Off-the-Shelf Compliance Training Myths

Myth #2: It’s Not Really Targeted to the Life Sciences Industry

In this installment of our series on the myths and realities associated with off-the-shelf compliance training, I cover the common concern that off-the-shelf compliance and ethics training is not effective because it is so rarely focused on the life sciences and the only way to get targeted training is to build from the ground up.

The Myth 

All too often, life sciences companies purchase off-the-compliance training designed with generic content that is somehow intended to be applicable to any industry. This especially holds true when training is sold under the banner of ethics training. After all, ethics is ethics, no matter the industry…at least that is the sales pitch from companies who sell generic compliance training.

Unfortunately, the aggressive marketing and sales efforts of those companies perpetuate the myth among many life science companies that custom-development is the only training option that will meet their needs. Unknowing compliance professionals think they have only two bad options: 1) purchase generic training, or 2) hire a generalist training developer to build expensive modules from scratch, with the added burden of having to provide subject matter expertise to the training developer (As if they don’t have enough to do already!). There is a better approach, one that can be both efficient and cost-effective.

The Reality

Those pedaling generic compliance training may insist otherwise, but effective life sciences compliance training absolutely requires content targeted to the pharmaceutical or medical device industries. The intricacies and details of the risks in our industry are far too unique to expect learners to find real value in generic training. But that doesn’t mean the only path to quality training is through custom development. Off-the-shelf training, with content developed by industry experts and vetted by your peers in the industry, is readily available for customization and launch.

Interactions with Healthcare Professionals Compliance Foundations eLearning Module

Our Compliance Foundations™ eLearning modules cover the topics those working in the life sciences industry need to effectively reduce the risk inherent to their job responsibilities. Off-the-shelf courses include Good Promotional Practices; Interactions with Healthcare Professionals; Healthcare Compliance Overview; On-label Promotion; and Managing Speaker Program Risk to name a few. The modules are designed for easy customization, so your language, policies, and practices are easily woven into the content. And our modules can be launched on any SCORM-compliance learning management system…either the one you have in place or our cost-effective LMS.

The Bottom Line

There is a better way. You don’t deserve to have to settle for generic compliance training. You can have off-the-shelf content that is specifically targeted to the risks in our industry and the ability to further customize the training specifically to your company. You also don’t need to always build from scratch to ensure the content is relevant and optimized for the risks your learners face every day as they interact with healthcare professionals and conduct their work-related activities.

But don’t just take my word for it when you can see for yourself. Follow the four steps below to access demos of the Compliance Foundations™, and see first-hand, the level of industry focus we bring to our modules.

  1. Visit http://www.pharmacertify.com/demo/interactions_hcps/start_course.htm
  2. Follow the navigation prompts to review the demo.
  3. Visit http://pharmacertify.com/foundations-compliance-training.html to see short descriptions of all of our Compliance Foundations modules.
  4. Contact Tessa Hoyer at thoyer@nxlevelsolutions.com for course outlines and to learn more.

Thanks for reading!

A Preview of the 4th Annual Life Science Ethics & Compliance Training Conference

PharmaCertify is a proud sponsor of the 4th Annual Life Science Ethics & Compliance Training Conference scheduled for June 5th and 6th in Chicago. As someone who has spent the last 12 years in the field of life sciences compliance training, I find the focus of this annual conference especially compelling as industry leaders and consultants share ideas, tips, and experiences for reducing risk through innovative training. It’s an exciting and energized group of presenters every year. Below are some of the presentations I find to be of note this year. You can learn more about the conference and download a full agenda at https://www.q1productions.com/compliancetraining/. Contact us about our sponsor discount if you are interested in registering.

Day 1: Wednesday, June 5

Day 1 will be chaired by PharmaCertify’s own Dan O’Connor, and after the opening ice-breaker, the conference begins in earnest with a keynote panel titled, Assessing Risk Tolerance & Company Culture as a Driver for Ethics and Compliance Education. Kudos to the conference organizers for scheduling a great kickoff session. Building an effective compliance training curriculum begins with a thorough risk assessment and I am looking forward to hearing the details of each presenter’s process for “shaping training based on tolerance, and conveying liabilities to ultimately create a culture of compliant and ethical behavior…”

Following the keynote panel, a multi-part session from 10:00 AM to Noon begins with the Legal Interpretation of Enforcement Trends & Areas of Inspection presentation. The talking points on the agenda include the first official reference to the new and trending topic of patient assistance programs. That theme continues later in the day with a case study from Catherine Starks of Sidley Austin, Risk Evaluation & Training Approaches for Compliant Patient Assistance Programs.  With PAPs and PSPs programs being the focus of recent corporate integrity agreements, any discussion of the associated risks and the best practices for conducting compliant programs is worthwhile.

The first session after the lunch break, Developing a Compliance Training Cadence Based on Risk & Needs of Business caught my if for only one word: cadence. The rhythm and pace at which compliance training is launched across a life sciences company is critical to the success of that training. Microlearning is all the rage lately and effective microlearning is more about the frequency and schedule at which training is delivered than it is about the length of the individual learning components. In this session, the presenter will discuss the factors affecting that cadence, including establishing a “cadence to coincide with business agendas and timetables to inform stakeholders at optimal moments.”

Two case studies on the topic of “measuring training effectiveness and risk reduction” are scheduled for the afternoon and I am excited to hear the speakers from Exsurco and Gilead detail their strategies for tracking retention and engagement, and as described in the agenda, “translating the data into actionable strategy.”

Day 2: Thursday, June 6

Day 2 kicks off with one of the more intriguingly-titled sessions from this or any conference: Masterclass: Effectively Maintaining Training Priorities Upon Exiting a Corporate Integrity Agreement. The end of a CIA presents a great opportunity for companies to incorporate the lessons learned during the term of the CIA, when training schedules and the modules were under the demands of the agreement and create a curriculum even more dynamic in terms of scope and levels of engagement. I look forward to hearing Maureen Mason of AstraZeneca discuss her philosophy and suggestions for maintaining the diligence of a strict curriculum while expanding and enhancing the company’s compliance curriculum.

“Cadence” isn’t the only word that jumped off the screen when I initially reviewed the conference agenda. The sessions scheduled after the 10:00 AM coffee and networking break (don’t forget to visit us at the PharmaCertify booth to see demos of our newest training products), Multi-Part Case Study: Contextual Compliance Risk Evaluation in Prioritizing Training caught my eye for the use of one word: contextual. In our 15th year developing compliance training for life sciences, the team at PharmaCertify has worked with compliance departments ranging from an “n of 1”, to those that have a full team of internal resources. And while context does matter, ultimately results are what count no matter the number of resources. In this case, the large corporation perspective will be provided by Abbvie, the mid-sized by a speaker from Convatec, and the “limited resources” perspective by Otsuka.

After the lunch break, two breakout groups are divided by industry, in sessions titled, Compliance Considerations Specific to Pharmaceutical & Medical Device Organizations. I am glad to see the focus on the medical device industry, which too often is not as well represented at conferences. Two speakers from Teleflex will provide the me device experience and their talking points include updates to the AdvaMed Code of Conduct; compliant interactions & “no touch;” and the EU General Data Protection Regulation.

The afternoon of Day 2 includes a session on third-party vendors: Managing Distributor Partner Compliance Training. The intricacies of doing business through third-party vendors hold the potential for increased risks compliance violations. It’s a critical topic and any opportunity to hear tips and suggestions related to training, tracking and managing global vendors is worthwhile and valuable.

Discounted Conference Registration

The 4th Annual Life Science Ethics & Compliance Training Conference is scheduled for June 5-6, in Chicago, Illinois and if you’re interested in hearing industry leaders share their experiences and best practices, there is still time to register. Contact me at smurphy@nxlevelsolutions.com to take advantage of our discount registration rate. I can’t recommend this conference more highly!

Thanks for reading!

Sean Murphy
Product and Marketing Manager
PharmaCertify by NXLevel Solutions

Connie the Compliance Training Manager Tackles New Hire Training!

Welcome to a new edition of “Dear Connie, the Compliance Training Specialist,” where Connie answers questions about life science compliance training concepts and discusses new ideas for making that training more effective.

This week: Connie hears from a compliance training manager looking for a more exciting way to train new sales representatives.

Dear Connie,

I know I should change my new hire compliance training session for the sales representatives because my PowerPoint deck might be getting a little stale, but I only get an hour in front of them, so I don’t really have time for a more creative approach. Any suggestions?

Concerned Compliance Manager in Cambridge


Dear Concerned,

You may be surprised to hear that an hour is more than enough time to conduct a more engaging and more memorable live training session. Now is the time to ditch that overused and dull PowerPoint deck!

Make it More Competitive

Research shows that learners are motivated by competition. So how about creating a Jeopardy-style game format with questions designed around your company’s policies and risks? In my experience, five categories, with five questions per category, fills an hour of time. Make sure you take a few minutes after each question to explain why the answer is right or wrong and ask the participants for examples of similar situations they have faced.

Depending on the size of your audience, I suggest you pick 3-5 participants per team to “represent” groups in the audience and have representatives buzz in once they think they know the answer. It’s a great way to take the learning to another level and create an interactive experience where ideas are exchanged with the audience. One warning: have someone there with a timer to make sure they don’t buzz in and then take forever to figure out the answer.

Make it More Engaging

You could also create an interactive workshop where the participants are divided into groups and asked to “solve” compliance scenarios together. Break the workshop into two activities to keep it moving and make sure each team has a tablet or laptop on a table. I like the idea of a Compliance Sprint as the first activity. Have the teams solve a series of exercises (a card sort works well) based on situations they are likely to encounter in the field.

You could also mix in a Compliance Mystery. The same teams play compliance “detective” and solve more complex scenarios with the help of a series of clues. The clues can be emails, phone call transcripts, business cards from a meeting, or whatever clues help provide hints about the scenario. Be creative and make it fun, but make sure you make it realistic in terms of their work activities. Of course, both activities should be scored and tracked on a leader board to raise the engagement level even more.

If you have the time and resources, you can certainly create the game or the workshop in-house, but my friends at PharmaCertify (that’s the compliance training division of NXLevel Solutions) have workshops just like the ones I described that are easily customized with your content. I’ve been there when their clients have used their workshops, and wow it is fun to watch the learning! They’d be happy to demo the workshops for you. Just email Tessa Hoyer at thoyer@nxlevelsolutions.com.

Thanks for the question and remember to make it fun and make it memorable!

Your compatriot in compliance training,

Connie

A Preview of the 2019 Pharmaceutical Compliance Congress

The 16th Annual Pharmaceutical Compliance Congress is scheduled for April 16-18, 2019 in Washington DC.

The 16th Annual Pharmaceutical Compliance Congress begins April 16-18 in Washington DC and as is often the case, the agenda promises a compelling mix of presentations covering topics important to new and experienced compliance professionals alike.

Tuesday, April 16th is dedicated to the Congress “prelude” and one of the sessions looks particularly interesting based on its subject matter. Nurse educators are a trending topic in life sciences compliance with the potential for patients misinterpreting the line between medical advice and a commercial sales pitch. The description for the Compliant Nurse Educator prelude includes the timely suggestion that attendees will “gain foundational and operational needed to structure and maintain compliant programs.”

On Day One, Wednesday, April 17th at 11:15 AM, the Highly-Acclaimed U.S. Healthcare Fraud and Enforcement Panel begins with current prosecutors reviewing “Top Enforcement Trends and Focal Points for 2019 and Beyond.” During the Former Prosecutors Panel that follows, three former Assistant US Attorneys will focus on “New Developments on High-Profile and Settlements Uncovering Healthcare Fraud.” The perspective from the regulator side of the table is not readily accessible outside of this type of conference and attendees will be listening carefully for suggestions and tips from those responsible for regulation.

Following the networking lunch (important tip: the networking sessions offer great opportunities to learn from your peers), Day One continues with a series of “content streams” divided by general topic matter.

Patient assistance programs (PAPs) and Patient support programs (PSPs) are certainly under scrutiny (see our recent blog post on the programs here), so we have to recommend Content Stream A: PAPs and PSPs. A team of panelists, including Jennifer McGee from Otsuka, Chetan Shankar from GSK, Francisco Ribeiro Filho of Tesaro and Ann-Marie Tejcek of Eli Lilly will speak in two sessions: Navigate the Complex Legal Landscape of PAPs and Examine PSP Enforcement Trends as Scrutiny Heats Up. Content Stream C: Transparency and Aggregate Spend is also of interest considering the pending expansion of the Sunshine Act to include Advance Practice Nurses and Physician Assistants. It’s time to update that Sunshine Act and Open Payments training!

A series of interactive workshops follow the content streams and I’m looking forward to the Beyond Due Diligence – Auditing and Monitoring Third-Parties session, in particular. Third-party vendor compliance continues to be an area of focus in the industry and Lori Queisser of Teva should bring an important global perspective to the challenges of bringing vendors into compliance as they conduct business of the company’s behalf around the world.

Speaking of hot topics – Interactive Workshop 4: Risks Associated with the Hub and Field Reimbursement Teams so I expect the impressive list of panelists, including Sarah Whipple from Akebia, Joe Philipose from Alexion, and Richard Konzelmann from Sanofi to be speaking to a crowded room of attendees anxious to hear how they are managing the compliance risks that are inextricably linked to the use of Hubs for specialty products.

After a networking and refreshment break at 4:25 PM (don’t forget to stop by the PharmaCertify Booth to see demos of our newest compliance training products), the conference transitions to a series of “think tank sessions.” Frankly, I am not sure of the difference between a workshop and a think tank, but I suppose the changing up the name does make for a more organized agenda.

Anyway, on the think tank front, the Speaker Programs – Best Practice Benchmarking is right at the top of my list. Our recently completed Managing Speaker Program Risk Compliance Foundations™ module is already popular among our client base and for good reason. The programs are fraught with risk at every stage, including planning and execution, and this session, featuring Jennifer McGee from Otsuka again, as well as Maggie Feltz of Purdue Pharma, and Rebecca Spitler of Johnson & Johnson, should prove to be a valuable primmer on how to navigate those risks.

Add Social Media – Practical and Pragmatic Guidance to our target list among the think tanks because, well, it’s social media. We’ll also be in the PAP and PSP Benchmarking – How is the Industry Adapting? think tank to hear how Casey Horton and Stefanie Doebler from Navigant are working with their clients to help minimize program risk.

Day 1 closes with an end-of-day cocktail reception and I do recommend taking the time to attend this important networking event before you run out to dinner. It’s a great opportunity to interact with your peers and learn how they are dealing with some of the same challenges you face every day.

Following the Chairman’s Review of Day One, Day Two, Thursday, April 18th opens with an interesting session titled, From the Trenches: An Inside Look at the Forces and Pressures that Drive People to Violate the Law. The idea of approaching compliance from a higher “ethics” level has been a topic for discussion in recent years and companies are clearly seeking ways to integrate the concepts into their policies and procedures. I’ll be interested to hear how the speaker, who is the CEO of Business Ethics Advisors, LLC, how is working with clients to do just that.

After a session dedicated to recent trends in enforcement, featuring Eric Rubenstein from the OIG and Heather Johnson from the FTC, the agenda takes a turn to the future with Rethinking the Compliance Profession Where Should We Go from Here? Including such forward thinking presentations is appreciated and this look at the future of the industry should dovetail nicely from the opening session on ethics.

Next, attendees choose from what are described as “five in-depth summits.” The Small to Mid-Sized Company Resource Center holds interest for me based on the uniqueness of its title, and simply because I find the small to mid-sized company focused sessions so informative from a standpoint of learning what those with limited resources are doing to address the same challenges their peers at larger companies face.

With HCP interactions still representing so much of the compliance risk companies face, the Compliant Patient Interactions summit should be worthwhile, with an impressive array of industry professionals ideally sharing tips and suggestions for ensuring those interactions are conducted in a compliant manner. Hopefully, training is included on the list of talking points.

Following the final networking luncheon, the conference closes with the reveal of an inaugural benchmarking survey. The agenda does not list what organization conducted the survey, but I’m sure attendees will be listening closely to learn what their peers from “brand/generic, large/small and private/public” companies consider to be their top priorities on the established and emerging compliance risk areas.

Summary

The panel presentations, workshops, think tanks, and summits I touch on in this preview represent just a few of the sessions CBI has planned for this year’s conference. The Pharmaceutical Compliance Congress never fails to deliver the content and networking opportunities industry professionals need to stay abreast of current risk areas, policies, and best practices. I highly recommend the conference for the new and established life sciences compliance professional.

If you are considering the conference but have yet to register, we are still offering discounts on the regular conference registration rate. Contact me at smurphy@nxlevelsolutions.com if you’d like to take advantage of that discount. If you are attending, don’t forget to stop by the PharmaCertify booth to say hi and let me know what you think of our blog. As always, your feedback is appreciated.

Thanks for reading and I will see you in Washington!

Sean Murphy
Editor
Compliance Training Intelligence Blog

PAPs and PSPs: Training Beyond the In‑Program Staff

Patient Assistance Programs (PAPs) and Patient Support Programs (PSPs) are in the news. The programs are under increased scrutiny for violations of the Anti-Kickback Statute, HIPAA, and False Claims Act. Recent settlements and Corporate Integrity Agreements highlight the need for vigilant and more effective training for these programs.

Nicole Serena Waldron & Associates

With that in mind, we recently sat down with Nicole Serena, Senior Consultant for Waldron & Associates and 25-year industry professional, to discuss her suggestions for how to approach PAP and PSP training to better reduce the risks and the red flags associated with the programs.

A Focus on Customer-Facing Staff

Serena began by highlighting the need to extend training beyond those working directly in the programs to other employees who require a fundamental awareness of how they work, why they are important, and the associated risks. Everyone involved, particularly the sales representatives, MSLs, and nurse educators who interact with healthcare professionals need to be aware of the programs and understand that value.

Serena points out that when a company is launching a specialty or biological product, healthcare professionals will often ask if the company has an assistance program for the product. “Depending on the company and what kind of roles are involved when launching a product,” she says, “sales representatives, MSLs, and nurse educators are all part of the team introducing the program to a clinic and discussing how it supports the patients. They all need to be trained on what they can say, and they need to know they can’t give any incentive for patients to be enrolled.”

According to Serena, when representatives don’t have the proper training and they don’t understand their company’s assistance and support programs, their interactions with HCPs hold the potential for increased risk. “Since they are the first people to hear about problems customers have with a PAP or PSP, representatives need to be careful how they react to that information,” she says, “and since they are responsible for managing the relationship with the HCP, they need to be careful about not over promising.”

In addition, the training shouldn’t assume that employees understand the programs just because they have worked in the pharmaceutical industry. “An employee’s previous position may have been with a division of the company that dealt with a general medicine product, like a high blood pressure pill or antibiotic, which would not involve a PAP or PSP,” says Serena, “so when he or she gets moved into a specialty product role, that background training is critical.”

Extend Training Beyond the Field Force

Vendors are sometimes overlooked for training, particularly when they claim to have their own PAP and PSP training in place. Even if that is the case, rolling out the company training to the vendor’s staff helps ensures consistency in messaging and accountability of trainee rosters. In other words, the vendors need to be trained using the same training the inside employees receive.

According to Serena, “vendor work forces have quite a large turnover in the staff working on the programs, so it can be difficult for them to have enough resources to track training.” The pharmaceutical company needs to take responsibility for that, roll out the company’s own training to the vendors, and track it on company systems.

Since marketing departments are often responsible for funding the programs and developing program materials, marketing staff should be included on the training roster. “All marketing staff need a base level of training,” says Serena, “and those tasked with working in partnership with the in-program team need a deeper level of training.”

In addition, since Medical Information is tasked with answering HCP questions that come in by phone, an awareness on how the programs work is critical for them as well. Add the Finance Department employees to the training list as well. They need to understand the reason for the program, its value to the company, and the justification for why it shouldn’t be eliminated when budgets need to be cut. Finally, don’t overlook the need for PAP and PSP training for the Compliance Department. Compliance is often staffed with professionals from other disciplines across the company and their awareness and familiarity with the programs may be limited.

Although this post delves into the broad scope of employee groups who should be trained on PAPs and PSPs, the list should not be considered complete by any means. Every company’s approach to the programs is different and the structure, frequency, and roster lists for program training will vary.

The stakes are high though and careful planning is needed to help ensure a higher level of compliance across the company. As Serena so succinctly puts it, “everyone in the industry talks about the importance of being patient centric. These programs speak to the value of that focus and the company’s reputation and that must be taken into consideration when planning the training.”

Thanks for reading!

Sean Murphy
PharmaCertify by NXLevel Solutions

Lessons Learned at the 19th Annual Pharmaceutical and Medical Device Compliance Congress

Lesson 2: The More Things Change…

Tessa Hoyer of PharmaCertify greets attendees at the 19th Annual Pharmaceutical and Medical Device Compliance Congress.

The French journalist and novelist, Jean-Baptiste Alphonse Karr, is credited with coining the phrase, “the more things change, the more they stay the same.” For anyone who has attended multiple compliance conferences in the last five years, his words certainly ring true. Terms like “partnering with the business,” “tone from the top,” and “third-party risks” are still staples during conference presentations and this year’s Pharmaceutical and Medical Device Compliance Congress was no exception. For good reason.

As an example, the Compliance 3.0 presentation on Day 2 of the conference began with one panelist expressing his concern that “we still have to fight for a seat at the table.” In other words, while the concept has been bandied about for years now, the reality is that raising compliance to the organizational level of respect it requires to affect true behavior change is still a struggle. He and his co-presenters emphasized the need to not only find that seat alongside the businesses but truly understand their business policies as well as what they do and who they are. As another presenter put it, “bring value to the business as a compliance representative, educate them every step of the way, and help them educate their people.” She added, “when they get to the point where they are doing it themselves, that’s nirvana.”

Not surprisingly, the need to train and manage third-party vendors continues to be stressed. In the session covering the Foreign Corrupt Practices Act, one government representative even delved into the need to extend the corporation’s culture to the vendors. She added “you really need to know your third-party vendors and they need to understand you. You need to know who it is that is making payments on your behalf.” The presenters in the Third-Party Lifecycle Management session agreed, citing the need to “have vendors take the same training that is rolled out for your employees. Treat them as partners and make sure they understand the risks involved.  They are more likely to care about being compliant if they feel like a partner and if they will be held responsible.”

As with the conversation and debate over an “ethics-based approach to compliance,” concepts like “tone from the top,” “partnering with the business,” and “third-party risks” warrant our focus and consideration simply because they are that relevant and critical. Industry conferences offer the valuable opportunity to hear our peers share their latest insights and success stories around the themes that seem to drive the conversation. While the world of life sciences compliance is evolving, in some cases, the more things change, the more they stay the same…at least at the compliance conferences.

Thanks for reading!

Sean Murphy
Editor
Compliance Training Intelligence Blog

Lessons Learned at the 19th Annual Pharmaceutical and Medical Device Compliance Congress

Lesson 1: Rules and principles can coexist.

Welcome to the first in a multi-part series based on lessons learned from the recent Pharmaceutical and Medical Device Compliance Congress in Washington D.C. Our goal in this series is to share best practices and tips for strengthening your compliance culture and reducing risk based on the themes and best practices heard during the three-day conference and provide suggestions on implementing those concepts from a training perspective. We begin this week with a twist on a topic that has been on the agenda for a few years now…rules vs. principles.

During the Compliance Considerations for Small to Mid-Size Pharma and Device Companies panel presentation, a team of industry compliance officers and consultants discussed the challenges and opportunities brought on by limited resources and personnel. The suggestions were varied and intriguing, but one stood apart for me, especially from a training perspective. When he was offering the details of how he approached his transition to a small company compliance department, one chief compliance officer said, “it’s important to start with foundation training, and then have a conversation about culture.” In the milieu of conversation about the importance of principles, and the need for “an ethical approach to decision making,” it was refreshing to hear acknowledgement that rules-based and principles-focused approaches can co-exist and work in conjunction.

Foundational training lays the groundwork for the rules and policies that are critical for all life sciences employees to understand and incorporate into their daily activities. Although the “check the box” approach to training has been much maligned in recent years, being able to document that your staff, especially those who interact with healthcare professionals on a regular basis, have successfully completed training in topics such as HIPAA, on-label promotion, the False Claims Act, and the Anti-Kickback Statute, is a critical first step. Once that foundation is established, on-going opportunities and touchpoints can be utilized to establish the “why” behind the decisions as you strive to strengthen the culture across the organization.  As was emphasized during the presentation, you need to “have a plan that builds across all work streams” to do that throughout the year. As one example, workshops with interactive activities that immerse employees in ethical scenarios are an effective method for reinforcing the principles. In addition, assessments, microlearning, and games deployed across an employee’s timeline remind learners that compliance isn’t just about rules and regulations, it’s about “doing the right thing, for the right reason.”

During the Chief Compliance Officer Roundtable at the conference, one participant made the point that “a principle-based philosophy helps ensure compliance throughout the company and not just at the surface level.” That’s certainly true, but from our perspective, a principle philosophy is more effective when its built on a solid foundation of policy and rules-based training.

Thanks for reading!

Sean D. Murphy
Editor
Compliance Training Intelligence Blog