One of the critical elements of an effective compliance program is education and training. Evaluating your education and training program is essential for performing a compliance program effectiveness review.
For example, in their compliance guidance document, HHS OIG prompts compliance programs who are evaluating their training efforts to ask themselves if they “seek feedback after each session to identify shortcomings in the training program?” And whether the program will “administer post-training testing to ensure attendees understand and retain the subject matter delivered?” Similarly, the U.S. Department of Justice, in their guidance on evaluating compliance programs, asks, “Has the company evaluated the extent to which the training has an impact on employee behavior or operations?” So, you may agree it’s essential to evaluate your compliance program’s training effectiveness, but you don’t know exactly how to proceed.
Here are some tips and resources to help you get started:
- Get the ASTD Handbook for Measuring and Evaluating Training. 1st edition. (Patricia Pulliam Phillips, editor). American Society for Training & Development, 2010.
This handbook is a great place to start for people who are just beginning with a formal evaluation of training programs. The book outlines steps for planning your evaluation before diving into techniques such as using surveys and questionnaires, designing a criterion-referenced test, conducting interviews and focus groups, using performance records, using statistics in the evaluation and analyzing qualitative data.
- Utilize the OIG’s resource guide titled, “Measuring Compliance Program Effectiveness.”
This document helps evaluate all aspects of a compliance program, but section 4 (pages 23-31) focuses on examples of measurable training aspects. For example, measure 4.40 suggests that you can survey employees to determine the effectiveness and level of understanding of the material presented, conduct post-training evaluations, and review and track questions and disclosures made following the dissemination of information and education. Another measure, 4.28, suggests reviewing department meeting minutes and conducting random staff interviews to determine if first-line managers discuss compliance obligations with their direct reports and that staff understand specific compliance requirements associated with their job.
- Search the scholarly literature.
Some scholars research and publish best practices on training within organizations. And you don’t always need to be affiliated with a university to get access to their publications. For example, you can search on Google Scholar or other similar search engines that often return publicly available results. An example of what you might find is an article I found titled “The Science of Training and Development in Organizations: What Matters in Practice,” published in the Psychological Science journal in the Public Interest section. One of my favorite lines from the article is, “The research on training clearly shows two things: (a) training works and (b) the way training is designed, delivered, and implemented matters.” Other journals that publish similar research and content include the Journal of Organizational Behavior, Journal of Educational Measurement, and Educational and Psychological Measurement.
- Hire an Expert.
If you’re not up to personally evaluating the effectiveness of your compliance training efforts, many firms specialize in training, and plenty of consultants are experts in evaluating training program effectiveness.
To Evaluate Yourself or Hire Out
Evaluating the effectiveness of your compliance program’s training efforts is an important expectation for any compliance program. If you’re up for performing the evaluation yourself, I've provided some sample resources, including a handbook, an OIG resource guide, and examples from the scholarly literature. And, if you’re not up for tackling this important task yourself, you can always turn to firms or consultants who are experts in the area.
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