Measuring Compliance Training Effectiveness
from 31 Days to a More Effective Compliance Program Hosted by Thomas Fox
Since at least 2017, the DOJ has emphasized the need for a determination of compliance training effectiveness. In the 2020 Update, it stated under the section entitled, “Form/Content/Effectiveness of Training” the following questions, How has the company measured the effectiveness of the training? Have employees been tested on what they have learned? How has the company addressed employees who fail all or a portion of the testing? Has the company evaluated the extent to which the training has an impact on employee behavior or operations? The importance of determining effectiveness of your compliance program was enshrined by the DOJ in its 2020 Evaluation. The 2020 Evaluation demonstrates the DOJ wants to see evidence of the effectiveness of your compliance program. This is something that many CCOs and compliance professionals still struggle to determine. Both the simple guidelines suggested herein, the more robust assessment and results provide you with a start to fulfill the precepts set out in the 2020 Evaluation, but you will eventually need to demonstrate the effectiveness of your compliance training going forward. Three key takeaways: You must demonstrate you have measured the effectiveness of your compliance training. The DOJ is clearly moving into requiring a demonstration of effectiveness of compliance training. You should be moving towards a model of demonstrating compliance training ROI to validate full operationalization of your compliance training.
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