Focus first on priority areas where, through a needs assessment or otherwise, risk areas have been identified. Document the training program, and demand participation. Some of this training should emphasize the serious consequences of non-compliance with federal program requirements. Do not expect administration or outside counsel to protect you by reviewing contracts after you sign them. Remember that federal requirements are constantly changing, and that training materials as well as policies and procedures have to be updated continuously.
Training also has to respond to experience in other areas of the compliance effort.
When audits in April show serious coding or documentation problems, do not wait until next January for another training session. Some practices focus training very heavily on new hires. Internal policing Compliance programs are all about self-policing, and it can take many forms. Incorporate periodic monitoring and auditing mechanisms, such as employee interviews, random chart reviews, and prospective billing audits. These identify system weaknesses and the need for changes to current practices or for additional employee training.