The existing model of corporate compliance training is complicated. All too often, physicians working at multiple institutions have to complete annual compliance trainings at each one, despite the fact that the subject matter they get trained on is, for the most part, the same across organizations.
In the absence of a federal compliance training infrastructure, some hospitals and health systems are developing reciprocity agreements with neighboring organizations to eliminate this duplication and put physicians back where they ought to be—in clinic, caring for patients.
Among those are University of Texas (UT) Southwestern Medical Center, Parkland Memorial Hospital, Children’s Medical Center Dallas, and Texas Health Resources. Together, they save their physicians about three to four hours in redundant training each year, depending on how many facilities the individual doctor works in.
To help ease corporate compliance consolidation, the AMA House of Delegates adopted policy in June to “encourage reciprocity for corporate compliance curricula between institutions to minimize duplicate training and assessment of physicians.”
Existing relationships are easiest
“Altogether, we train about 25,000 employees on an annual basis,” said Natalie Ramello, chief compliance officer and chief audit executive at UT Southwestern.“That includes everyone—MDs, DOs, midlevels—and they all get trained within 30 days of hire and then again every 12 months.”
The group of facilities was in a position to implement a consolidated compliance training because they were already affiliated with each other. This has enabled each organization to get attestations of completed trainings from the others without too much effort and with reasonable assurance that the data they are getting is accurate.
“I'm not saying you can’t do this without being affiliated, but it's going to be more difficult,” Ramello said.
Still, the content of training is liable to vary from one organization to another. The various regulators requiring compliance training—including the U.S. Department of Health and Human Services (HHS) Office of Inspector General, the HHS Office of Civil Rights, the U.S. Department of Justice, and the Department of Labor—don’t specify what exactly the content should include, and they don’t review trainings before they are implemented.
“The first thing we did was we reviewed each other's content, because there’s always the concern that they could be different,” Ramello said.
This shouldn’t be a huge initial worry, she noted, since many of the core elements of compliance training, such as HIPAA, shouldn’t change from one organization to another. But the lack of required uniformity—where it is feasible to impose it—is a curious inefficiency in what amounts to an unfunded mandate on physicians’ time and resources.
“If institutions could get some sort of federally mandated training, along with a national database showing who has taken it, that would make things much easier on us, because this situation breeds difficulty,” Ramello said. “For example, many physicians are on the medical staffs of competing hospitals. What's the carrot for those organizations to give reciprocity to each other?”
Tips for implementation
Some three years into the process, Ramello suggested the following steps for other compliance officers seeking to consolidate their corporate compliance trainings:
- Connect with your counterparts. “If you have affiliations, you probably already have connections with those individuals, so start with those.”
- Convene a work group. “See if there's enough willingness to come together and have a conversation.”
- Exchange trainings. “This will help you establish consistency across entities.”
- Determine what to do about the differences. “If there's something missing from another organization’s training that you must have, just assign that one part of the training to your physicians.”
- Assign roles. “You’ll need to decide who’s doing the training and the other elements of your reciprocity agreements.”
- Get the word out. “Your marketing team should be able to help with communications.”
Learn more with the AMA’s “Debunking Regulatory Myths” series, which aims to provide regulatory clarification to physicians and their care teams. It is part of the AMA’s practice-transformation efforts and provides physicians and their care teams with resources to reduce guesswork and administrative burdens so their focus can be on streamlining clinical workflow processes, improving patient outcomes, and increasing satisfaction.
