In case you missed it: Hui Chen, the DOJ’s outgoing compliance expert, weighed in on compliance training this weekend.
Here’s the article, which, like everything Hui writes, is great.
The thrust of it is this: drawing from social science, the biggest driver for results is providing practical, how-to information. And "results" means what people actually do, not just what they say they will do.
Specifically, pay attention to her signoff (emphasis added):
Do your compliance training programs teach people what to do as well as what not to do? When it comes to measuring, are you more interested in how many attended, or what their initial reactions were, or whether their behavior changed?
That certainly seems like a common-sense thing to ask—that training should result in changed behavior. And it is consistent with what else we've heard from Hui since she took the DOJ gig.
But it is important to note that this is not how a lot of compliance programs actually do training.
Far too many compliance programs still live in a Morgan Stanley world, where the focus is on something totally different—and that is dangerous.
The Morgan Stanley world.
When I say “Morgan Stanley world,” I mean the view of training that flourished in the wake of the Morgan Stanley "declination."
You can sum that view up like this: the goal of training is being able to show you did training. Because if you do a lot of it and can track it, you might get a declination.
If your view of compliance training focuses on using e-learning and tracking clicks, and you interpret “effectiveness” as “high completion rates,” this is your view.
Whether this was how Morgan Stanley itself viewed the goal of training (probably not), or if it was wise to even view that as a legit declination in the first place (see here), is beyond this post.
For now, let's just acknowlege that this view took hold.
And this view probably helped sell lots of online training courses and learning management software licenses. And it has made compliance training people wring their hands over completion rates, ultimately treating just doing training as a goal in itself.
Which, you know, it isn't.
Training is not a goal; it is a cost. The goal is reducing risk, and training is a tool to do that.
That is what Hui Chen is saying.
"Does it work," not "did you do it.”
That is, Hui's post sets up the goal of training as practical impact, not just being able to prove you did it. And that post is pretty consistent with what she's said since taking the job.
For example, here’s an interview she did with Laura Jacobus in Feb '16. Here's the key quote:
Does the clerk in the accounts-payable room understand his job to be processing payments as quickly as he can, or does he understand that he is supposed to keep an eye on certain things and escalate issues he identifies? Does the new salesperson understand her job to be making the deal at all costs, or does she understand that there are boundaries?
Those are training questions. You can sum them up like this: "do your people understand how to do their jobs compliantly?"
That is the goal of training: have people know how to do their jobs compliantly. Not "show you did a lot of training."
Why this matters.
If you think the goal of compliance training is to show you did training, you are probably wasting a lot of money on bad training that will not accomplish anything.
And you will not actually know it is bad, because you are measuring the wrong thing. Because even the absolute worst training can be "successful" if you define "success" as "people sat through it."
And then, if things do go south, you'll end up in a position where you are unprepared to answer the type of questions the DOJ's compliance expert is flagging for you.
That is a big deal.
And look: I get that measuring behavior change is harder than measuring completion rates.
But so what?
Even if Hui Chen wasn't saying this stuff, the same principle would apply: completion rates do not show if your training worked.
That's because using completion rates as a standard of effectiveness is like saying you should get a good performance review because you came to work every day—regardless of whether you did any work. It is a measure of activity, not value.
If you want your business to think compliance training is valuable, measure how it is valuable. Figure out the risky things people do, train to those things, and then audit those things to measure results.
Or you can attend our session at the SCCE's Vegas conference this year, where we're going to go a step further and explain how to translate those results into dollars saved.
Add value, and show that it was valuable. That is what the government—and your business leaders—are asking you to do.