BUSINESS INTEGRITY PROGRAM
Policy Manual
APPROVED: May 14, 1998
by BOARD OF DIRECTORS
WASHINGTON COUNTY HEALTH SYSTEM
formerly titled “Legal Compliance Program”
Revised 5/2002
25. Training and Education
New Employee Orientation Policy
All new employees will complete the mandatory in-service on business integrity as part of their
initial orientation session. At the time of their probationary evaluation, their manager will
remind them to schedule their attendance at the introductory business integrity training session to
be completed by their first employment anniversary date.
This training program for new employees will include, but is not limited to, a review of the
Health System's Business Integrity policies and procedures. Business Integrity training shall
encompass laws and regulations, specific responsibilities for each department, methods to report
violations, disciplinary measures for violating the Company's policies and procedures, and
proper response to third party requests to interview employees and review information.
This introduction to business integrity will be supplemented by specific training geared toward
the employee's responsibilities. Selecting and scheduling training related to specific
responsibilities is the responsibility of the employee’s manager, and resources are available by
contacting the Human Resource Development Department or Director of Business Integrity.
The Human Resource Development Department and the Director of Business Integrity shall
oversee the monitoring, evaluation, and auditing of the compliance training program. This
includes taking steps to ensure educational videos and materials are current, attendance records
are kept, new employees complete training by a specific time, and new employees acknowledge
in writing that adherence to the company's compliance policies and procedures is a condition of
employment. In addition, the Human Resource Development Department will retain a sample of
the training material, as well as a brief description of the subject matter of the education.
In addition, the Human Resource Development Department and Director of Business Integrity
shall oversee the review of training procedures, including feedback from employees and trainers.
The Director of Business Integrity and Compliance MAC Education Subcommittee shall review
on an annual basis the training program to ensure content is applicable to current policies and
law.
Continuing Education
The Human Resource Development Department and Director of Business Integrity shall monitor
the continuing education of employees and staff of the Health System. The employee's
responsibilities in the organization will dictate the content of continuing education, as well as the
minimum hours of education per year that will be received. This shall include additional training
for employees or professional staff who fail to demonstrate the requisite knowledge to perform
his/her tasks and training as required to educate employees and staff on changes in federal or
state regulations and the Health System's business integrity policies and procedures.
Each manager shall be responsible for utilizing the monthly business integrity training
curriculum materials provided for use during staff meetings. These materials will include
articles, discussion materials and computer-based courses that are pertinent to Health System
operations and its business integrity program. Each manager is responsible for maintaining a log
of this training, including a list of attendees, time spent, and topic covered. Sample materials or
references to their location should be readily available.
The Director of Business Integrity shall also be responsible for disseminating updates of laws or
the Health System's policies and procedures to employees and professional staff via periodic
newsletters, memos and/or e-mail.