Complying with Communication Training Demands
Jeannine LeCompte, Compliance Research Specialist
Communication training in a Skilled Nursing Facility (SNF) environment—a process which must be in place by November 28, 2019—entails ensuring that all facilities meet certain requirements in communication training programs for their direct care staff. A SNF must ensure that specific compliance training is provided to employees designated to be in high risk administrative positions such as those involved in coding and billing, and also to physicians and nurses. If appropriate, the SNF must offer Continuing Education Unit (CEU) credits to ensure compliance.
The facility must also establish a process to communicate and provide training to employees on new laws, regulations, policies, and procedures. This must be included in all education deployed throughout the organization.
The compliance training programs must address specific risks identified within given job families, that is, groupings of jobs related by common vocations/professions.
It is also important to ensure that the SNF always fully evaluates policy and compliance failures and provides re-education to applicable staff. In this regard, the organization must track all disclosure reports (hotline calls and direct contacts to the compliance department) to ensure that the education is effective at raising employee awareness of specific areas of vulnerability.
The training plan must be regularly updated to address new laws and regulations, and the most effective method for compliance education should be used. Training must also comply with the regulations governing accessibility for those with disabilities or language barriers.
The effectiveness of compliance education must also be continually evaluated though the use of post-training tests or evaluations. In this regard, the SNF must solicit feedback from employees on compliance training needs.
Finally, the organization must ensure that all documentation of education provided is retained for inspection.
