Training: Content, Timing, and Effectiveness
Understanding that training and education (T&E) are critical in contributing to the overall implementation of a compliance program, I am often asked what are focus points that those who are developing compliance T&E content should consider. This is a very good question and like many good questions it invites a variety of responses. I like to share that among the many possible focus points, the following areas should be assessed so that their design can help in the creation and development of T&E that is useful and meaningful.
This essentially answers the question of “what” should be contained within T&E modules or sessions. This is going to vary between organizations based on factors related to the organization’s business operations, its size, and the regulatory oversight directed towards the business, to name a few examples.
At the same time, there are three specific types of content that I suggest all organizations include in their T&E inventory. These include an introduction and review of the organization’s Code of Conduct, information on how to report suspected violations of the organization’s Code of Conduct or policies and procedures, and that workforce members understand that they should have no fear of retaliation related to their good faith reporting efforts.
With respect to timing, most organizations implement at least two T&E schedules. The first relates to new members of the organization and often is described as part of what is referred to as “New Employee Orientation”, “NEO”, or some other label. This is critical as it first off lays out from the beginning to each new employee what is expected of them as members of the organization. Another aspect which sometimes gets overlooked but is also very important is that T&E received during new employee orientation provides a powerful first impression of the organization’s commitment to T&E as well as to its compliance program.
Determining the effectiveness of T&E is much easier said than done. One of the most significant challenges with respect to effectiveness is identifying what is available or what can be developed to measure the effectiveness of training. In addition, what is meant by “effectiveness” can also be a challenge in and of itself. Does it mean that people are retaining the T&E? Does it mean that desired behaviors related to T&E are observed? Does it mean that processes are reflecting that people are performing their jobs in accordance with the guidelines presented through T&E? The list can go on and on. My point here is that when developing T&E content, developers should also consider identifying how or what can be used to assess the T&E’s effectiveness.