Compliance Training—Not Just 15 Minutes Anymore
Gone are the days when compliance training could be dispensed through a 15-minute video. The heightened enforcement atmosphere makes it increasingly likely that your program, office or facility will be audited or the subject of an unannounced onsite government investigation.
During such investigations, employees are commonly asked compliance questions such as—who is your compliance officer? What is fraud and abuse? How do you report a compliance problem? Employees must be trained in sufficient detail (and retrained) to be able to knowledgeably answer these and other questions about your compliance program.
Another aspect of training that is often given short shrift is how to spot compliance concerns. Virtually all compliance training will inform employees about the compliance reporting line, but few actually teach employees what to watch for. If your reporting line never gets a call or the calls are largely unrelated to true compliance issues, it is very likely that lacking training is the cause.
Many compliance training programs do not adequately address HIPAA compliance. HIPAA is a significant topic in itself and deserves extra time to ensure that trainees know the basics and who to consult for questions.
But there is more. Contractors who have significant contact with your organization and who provide onsite services must also be trained. Contractors are in a position to circumvent an organization’s best laid compliance plans and procedures if they are not prepared for investigator’s questions and do not know and follow your compliance procedures.
Employees must also be prepared for other aspects of investigations. They should be warned that investigators may contact them at home and that they do not have to agree to such interviews.
The Supplemental Compliance Guidance for Hospitals (published January 21, 2005), specifically addresses training for Board members. In addition to receiving regular reports of compliance activity, Boards of Directors should receive compliance training and updates at least annually. Training for Board members is recommended for all provider types even though it may not be specifically mentioned in the relevant compliance program guidance.
Finally, what is the compliance committee’s role? The compliance committee/officer should identify all of the categories of individuals who should receive compliance training and specify the extent of training required. Some individuals will only be asked to attend the basic level of training (making sure that “basic” training includes the issues discussed in this article). Others will require significantly more training, e.g., coding and billing staff, providers, compliance committee members and managers. The compliance committee needs to ensure that training is offered in appropriate formats and frequencies; it should be possible for all to be conveniently trained both initially and during annual refresher training sessions. The committee must also assure that records of compliance training which include outlines of the training content are maintained and retained whether the training is provided internally or externally.
Make sure that your compliance training is scaled up for the current regulatory environment.