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Ethics & Compliance Training: Are We Having Fun Yet?

Ethics & Compliance Training: Are We Having Fun Yet?

Mark P. Graves, J.D.Mark P. Graves, J.D.

Assistant Ethics & Compliance OfficerAssistant Ethics & Compliance Officer

TAP Pharmaceutical Products Inc.TAP Pharmaceutical Products Inc.

Mark P. Graves, J.D.Mark P. Graves, J.D.

Assistant Ethics & Compliance OfficerAssistant Ethics & Compliance Officer

TAP Pharmaceutical Products Inc.TAP Pharmaceutical Products Inc.

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Guiding PhilosophyGuiding Philosophy

“The great aim of education is not knowledge but action.”

- Herbert Spencer

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Overview

• Putting Theory Into Practice: Communicating with the MTV Generation and Making Compliance Training Interesting, Fun and Effective

• Know Your Audience• Have the Right Resources/Team• Use Effective Marketing to “Brand” YOUR Product• Use Relevant Case Studies • Use Multiple Media to Communicate/Train• Dare to Laugh and Poke Fun at Yourself• Create Positive Incentives

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Making Compliance Training Fun & Effective

Know Your Audience

• Industry Sector

• Internal

• External

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Making Compliance Training Fun & Effective

Know Your Audience

• Industry Sector

• Pharma

-- Sales & Marketing

-- Corporate Office (R&D, Finance, QA, HR, Legal, MIS, etc.)

• Hospitals, Health Systems, Physician Practices, Managed Care Organizations, etc.

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Making Compliance Training Fun & Effective

Know Your Audience • Internal

Board Executive Management Functional Areas

– Senior Management– Mid-Level Management

Employees Stakeholders

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Making Compliance Training Fun & Effective

Know Your Audience• External

Government HHS

– OIG– FDA

DOJ Congress

Media Public

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Making Compliance Training Fun & Effective

Have the Right Resources/Team

• Resources

• Senior Management Support

• Time

• Money

• Technology/Systems

• People

• People –

• Complement your skill sets

• Emphasize communication skills

• Emphasize credibility

• Seek diversity

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Making Compliance Training Fun & Effective

Use Effective Marketing Techniques to Brand YOUR Product

• Create a theme, recognizable brand, logo

• Use visual and vocal branding through color, sound

• Pay attention to details

• Font type, size and color

• Use of punctuation

• Apply your brand to all of your materials

• Code of Conduct

• Training materials

• PowerPoint presentations

• Displays and posters

• Speaking opportunities

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Making Compliance Training Fun & Effective

Use Relevant Case Studies

• Tailor training to real-world issues that your audience experiences

• Makes it real, more memorable and more effective

• Use role plays or some form of interactive participation

• Video vignettes

• Case study teams in live training

• Interactive computer questions

• Inject humor when possible but strike careful balance not to go “over the top”

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Making Compliance Training Fun & Effective

Use Multiple Media to Communicate/Train

• Redundancy of message can be good

• Resources allowing, use

• Live training

• Computer-based training

• Voice-mail

• E-mail

• Written materials

• Web-based materials

• Audio & video tapes

• Do NOT rely on any ONE medium.

• Seek to complement and enhance different forms of training.

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Making Compliance Training Fun & Effective

Dare to Laugh and Poke Fun at Yourself

• Be yourself

• Self-deprecating humor works

• Use seriousness and perceived negativity of subject to lighten tension.

• Recognize up front that this stuff can be dry and boring

• Openly express intent NOT to demonize or play “Gotcha!”

• Focus on service-oriented approach, partnership

• Openly seek to have fun and laugh at yourselves

• Don’t overdo it; strike a balance

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Making Compliance Training Fun & Effective

Create Positive Incentives

• Add ethics & compliance performance criteria to performance evaluations where achieving goals lead to financial rewards

• Create team contests involving functional areas, divisions etc. where “winners” will be rewarded

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Multiple Dimensions of Compliance EffectivenessMultiple Dimensions of Compliance Effectiveness

Macro – Organizational Impact Legal Operational

Micro – Programmatic Impact Structural Substantive Effort/Input Outcomes/Results

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HCCA Resource DocumentHCCA Resource Document

“Evaluating and Improving a Compliance Program: A Resource For Health Care Board Members, Health Care Executives and Compliance Officers”

Available on home page of HCCA website:

www. hcca-info.orgwww. hcca-info.org

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Positive Communications

Define Ethics & Compliance Positively as “a way of doing business that adds value.” Ethics & Compliance =

Precision + Accuracy = Better

Information/DocumentationBetter Decision-MakingHigher Quality/More Efficient

OperationsMore Competitive PositionLower Risk of Violations

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Positive CommunicationsPositive Communications

Counters Negative Perceptions that Ethics & Compliance = Added Costs Administrative Burdens Imposed Rules and Regulations Negative Impact on Business “A pain in the …”

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What’s Ahead?What’s Ahead?

Empirical Measurement Using Technology

Accountability

More, more, more….

Compliance Effectiveness

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What’s Ahead?What’s Ahead?

A Theme of Partnership and Common Purpose Between Public & Private Sectors

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Food For ThoughtFood For Thought

“With regard to excellence, it is not enough to know, but we must try to have and use it.”

Aristotle, Nichomachean Ethics, circa 340 B.C.

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Guiding PhilosophyGuiding Philosophy

“The great aim of education is not knowledge but action.”

- Herbert Spencer

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Final ThoughtsFinal Thoughts

Good compliance is good business!

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Contact InformationContact Information

Mark P. GravesMark P. Graves

Assistant Ethics & Compliance Assistant Ethics & Compliance OfficerOfficer

TAP Pharmaceutical Products Inc.

675 North Field Drive

Lake Forest, IL 60045

Tel. (847) 582-6529

Fax. (847) 582-5002

e-mail: mark.graves@tap.com

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Thank You!Thank You!Thank You!Thank You!