Regulatory changes in recent years have led to increasing pressures on companies to ensure they are facilitating and managing the right compliance training program for their employees. Regulators and companies alike know that employees forget things they’ve learned over time - it’s a part of being human - but it’s not something that bodes well for maintaining a culture of compliance within a corporation.
Companies have historically approached compliance training as a once-a-year requirement, simply checking it off the list with each passing year. With this approach, companies are effectively defining the effectiveness of their compliance program based solely on whether employees sat through their annual training. A successfully trained employee is defined simply by their completion of that one training session.
Recent rulings in compliance-related lawsuits have placed a heavy price tag on the value of a truly effective compliance program. In a recent Foreign Corrupt Practices Act (FCPA) case, the U.S. Securities and Exchange Commission (SEC) charged a manufacturing company with a failure to implement adequate compliance program controls, and a hefty fine of $2.03 million to settle. In this specific case, the SEC determined that a firm can be in violation of securities regulations based solely on the inadequacy of its compliance program.
As scrutiny from regulators continues to grow, the once a year training approach is becoming a thing of the past. Organizations are turning to programs that leverage MicroLearning, focused on delivering training in small, specific modules, to ensure their compliance program is effective and relevant for employees.
Chapter One
Regular Training – finding the right pattern
Humans are by nature forgetful of certain information if they are not actively and regularly practicing what they’ve learned. In 1855, Hermann Ebbinghaus hypothesized that there was both a learning curve, where people take time to learn in the first place, and a forgetting curve, where individuals lose what is learned if that knowledge isn’t used regularly.
Research suggests that learning spaced out over time helps people learn more quickly and remember better [2] . Academics have for ages leveraged regularly-scheduled teaching and testing strategies to help students move further along the learning curve, at a faster pace, and fight off the effects of the forgetting curve. This practice has proven to be effective in a wide variety of use cases beyond academia from sales training to medicine and even creating effective ads to grab a viewer’s attention.
The knowledge gap between what is learned and what is actually retained by an individual presents an inherent flaw in the once a year compliance training approach that companies, both large and small, have taken for years. In order to preserve the information that is learned in training, individuals must use this knowledge on a more regular basis. Companies that use training approaches with a select group of relevant lessons spread across a period of time can create a change in employee behavior, causing them to more easily remember the lessons learned.
A body of research on a select group of students proved that those who learned via distributed, short lessons remembered more than those who learned the same lessons in one day of studying. Scientists Kristine Bloom and Thomas Shuell taught 20 new vocabulary words to students, breaking them into two groups. One group focused on learning in one 30-minute session and the other spent time learning in 10-minute sessions on each of 3 consecutive days. A test taken four days after the lessons occurred showed that the group that learned in shorter training sessions over 3 days was able to remember 15 words correctly while the group with only one session remembered only 113 .
Without regular practice of proper compliance procedures, employees can fail to recognize red flags when they present themselves, putting companies at risk of committing compliance failures. These can range from an issue of sending a confidential email to the media to a lack of proper oversight of critical financial data. All of these have a real impact on the success and reputation of an organization.
Chapter Two
Keep it Relevant
The human mind is better equipped to remember certain lessons if they are closely related to experiences a person has every day or on a regular basis. Relevance can take many forms when it comes to training – from providing alerting tools for recent regulatory changes to creating training examples that speak directly to each employee’s role in the company and even incorporating real-world examples from news headlines.
As every employee is likely to run into certain compliance regulations given their job role and primary focus within the company, it’s critical that organizations consider the relevance of their training program as related to different groups within the organization. By delivering relevant training lessons focused on the items that are likely to surface in each employee’s day-to-day work environment, companies are providing their team with the information they need to more quickly and easily notice potential compliance issues.
For even the most practiced compliance professional, it’s easy to get lost in the barrage of new regulations and requirements. As one example, the United States Justice Department recently issued a memo putting more pressure on senior level executives rather than just corporations, encouraging companies to take a closer look at their internal policies, including their training strategy [4].
With the media paying even closer attention to stories of regulatory fines and other penalties for corporations of all sizes, it’s hard not to read the news without seeing at least one story about a company paying a hefty sum for failed compliance practices. By incorporating these real-world examples into a company’s training program, employees can better understand the true implications of failing to comply with relevant rules and regulations.
When it comes to ensuring that employees are up to speed with regulatory changes and new rules, alerting capabilities within a regular training module provides the immediate delivery of important information that companies need to ensure they are training employees in a timely fashion. Systems that incorporate this alerting, allowing companies to roll new regulation into their workflow, can also help companies by equipping them with the audit trail and records they may need in conversations with regulators and the Board.
New compliance regulations across various industries now frequently include specific sections related to the training needed to ensure compliance with each rule, showcasing the importance of relevant training for industry professionals.
Chapter Three
Repeat Key Lessons
Research has found that the human mind retains information more quickly when it is repeated in regular intervals. “Say it, say it, say it again” has long been an adage and best practice in the advertising and marketing space. Advertisers have used repetition for decades as a key way to ensure consumers remember their ad, and therefore their brand, thus driving their purchasing behavior toward their product.
Companies are beginning to take a page from the advertiser’s playbook as they look to create a training program focused on repeating key lessons at regular intervals. This method helps facilitate the learning process for employees, pushing them further away from the forgetting curve and sending them more quickly along the learning curve.
Repetition alone helps individuals remember information better and faster, but repetition through various learning methods targeting the variety of ways that individuals learn is key to delivering effective training.
No matter what learning method is preferred by each employee, companies can make sure their training experience is focused on their learning needs through the use of video, audio, real-life examples and quiz questions. Research by Walter Burke Barbe and colleagues alludes to three learning modalities that humans take on including visual, auditory and kinesthetic. These modalities are often identified by the acronym VAK [5].
Visual learners are more likely to remember information when it’s delivered to them in a visual way as through images, video or print – a simple speech isn’t going to help them retain information unless it’s accompanied by a slideshow or video.
Auditory learners remember better when information is delivered to them via voice as in a video – just visuals like images and print aren’t going to help them move along the learning curve fast enough.
Kinesthetic learners are more in tune with learning methods that incorporate gesture, body movement and object manipulation – thus training that incorporates interactive Q&A and testing would work well while a simple speech would not help a person learn a specific bit of information.
Repetition through various methods of delivery from visual to audio can be a very effective way to ensure an individual is receiving the right information the right amount of times to retain it. Companies that leverage video and audio can help ensure their employees are receiving the right amount of repetition in a variety of ways, giving employees the choice of the method that works best for them.
Chapter Four
Review Lessons Learned
Research shows that learning designed as short lessons extended over a period of time may not only help learners remember, but also reduce the need for longer training. Allowing for proper time between lessons gives individuals the ability to review what they’ve learned, putting them in a position to better recognize places where these lessons can be applied.
As employees face the challenge of time constraints in their day-to-day work life, a distributed pattern of learning helps solve for the busy learner problem. Under the once-a-year training model, busy employees are often distracted during their annual session and thus not paying enough attention to important compliance lessons while they are occurring.
While individuals may be able to answer questions immediately after this cramming-style session, the information quickly escapes their memory as they return to their daily routine. By suggesting or requiring that employees revisit lessons learned in a more regular fashion and reflect on how they can be applied in their everyday life, companies can make training even more relevant and timely and therefore effective.
As senior management and regulators demand a greater level of visibility into reporting on compliance efforts and training, traditional methods of manual record-keeping are becoming less effective. Real-time online learning management systems that can record full details of training, including courses and a comprehensive audit trail, can help companies demonstrate training compliance and effectiveness.
Chapter Five
Conclusion
Measuring the effectiveness of compliance training is quickly becoming a core focus for companies across size and sector as regulatory scrutiny only continues to increase. Research on intelligence and learning styles is helping organizations develop training programs that meet the needs of each employee and therefore the broader company.
Compliance and training professionals are searching for ways to ensure their training process is doing its job – creating a workforce that understands how to mitigate risk in the workplace. With more and more companies and executives throughout the world facing external and Board pressure to implement the most effective training strategy across the organization, companies are approaching training in new, interactive ways.
By implementing a training program that incorporates regular intervals of relevant, repeatable lessons with ample time for review, companies can better avoid the threat of the knowledge gap and the very real effect it can have on an organization’s success.
Chapter Six
References
- http://www.sec.gov/News/PressRelease/Detail/PressRelease/1370542384677
- Caple, 1997; Castel, Logan, Haber, & Viehman, 2012
- Bloom, Kristine C; Shuell, Thomas J. Effects of massed and distributed practice on the learning and retention of second-language vocabulary. Journal of Educational Research. Vol 74(4) Mar-Apr 1981, 245-248.
- http://www.nytimes.com/2015/09/10/us/politics/new-justice-dept-rules-aimed-at-prosecuting-corporate-executives.html?_r=2
- Barbe, Walter Burke; Swassing, Raymond H.; Milone, Michael N. (1979). Teaching through modality strengths: concepts and practices. Columbus, Ohio: Zaner-Bloser. ISBN 0883091003.OCLC 5990906.
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