By Lauren Barnett
Compliance Content Specialist, PharmaCertify
As a compliance trainer, I faced the challenge of convincing my learners that their training involved more than just a bunch of regulations that had little to no relevance to individuals. So the recent stories of the government actively pursuing individuals as a result of investigations of their companies caused me to wonder: will these “real world” examples of how regulations can impact them personally have an impact on how the learners view the importance of the training?
Then, just as quickly, the words of a former trainee came to mind, “I’m so glad you didn’t give us the orange jumpsuit lecture.” And with that thought, I was brought back to reality. Sure, trainees need to know the government has taken this position, but is there any need to make it a linchpin in training? No, not really. No matter how nicely delivered, I have to agree with the thought that hearing “I want to keep you out of jail” isn’t necessarily a sound approach. Don’t tell me you anticipate that I’m going to do the wrong thing, and expect me to respect the training.
Now firmly back in reality, I thought about the things that, for lack of a better phrase, keep people out of jail. Laws and their application may change over time, but far less changeable are the basic principles by which most companies conduct their business. These principles provide a foundation for decision making. It would be impossible to have a policy for every situation a person might encounter while on the job, but by applying a principle to a situation, we can have a good idea of the appropriate action to take in any situation.
With the basic principles as a foundation, a set of practices can be built from the laws, guidance and industry best practices to address the many situations one is likely to face. In commercial compliance we call these Good Promotional Practices, or GPPs for short. These GPPs can be couched in terms of company policy, which as a trainer, is a great way of presenting compliance topics. Teaching the PhRMA Code, for example, has a distant feel to it. However, the same material presented as a set of practices supported by company policy feels closer to home and more relevant.
GPPs also help us present legal topics, such as the False Claims Act, in a more relatable way. Let’s face it, most people do not hold such legal topics with the fascination that many of us compliance folks do. Rather than training people about the legal ins and outs of the False Claims Act, GPP training gives learners the tools to keep from running afoul of the False Claims Act.
While we certainly have to present the reality that the government is going to hold individuals accountable as they pursue fraud and other cases against companies, it doesn’t have to turn compliance training into a scared straight presentation. We want compliance to be accessible and relevant to the learner. Training on GPPs does just that. Built on solid practices, GPPs take what may seem remote and present it in a “personal” way that is easily understood and applied. It removes the temptation to bring in the “fear factor,” and focuses learning on what’s important – putting principles into practice.