Harmony Healthcare International (HHI) Blog

Compliance Series - 7 Elements: #3 Education and Training 2019



Compliance • Audits/Analysis • Reimbursement/Regulatory/Rehab • Education/Efficiency • Survey


training.pngAs a continuation of the 7 Part Blog Series on Compliance, today we will explore Education and Training. 


  1. Policies and Procedures
  2. Reporting and Investigating
  3. Education and Training
  4. Prevention and Response
  5. Auditing and Monitoring
  6. Responsibility/Oversight of Compliance Officer/Committee
  7. Enforcement, Discipline and Incentives 

Education (Distill and Synthesize)

One cannot expect compliance unless the rules of engagement are effectively taught to the team.  Education and Training encompasses the expectation that the organization provides ongoing, competency-based instruction on the laws, regulations and changes that define the ethical and cultural parameters of the organization’s essence.   We have all heard the quote from an unknown author originating back in 1996:

CFO asks CEO: “What happens if we invest in educating and training our people and they leave?”
CEO to
CFO: “What happens if we don’t….and they stay?

At this juncture, the quote may seem cliché.  Yet, take a moment and assess your surroundings….how much education and training occurs at your facility? Does your team know the 18 elements of PHI? Do they know what PHI acronym represents?  Information is readily available on the internet, which is super helpful.  Information is readily available on the internet, which is super time consuming. 

Patient-Driven Payment Model (PDPM)

It is incumbent on the organization to provide the necessary information to all employees in order to abide by the rules that govern operations in the healthcare entity. The information is fast, unending and complicated.  To that end, it is critical for the organization to “distill and synthesize” all relevant material in a user friendly manner.  The advent of technology is accompanied by a false sense of effective communication and training; via a press of the send button with an attachment of a 146 slide PowerPoint filled with the latest rules and regulations.  Employees, physicians, vendors and other agents require formal and informal modes of training to ensure the information is properly delivered and understood. 

In the world of compliance, educational content ranges from teaching staff the actual policies and procedures to teaching staff the rules, regulations and laws that define the subject matter.  Understanding “Why” is super helpful for assimilation. 

Why is PHI (Protected Health Information) confidential?  Of the many reasons, one major motive is to prevent fraudulent billing. Once the employee understands the why, compliance is better achieved.

The Goals of the Education and Training include:

  • The distribution of regulatory guidelines and materials to all relevant staff and vendors.
  • Establishment effective training modules with competency mechanisms. (i.e., post-test).
  • Distill and Synthesize the information to be easily understood and
  • Offer multiple channels for learning (in class, on line, newsletters, contests, posters, etc.) in order to address all learning styles.  
  • Implement a tracking system to monitor that all employees are included.
  • Participate in continuing education and Industry Events (harmony19) to ensure knowledge of the current facts and governmental expectations. 

In closing, education and training is a significant element for your compliance program. Lack of knowledge or unawareness is not an acceptable excuse if under a governmental review. A False Claim results when the government determines: 

  1. The provider had "actual knowledge of the  information" or
  2. The person acted in "deliberate ignorance" of the truth or the falsity of the information, or
  3. The person or provider acted in "reckless disregard" of the truth or falsity of the information. 

As always, I hope this helps with your quest for compliance!!


Harmony Healthcare International (HHI) is available to provide assistance You can contact us by clicking here. Looking to train your staff?  Join us in person at one of our upcoming Competency/Certification Courses.  Click here to see the dates and locations. 

harmony20 October 29-30 2020 Encore Boston Harbor

Topics: Compliance

Kris Mastrangelo, OTR/L, LNHA, MBA


Kris Mastrangelo, OTR/L, LNHA, MBA

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