Make Training and Education Mandatory
Set your practice’s compliance program up for success, not failure.
Training is an essential part of any compliance program. If employees don’t know about compliance issues and the applicable laws and regulations specific to their job descriptions, your compliance program will fail. Conversely, if employees understand how the rules affect them personally, they will be more willing to embrace necessary protocols.
Put Your Policy in Writing
To begin, create a written policy mandating training and education. Next, determine who should be trained, the duration of the training, and who should conduct it. Essentially all employees, independent contractors, and agents of your practice or medical organization should be educated in the significance of the compliance program and its operation, including the audit and reporting functions and features.
All employees should know there are consequences for not attending any required training sessions. A policy titled “Training and Education” should clearly explain what these consequences might be. Examples may include a performance improvement plan, corrective action, suspension, etc. The expectations of training cannot be stressed enough. Employees must clearly understand that their employer expects them to attend training throughout the year.
Employees should be provided with a timeline of when the training is expected to be completed. A few days prior to the deadline it’s best practice to send the employee a reminder. At that point, if the timeline has expired and the employee still has not completed his or her mandated training, the next step per the Training and Education policy must be followed.
Make Training Mandatory
Training should consist of overviews of federal and state fraud and abuse laws and regulations, employment laws and regulations, and health and welfare laws and regulations. Everyone must understand his or her role in adhering to the compliance program, including a duty to report misconduct. Be sure to explain the procedures and methods to report suspected misconduct, as well as the conditions of confidentiality (and when/where confidentiality ends). Assure employees they will not be retaliated against for good faith reporting.
Each person should be educated and trained in the specific areas applicable to their department. As soon as possible after their date of hire, all new employees should receive initial training regarding your practice or organization’s compliance program, as well as specific, job-related compliance training.
Require internal and external education and training updates for all staff members at least annually. These updates should include a refresher of HIPAA rules and regulations and your compliance program (with an explanation of how these updates specifically relate to employees’ roles and responsibilities).
Document Training and Continue Maintenance
Document all training. Best practice is to document the date and time of training, provide a brief summary of what was covered, and ask both trainer and trainee to verify their participation with a signature. Employees should understand the expectations of your practice or organization with regard to additional training required to perform their job in compliance.
Your practice or medical organization will need a written directive regarding maintenance and retention of training and education records. Each individual’s attendance at all training and education seminars should be documented and retained in his or her human resource file, as well. During an annual review of employee records, your practice or organization will need to audit these records to ensure the training requirements have been met.
Michelle Ann Richards, CPC, CPMA, CPPM, has 21 years of practice management experience. She has been an auditing and compliance consultant for AAPC since 2009, and was promoted earlier this year to manager, Compliance division. Richards teaches the CPPM boot camp and holds a Bachelor of Science in Health Care Administration. She is a member of the Elyria, Ohio, local chapter.