that employees see as valuable in their daily jobs? • do your employees understand why training is necessary? • do you have examples of where training has prevented violations from occurring? if your self-assessment shows room for improvement, what should you do to improve your education process? consider how you convey the laws, regulations, and policies that govern our everyday activities. beyond just conducting training, do your employees understand how this applies to their daily tasks? effective compliance training instills a sense of awareness of possible violations that move employees to ask appropriate questions if they are unsure of a particular issue before they act. they know where to go for guidance and understand that their questions will be appreciated. Employee Training Should, at a Minimum: • introduce employees to your organization’s compliance plan • discuss the components of your compliance plan • review the consequences of non-compliance • discuss your standard of conduct • educate employees to do the right thing • explain where employees can access your compliance plan • identify key personnel who can assist or answer questions regarding compliance but, how do you engage your staff and make compliance more than a book on a shelf? The Following Suggestions May Be Just What the Doctor Ordered: 1. include a compliance tip in your employee newsletters. 2. Keep your training sessions short, but frequent – Kiss – “Keep it simple, stupid.” 3. Post your compliance plan on your company website. 4. get assistance building compliance training sessions with a company such as compliance cartoons. for a reasonable cost, this company can work with you to integrate your policies into cartoons and ensure consistency. 5. acknowledge employees at staff meetings when appropriate. 6. never have a staff meeting without discussing at least one compliance topic. 7. use real life compliance examples. these can be found on the web, on the oig site, or perhaps from S 46 hbma billing • march.aPril.2013
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