Chapter 3: Running an Effective Compliance Program

Resource: Designing Your Annual Compliance Education

  1. Determine the theme that will weave the components together in your training.

    1. You will have to cover the same topics every year. Very little will change. Therefore, the way that you deliver the education should garner and keep the attention of your audience. Consider current events, organizational core values, or a specific risk as your theme.

  1. Obtain a copy of the latest compliance and education risk assessment.

    1. Highlight the items that can be reinforced within the annual education. Keep in mind you can bring awareness to these items, but annual education should not be used as the sole source of high-risk education.

  1. Determine the elements that must be covered in each annual compliance training. These elements should include but are not limited to:

    1. Mission and Vision

    2. Core Values

    3. Standards of Business Conduct Overview

    4. Conflicts of Interest

    5. Fraud, Waste, and Abuse

    6. How, When, and Why to Report Wrongdoing

    7. The Identity of the Chief Compliance Officer

    8. The importance of following policies, procedures, and regulations

    9. Accurate Documentation

    10. Privacy and Security Overview

    11. 7 Elements of a Compliance Program

    12. Workplace Culture

  1. Develop three (3) outlines based on workforce level within the organization: Workforce (staff level), Leadership (management and above), and the Board. An optional role could be volunteers. Ensure you develop the education based upon the needs of each role.

    1. Determine how the risks and annual elements in items 2 and 3 will be categorized under the different components of the theme. This will serve as the sections of your training. For example:

      1. Suppose your theme is organizational core values and integrity is one of your core values. Two items that can be categorized in this section are conflicts of interest and Fraud, waste, abuse.

  1. Devise an outline of how the education will be delivered to include elements and final method of delivery.

    1. Examples of delivery methods are modules in the learning management system (LMS), web link, and live training.

    2. Confirm that method(s) used allows for completion tracking.

  1. Determine within your outline which high risk areas will be used for the focused games, questions, or trivia you may incorporate into your training. This will help your learner further digest this needed content. The high risks will be pulled directly from the risk assessments mentioned in item 2 above.

  1. End with a required signed (electronic or hardcopy) acknowledgement.

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