Training for Compliance

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Since training is part of the FSGO "Seven Elements" model there are many individuals and companies willing to provide related services. There are also, increasingly, regulatory requirements for training in particular topics and definitions of what constitutes "effective " training.


What is "training"?

In California, for example, a state law and accompanying regulations require any company with more than 50 employees in the state to provide its supervisors two hours of sexual harassment training biannually. Besides setting the requirement (and the"carrot" of an affirmative defense to harassment claims for those comply) the regulations also spell out the required backgrounds for trainers, what formats will be considered "effective interactive training'" and specific learning objectives. Learn more

Similarly, the federal and state OSHA authorities have long ruled that their training requirements cannot be met by purely online modules. The participant must also have access to a "qualified trainer" to ask questions, give a "hands-on" demonstration of competence and receive a certificate of completion. Learn more

Other regulatory requirements may include (1) who must be trained; (2) how completion / mastery is documented; (3) frequency; (4) within x days / months of hire or association; (5) a minimum period of supervised field experience before the participant is "trained". The latest Corporate Integrity Agreement with Hill-Rom incorporates most of these. Specialized training of Board members about their role is also routinely required in CIAs.

A recently enacted Texas statute relating to electronic storage of "sensitive personal information" is a good illustration of some of the challenges posed by government training requirements. Effective September 1, 2012 each "covered entity" under the statute is required to provide training reflecting its "particular course of business" and the employee's "scope of employment" about protected health information, its use and access to it. That sounds like "one size fits all" training won't be sufficient. The statute doesn't specify format, length or method of delivery requirements, but it does mandate that the training must be completed within 60 days of hire and repeated every other year. And as part of the training the employee must sign a verification - electronically or physically - of "attendance" at the program. So does this last requirement mean the training must be in person? Or could "completion" = "attendance"?


Government provided training

Some agencies have gone so far as to create and deliver training in topics they consider relevant - e.g. the DHHS OIG provider compliance training in connection with its HEAT initiative - and / or publish it on the Web. The same OIG posted video training (and accompanying materials) - which although aimed as physicians could also be useful in training staff who work with them and or assist in their billing. Similarly, in 2011 California created a series of videos that are required viewing by those charged with reporting elder and dependent adult abuse.

The New York Medicaid Inspector General's office has posted audio and slides from its webinars on various compliance topics. And CMS has long made available extensive training resources in various formats about Medicare, e.g. Guidelines for Physicians at Teaching Hospitals, Residents and Interns. In September 2012 CMS began distributing "Hand in Hand: A Training Series for Nursing Homes" which consists of six one hour videos and an instruction guide aimed at better treatment of those with dementia and the prevention of abuse.

Sometimes government training even comes with the incentive of continuing education credit, e.g. these HIPAA training modules from the Office for Civil Rights via Medscape.


Government Provided Training Resources on the Web:

Federal

State


What others have done about training:


Government Required Training

Compliance

Ethics

Specific Topics

Theories about training

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