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

Fair Balance: Training on a Tricky Concept

Mona Kay Gorman
This week, we welcome Mona Kay Gorman to the Compliance Training Intelligence Blog. Mona Kay is the Director of Training & Leadership Development at Valeritas. She has extensive experience in the management of compliance training and communication programs, as well as the design and delivery of virtual and live compliance training courses.

Has anyone ever asked you how to apply fair balance to a promotional discussion? In my experience, it’s one of the most challenging FDA standards of promotion to explain, train, and apply. Most industry professionals understand how to keep a conversation on-label, but the definition of fair balance is a bit vague, and appropriate use can be a hard concept to grasp. Through a few simple steps during training, and by making the effort to partner with the businesses, we demystify the concept and help promotional people effectively balance their messages.

Good Training Enables Better Practice

If you’ve ever attended a sales training workshop, you know that sales representatives are extensively trained on promotional messages to make their discussions sound confident and natural. Role-playing, or some type of repetitive practice, is understandably an important part of the training content. Fair balance can be practiced in the same way if the audience understands and can apply the concept. Some amount of hand-holding is helpful, so training design is important.

For instance, if the content includes only broad, high-level examples of fair balance, trainees may struggle to apply the examples to their day-to-day discussions. As a result, fair balance messages are tacked onto the end of a promotional call, like a canned disclaimer. When training is customized using role-specific customer types and messages, the examples are more relevant, and trainees understand what a balanced message sounds like for their specific discussions. Armed with this understanding, they can practice balancing the promotional messages they typically use in their day-to-day customer conversations.

Collaborate for Shared Success 

Since collaboration drives shared ownership and desire for success, partnering with business stakeholders is critical. When designing your training, meet with leadership members of your intended audience to share your vision and ask them about typical customer types and discussions. Seek feedback on the draft content. Are the examples and scenarios relevant and easy to apply? Do business leaders feel confident providing feedback during coaching sessions? Make sure the sales training department is part of the conversation as well. Collaboration helps stimulate pull-through.

Finally, make yourself available for questions, and keep your commercial partners informed of questions you receive during and after the training and the answers you provide to those questions. Doing so will drive communication and advocacy and establish you as a valued resource and partner.

Effort Well Spent

Effective fair balance training leads to confidence in execution. When training is optimized as described, sales representatives know how to balance their promotional discussions, the sales training department has more confidence pulling the concept through, and the stakeholders across the company support and even advocate one of the trickier promotional standards. When all of that occurs, organizational risk is reduced, and the compliance department is seen as a partner instead of just the “scary enforcer.” The extra time and resources spent developing relevant, customized fair balance training, and partnering with the business, is not only worthwhile, but necessary, to improve learning and ensure representatives are balancing their messaging appropriately.

Thanks for reading.

Mona Kay Gorman

To download a printable version of this article, please visit the Insights page on the PharmaCertify website.

 

Lessons Learned at the 2018 Pharmaceutical and Medical Device Congress

Lesson 3: Learning to Listen

“There is only one rule for being a good talker – learn to listen.”
Christopher Morley

The importance of effective communication and more specifically, listening, wasn’t lost on the speakers at the 19th Annual Pharmaceutical and Medical Device Compliance Congress. The consequences of poor listening were summarized by one panelist on the Qui Tam Roundtable when she said, “the vast majority of whistleblowers who contact me have tried to report their concerns to the company, but the company didn’t want to hear it.” In an era when the nuances of an effective compliance program are discussed and debated in detail, the simple yet often lost art of effective listening needs to be a priority.

The value of listening extends across all departments and business units and it starts with field-based employees. A presenter in the Compliance Considerations for Small to Mid-Size Companies session echoed that sentiment, saying, “the stream of questions from the field is not going to stop, but those questions tell a story and you need to monitor them carefully and build your plan from there.” The data from those responsible for interacting with healthcare professionals is critical as you evolve your program and look for gaps and redundancies that need to be addressed in personal interactions and in your continuous training curriculum. And listening for that data begins with open, non-judgmental relationships across the company. Or, as another presenter in the Compliance Considerations for Small to Mid-Size Companies session stated it, “when employees interact with the compliance department, they should not feel like they are being judged.”

The need for open lines of communication doesn’t stop with the field. The industry trend toward “building a culture of ethics and compliance,” and frankly, the regulatory focus on the culpability of those in the C-Suite and boards of directors, more than ever, dictates the need for open and regular communication with company leadership. The proverbial “seat at the table” for Compliance extends upward in the organization. As was stated during the AUSA Roundtable, “Compliance should have a good relationship with the Chief Executive Officer, and the officers of the company. The two departments need to communicate openly and honestly.” He continued, “when issues do arise, the Department of Justice needs to see that you are being proactive and responding to those issues.” In other words, listening to one and another.

During the Chief Compliance Officer Roundtable, the risks associated with the use of third-party vendors was discussed in detail and the need for open lines of communication beyond the walls of the company was stressed. “Work with the stakeholders in the third party and make them feel like you are partnering with them,” one participant said, “be transparent, if you hear that people aren’t disclosing information, that’s a warning sign. If there is any confusion, ask questions.” And listen carefully to the answers.

The key takeaway: to build a truly effective and modern compliance program that proactively addresses the risks across the organization, a policy of open communication must be established from the top down. The concept of an ethics-based approach to compliance may seem nebulous and difficult to quantify, but it begins with fostering a level of respect across the company. And respect begins with real listening. When employee questions, feedback, concern, and complaints are welcomed, appreciated and nurtured in a respectful manner by Compliance and the C-Suite, all aspects of the compliance program, including the training, are enhanced.

Thanks for reading! I welcome your feedback.

Sean D. 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

4th Annual Life Sciences Compliance Congress for Specialty Products: A Preview

CBI’s Compliance Congress for Specialty Products kicks off next Thursday, September 13th in Boston, and Dan O’Connor, Senior Vice President for PharmaCertify, will be there to catch up with our clients and colleagues and hear industry leaders and government regulators share strategies for proactively addressing current risks for specialty pharmaceutical manufacturers.

We’ve reviewed the conference agenda and here are the sessions and presentations we are looking forward to in particular:

Day One, Thursday, September 13

Prosecutors’ Perspectives Panel

Following the opening keynote address, the conference begins with this prosecutor panel focused on biotech and specialty pharma companies. Charles Grabow, Assistant US Attorney from New Jersey, and Gregg Shapiro, Chief of the Affirmative Civil Enforcement Unit for the DOJ in Boston, will be joined by Jane Yoon from Paul Hastings, LLP, to discuss the high-risk areas for this unique industry group. Government panels typically offer some of the most compelling and important information during conferences and since this conference is focused on such a defined segment of the industry, the conversation should be revealing and educational.

Coping Strategies for the Lonely Compliance Officer

In addition to having the most creative name of any of the presentations, this session features three professionals facing the challenges that come with being a compliance professional for an emerging pharmaceutical company. We will be curious to hear how Heather Godling from Sobi, Francisco Ribeiro of Tesaro, and Sarah Whipple at Akebia Therapeutics, creatively utilize the limited personnel and resources available to them to build and maintain a strong culture of compliance.

Expert Panel: Evaluate the Risks Associated with Disease State Awareness and Other Pre-Launch Activities

The “Pre-Launch Activities” part of this title caught my eye. No matter their growth stage, all companies need to be aware of the compliance risks and concerns they face now and as they progress toward launch. That extends to compliance policies regarding interactions with healthcare practitioners. Ideally, compliance training for a new sales team should be built and planned before the product is commercialized.

Ensure Transparency in Contributions to Independent Patient Assistance Foundations
And
Reboot Your Approach to Patient Assistance Programs (PAPs) and Reimbursement HUB Support  

Patient support programs are an emerging enforcement trend in the pharmaceutical industry as more and more companies enter into settlements at least partly related to the programs (e.g., Aegerion, United Therapeutics, Jazz Pharmaceuticals). Add the high cost of specialty pharmaceutical products to the mix, and it’s no surprise that CBI has scheduled back-to-back sessions on this important topic.

Day Two, Friday, September 14

Daybreak Discussion: Specialty Café – Forecasting Priorities from Now to 2020

In a novel presentation structure spread across two consecutive time slots (8:15 – 8:40 and 8:45 – 9:10), attendees will have the opportunity to sit in small groups, share ideas and listen to their peers discuss three timely topics: Risk-based Approaches for Advanced Therapies; PBM Contracting Considerations; and Compliant Medical Affairs and Commercial Interactions. The format offers a welcome twist  from the typical large group presentation and should lead to a compelling exchange of peer-to-peer ideas. It’s a great idea.

Explore the Trends in Drug Pricing Legislation and Other State Initiatives

John Oroho, from Porzio Life Sciences, LLC, is a respected and established thought leader in the life sciences compliance industry and his presentation is a can’t miss opportunity to hear the latest news and regulatory updates on these two ever-evolving topics.

Scale Up Your Compliance Program for Global Operations

Going global can be fraught with risk and compliance traps. In terms of anti-bribery alone, pharmaceutical companies need to now consider Loi Bertrand, the EFPIA Code, the Medicines Australia Code of Conduct, and a cadre of emerging codes and regulations around the world.  These on-going changes in the global landscape make the presentation by Masha Chestukhin of Sanofi, and Darryl Williams of MediSpend, an important pre-lunch session.

GDPR is Here – Now What Do We Do?

Are you confused about the General Protection Privacy Regulation (aka, GDPR) and its impact on you as a pharmaceutical compliance professional? You’re not alone. The questions concerning details like data inventory and documentation abound, and what exactly does it mean when data subjects have the “right to be forgotten?” What about training? Who needs to be trained? How does it impact the field employees interacting with HCPs? We look forward to hearing answers, ideas and opinions from David Ryan, Vice President, Associate General Counsel, Chief Compliance Officer at Epizyme and Trish Shorey, Privacy Officer, Global Compliance and Risk Management at Shire.

If you’re attending the conference, we want to hear from you. Let us know what you think of the sessions and presenters, and conference content. And of course, if you see Dan, he’d be happy to share demos of our newest compliance training solutions and discuss how we help clients build a stronger culture of compliance and reduce risk.  

Thanks for reading!

10 Tips for Creating Transparency Training That Sticks

With government investigators rigorously examining Open Payments, and on the hunt for red flags, the need for effective tracking and reporting training is more important than ever. Here are ten tips to help you build and deploy transparency training that reduces risk across your organization. 

  1. Go global.
    Make sure your employees understand that transparency covers multiple countries, not just the U.S. Global companies need to think beyond the Sunshine Act and include the relevant codes and laws from around the world. Don’t forget to incorporate requirements from codes like the EFPIA Disclosure Code and the Medicines Australia Code of Conduct, and regulations like Loi Bertrand (French Sunshine Act).
  2. Keep the reports formal.
    Stress the importance of using legal names of healthcare professionals for reporting purposes. Even if an HCP is commonly known as Bob, his license probably reads as Robert. Only legal names should be used. Warn the learners about facility names as well. For example, Saint Joseph’s Hospital for Children might be commonly known as Saint Joe’s, but the full name needs to be used in the reports.
  3. Add in reference resources.
    When developing training, include resources for learners to use on an on-going basis. Infographics or quick reference materials are good options for learners to self-check information they may have forgotten after they completed the training.
  4. Emphasize that ALL HCP spend needs to be tracked.
    Spend reporting requirements vary from jurisdiction to jurisdiction. A cup of coffee may or may not be reportable, depending on the circumstances. Learners should understand that accuracy is important for HCP spend, regardless of amount or spend type.
  5. Don’t forget the T&E process.
    The details of the travel and expense system are critical. Make sure learners know how to properly record HCP spend in your company’s system. For example, some systems (e.g., Concur) differentiate between a “business guest” and an “HCP guest.” Attributing the spending to the correct category in the system is a time-saving step that helps ensure accurate data.
  6. Include examples of data entry errors.
    Some data entry errors are common, and so are the instructions for correcting them. Identify the common errors in your system and highlight them in the training so learners recognize them during the actual data entry process.
  7. Include a section on HCP interactions.
    Healthcare professionals are aware of the buzz around transparency and privacy. They’re bound to have questions. Instruct sales representatives on how to answer their questions and address their concerns.
  8. Review the rules on speaker programs.
    HCP consultants who serve as speakers on behalf of the company need to make the audience aware that they are being paid by the company. Also, sign-in sheets are necessary to accurately record attendance and account for every physician in attendance.
  9. Make it easy to report errors.
    Include information about the process learners should use, including contact information, when they find errors (misspellings, incorrect state license number, incorrect address, etc.) in the training. Make that information available as a resource they can use later.
  10. It’s all about accuracy.
    No matter the format (live, eLearning, WebEx, etc.), make sure the need for accurate reporting is a recurring theme throughout the training. Take the time to identify and fully understand where errors typically occur in the process and build that information into the follow up training in the form of scenarios and stories. Long live accuracy…king of the content.

The Compliance Foundations™ customizable eLearning module, Global Transparency: Reporting HCP and HCO Transfers of Value, helps learners understand the requirements of worldwide transparency laws and codes, and how those rules help foster open relationships with a company’s HCP customers. Contact me at smurphy@nxlevelsolutions.com if you’d like to see a content outline or course demo.

Thanks for reading!

Sean Murphy
Editor
Compliance Training Insights Blog