COVERSTORY
By Simone Handler
In 2019, Genentech made a transformational shift in its approach to compliance training. Like many companies, it relied on a traditional hours-based approach that documents employees who complete a minimum number of hours of compliance training each year. However, hours-based training never ensured that the training was of high quality or improved employees’ compliance competency.
So, Genentech strategically shifted to a competency-based training approach designed to help employees build a strong baseline of policy knowledge, become familiar with key compliance resources, use good judgment when making compliance decisions and discern when complex circumstances require further guidance or advice.
This transformational shift led to the creation of Compliance Fitness Training, an award-winning online learning program that empowers Genentech employees to own their compliance training. (Figure 1) Genentech’s Healthcare Compliance Office partnered with TiER1 Performance on the design and development of the program, which initially featured 24 e-learning courses tailored for three unique employee groups comprising more than 8,000 employees.
In June 2021, the training program received an LTEN Excellence Award in the Industry Partnership (Provider) category. This article will describe the key components that fuel the training program’s continued success and sustained impact.
Instead of a one-size-fits-all approach to training, the Compliance Fitness program provides a strong set of foundational courses tailored to specific persona learner types within each audience. (Figure 2)
For example, certain learners have direct contact with patients and customers, and others are strictly internally focused. Learners need only to complete the courses that are true for their group.
The program features specific scenarios that are relevant to each learner’s everyday work, empowering Genentech employees to apply key compliance principles to their role, navigate gray areas, successfully pass knowledge assessments and confidently handle compliance issues in their everyday work.
To ensure that the training addresses each role’s specific compliance knowledge needs but also remains engaging for learners, the program features cross-functional scenarios that involve more than one role working together, which reflects the reality of the day-to-day work. This personalized design enables employees to take ownership of their compliance knowledge.
To help learners absorb, practice and retain the content, all courses adhere to a five-part structure and follow a creative “compliance fitness” theme. (Figure 3) The program’s courses include:
Compliance Fitness coaches are featured throughout to make the program feel connected to past Genentech initiatives where compliance team members wore matching tracksuits to raise awareness of the compliance coach concept.
The fitness app design motif also infuses the training with elements of fun and wellness. This engaging theme continues to support measurable increases in adoption.
Previously at Genentech, key changes to compliance policy were typically taught through a live training session, followed by an online module. However, because of the scale of the changes being communicated, and the importance of its adoption by all employees in the target audiences, the healthcare compliance team created a new curriculum for each audience. This design ensures the training is robust, holistic and learner-centered, and the program includes knowledge assessments to ensure learners understand key concepts and guardrails.
Since the Compliance Fitness program’s initial rollout, Genentech has streamlined its annual compliance training to occur every fall during the back-to-school timeframe, which sets expectations for employees. The online learning format also allows Genentech to reserve live training for more advanced, complex and nuanced content.
Genentech’s compliance team continues to tailor the Compliance Fitness program to its learners and the industry’s changing landscape, adding new courses and revising existing courses as needed.
Like many organizations, Genentech employees must have a strong foundation in compliance and pass yearly compliance assessments to meet company requirements and industry standards. For that reason, employees are only required to complete the role-based program one time (when they join the organization or switch roles) and then complete annual quizzes that confirm their competence and understanding of compliance guardrails.
The Compliance Fitness program is updated annually to reflect policy changes, better align the subject matter to each audience and make the experience more engaging for employees. The annual competency quizzes are also updated annually.
The Compliance Fitness program was designed in alignment with the best interests of Genentech overall, including its employees, clients and partner organizations.
The courses don’t just cover the basics of compliance — they teach a way of thinking about compliance that has shifted employees’ practices in their everyday work. This shift has led to improvements in compliance reporting, which benefits everyone at Genentech, and contributes to an overall sense of empowerment for employees, which in turn creates more positive interactions between employees and their leaders, clients, partners and others.
To confirm that Genentech’s compliance transformation efforts drove real-world impact, it was crucial that learners completed the training and successfully passed their knowledge assessments with a score of 80% or higher. A completion rate exceeding 95% was achieved for the initial training, and the annual assessments continue to reach or exceed 95%.
Even more impactful than the program’s impressive initial completion rates are the gradual cultural shifts it has cultivated throughout the organization. Since Genentech’s initial launch of the Compliance Fitness program, compliance leaders have identified sustained behavior change among participants.
Core messaging embedded throughout the program reinforces Genentech’s strategic framework for compliance problem-solving; that is, the 3 Ps: Purpose, Process and Perception. (Figure 4) The program’s rolebased scenarios incorporate the 3 Ps, allowing employees in all roles to apply the framework to on-the-job situations.
The 3 Ps framework has since become universally adopted throughout the organization, not only in Genentech compliance policies, but importantly, with senior leaders integrating it into their day-to-day thinking and coaching conversations, and employees applying the framework to everyday situations. We see numerous examples that show our employees applying the 3 Ps framework when navigating a compliance issue, particularly in nuanced situations.
Genentech’s compliance leaders have also experienced an increase in the complexity of questions that employees present to the compliance team, which serves as evidence that the program is achieving its original goals of equipping employees with baseline knowledge, enabling employees to use good judgment, and helping employees discern when to seek further guidance. In fact, within the first year of the training’s rollout, there was an approximately 50% decrease in basic or simple policy questions received from learners.
Genentech recently repurposed the Compliance Fitness program to create tailored learning for its rare disease field team. The compliance team partnered closely with members of the rare disease team to collect feedback and real-life scenarios to ensure the content met their unique needs.
The compliance team was able to create the new courses much more quickly than if it had created them from scratch; it modeled the new courses after the Compliance Fitness program’s structure and leveraged a developer’s toolkit of screen layouts and content templates, making tweaks to the content and replacing specific scenarios where appropriate. Because of this, the Compliance Fitness program continues to expand its reach and have great impact across the Genentech organization.
Since Genentech’s launch of the Compliance Fitness program, other company affiliates (Genentech is a member of Roche Group) have shown a keen interest in using it as a model for their new compliance training initiatives. Genentech has been more than happy to share its approach and successes with its colleagues across North America.
Simone Handler, J.D., is the senior director of healthcare compliance training & operations in Genentech’s Healthcare Compliance Office. She can be reached at handlerhutchinson.simone@gene.com or through linkedin.com/in/simone-handler-jd-3459439.
