Here is some sample language on employee education and training that can be used to develop an education training policy as part of your overall compliance program and policies:
- All employee training shall include an overview of compliance policies and procedures for implementing the policies, focusing on the policies and procedures applicable to each employee’s job responsibilities; procedures for reporting compliance violations, including the use of the compliance hotline or other available reporting mechanisms; and the disciplinary system;
- All compliance program training documents including, but not limited to, lists of attendees, dates of training, and agendas or program descriptions shall be retained in the compliance filling system;
- [PROVIDER] may provide to employees all relevant fraud alerts and advisory bulletins issued by the OIG, or summaries or relevant points from fraud alerts;
- [PROVIDER] shall post a notice detailing it commitment to ethical standards and compliance with all applicable laws and regulations in the conduct of its business;
- [PROVIDER] shall use payroll stuffers and electronic communications (as appropriate) to inform employees of changes in applicable federal and state laws and regulations; and
- Employees shall be told that they can obtain additional compliance information from the compliance officer. Any questions that the employee’s immediate supervisor or the compliance officer cannot answer shall be referred to the [board of Directors, owner(s)] and/or legal counsel, as applicable.