Education and Training:
Today, we are going to discuss education and training as outlined in the OIG guidelines.
Guidelines:
Below, is the list that was outlined on January 17, 2017 by the OIG and team on what they believed was important in the education and training process of Element #4.
- Assure Compliance Training Occurs
- Distill Complex Laws and Regulations into a Format Employees Can Understand
- Assure Workforce Staff is Educated on Compliance Policies
- Assure a Mechanism Exists to Evaluate Employee Understanding of Compliance Responsibilities
- Participate in Continuing Education to Maintain Professional Competence
- Verify Participation in Ongoing Compliance Training Programs is Tracked
- Assure General Compliance Training is Conducted for All Employees, Physicians, Vendors, and other Agents
- Assure Risk Specific Training is Conducted for Targeted Employees
Let’s take a deeper look at this and what the OIG is expecting of companies in measuring the education and training program.
Measuring Your Education and Training Program:
The report has many suggestions on how to measure these points, and I have listed a few ideas for you below in an action plan format:
- Perform an audit to verify that positions deemed to be high risk (coding, billing, and physicians, etc.) are meeting training requirements.
- Test employees after a training to verify understanding.
- Audit training completion rates.
- Conduct document reviews to make sure a training program does exist.
- Verify sign-in sheets or other tracking tools, demonstrate the staff is attending required trainings.
- Review that training plans are updated periodically.
- Perform a document review to determine the extent to which the organization offers CEU’s for compliance training.
- Ensure a process is in place to inform staff of new laws, regulations, policies, and procedures is in place.
- Confirm employees are completing educations requirements according the organization policies.
- Audit files to verify if re-training needs to be done and if it was completed to expectations.
- Survey employees with communication issues or disabilities or language barriers to ensure the education was accessible and understandable.
Questions to Ask:
It is very important to make sure that what you think the organization is doing, is really being understood by the staff. Ask yourself the following questions:
Is your training program being attended by the staff?
Are they meeting the expectation of the facility for understanding the training programs? What is the completion rate of education and training by your staff?
Is staff meeting the expected CEU’s annually?
Are staff demonstrating the new policies, laws, regulations, and training?
After review of the questions mentioned above, now verify your results with facts and documentation. The link to the OIG site as to what to measure and how to measure is below. There is a lot of valuable information in this section and I highly recommend you review them. For more detailed information or if you want to review the what and how’s to measure element #4, the link is https://oig.hhs.gov/compliance/101/files/HCCA-OIG-Resource-Guide.pdf
Background Information:
On January 17, 2017, a group of compliance professionals and staff from the Department of Health and Human Services, Office of Inspector General (OIG) met to discuss ways to measure the effectiveness of compliance programs. The intent of this exercise was to provide a large number of ideas for measuring the various elements of a compliance program. Measuring compliance program effectiveness is recommended by several authorities. This list will provide measurement options to a wide range of organizations with diverse size, operational complexity, industry sectors, resources, and compliance programs.
Should you have any questions or want a consultation of your program, please contact me at karen@bcgdata.net.