Managing Compliance Training
Compliance-related training is a very big business. Bersin & Associates estimates that complying with regulatory guidelines accounts for as much as 30% of training-related technology expenditures. Many technology expenditures (LMS systems in particular) have been justified simply on the basis of keeping more accurate and accessible compliance records.
Our current research has revealed some interesting challenges in the implementation of compliance training and technology:
Compliance Requirements Demand Widely Differing Processes
An interesting aspect of compliance training involves the levels of complexity imposed by the various regulating agencies. Some require nothing more than a record of completion (e.g., transportation agencies) while others impose specific technology capabilities to ensure that electronic records are not compromised (e.g., FDA CFR Part 11). FDA compliance, for example, mandates that every training process be versioned, archived, and updated as manufacturing or process procedures change. These requirements could impact the instructional material, the system used to maintain records, and potentially even the delivery mechanisms. For instance, when a manufacturing or safety-related procedure changes, the compliance system must identify all workers who were certified on the prior process and mark them for “recertification,” for example. Most enterprise-wide programs, such as sexual harassment, are monitored by the company itself — not a specific government agency. Even these, however, must be tracked for legal protection and internal personnel administration.
International Requirements Vary from Country to Country
Meeting international compliance requirements adds additional complexity. Companies that operate globally may be under the jurisdiction of a number of agencies – each with different requirements. For example, the compliance training for a Holland America (profiled in a case study just released by Bersin & Associates) is monitored by over 100 agencies from all over the world.
Such disparate international regulations will impact data consolidation strategies. Disparate data from different programs may need to be combined in order for the company to monitor global compliance: programs with different languages typically have different program names or identifiers. Even the data itself may vary by country (for instance, some EU countries prohibit the capture of performance metrics for some training programs). Often the learning management system (LMS) is the only “single system of record” for all these complex global compliance records.
Program Design Varies by Compliance Needs
|Minimizing delivery costs is often a primary driver for compliance-related programs. Obviously, this makes electronic delivery the preferred and often exclusive choice. But mission-critical programs that involve safety procedures, security processes, or processes to minimize legal exposure demand true mastery to be successful. These programs are better left to a blended model. The chosen technology may need to support a variety of program designs and still capture sufficient data for record keeping. For example, some applications may require tracking of specific blended activities while others may need only a score or completion status.||
Content and Systems Integration Must be Considered
Our research also indicates that integration with other content and data systems is quite common for compliance training. Off-the-shelf content is available for many topics and may require some type of integration or testing process to ensure that it will launch and track correctly with your chosen technology providers. Many on-demand LMS providers have integrated their systems with commercially available content, making the process much smoother. These systems are becoming popular with smaller enterprises or departments that need turnkey solutions. Similarly, some agencies provide their own data repositories that companies use to submit their compliance records. Integration points or, at a minimum, some type of data mapping may need to take place to ensure the information can be accurately tracked by both the corporation and the regulatory agency.
LMS Systems Have Different Feature Sets for Compliance
Learning management systems are one of the primary systems used to store, manage, and report on compliance programs. While most have basic features to track compliance, scores, and certification date, each system has different ways of dealing with expirations, recertification needs, audit trails, and reporting. It is important for learning and compliance managers to take their own specific compliance reports and make sure they can be handled by the chosen LMS. Industries such as healthcare, engineering, legal and accounting, for example, have a wide variety of certification and record-keeping requirements which often vary by state. Many use arcane measures of compliance such as training units, credits, degree units, and others. Many of our research clients with highly sophisticated LMS systems tell us that these systems do not track these programs well. We strongly recommend that you test your organizations’ specific needs in your LMS before you select a system.
While not an exhaustive list, these considerations should be taken into account especially by organizations that spend heavily on compliance training such as those in financial services, healthcare, transportation, and manufacturing. Bersin & Associates research members can access case studies and upcoming Learning Solution Maps® that provide more insight in dealing with these and other challenges.