There is a disconnect in learning and development departments in most large companies: On one hand there is an obligation to meet regulatory requirements for compliance training. On the other, there is the drive to improve business outcomes by creating a culture of learning.
These two forces can clash when expectations are not well defined.
Suppose you are a learning coordinator in Environmental Health and Safety, and your company has just been cited by OSHA for people leaving fire doors open.
- You create a course about the importance of closing fire doors.
- You promise the OSHA inspectors that everyone at the company will take the training.
- Three months after launch, you pull up a report that 3,000 people have taken your training.
Unfortunately, there are 60,000 people in the company. Your boss must explain this to the C-suite and comes back with a mandate to enforce compliance.
Now suppose you are in talent development in HR, and you are in charge of an initiative to create a learning culture. You’ve created an engaging landing page on the learning experience platform (LXP) that encourages people to explore learning opportunities. When you give a demonstration of the process to your stakeholders and you click on a course in the LXP, an alert pops up saying that you are out of compliance on your “Importance of Closing Fire Doors” requirement.
- The VP of HR says, “Oh yeah, I’ve heard this is a big problem. Some people are having trouble logging into the LXP, or they’re taking the course and not getting credit. The help desk is getting swamped with tickets."
- The VP of Legal says, “Yeah I got a nasty email from my boss that 25% of my organization is out of compliance."
- The VP of Manufacturing says, “My people don’t even have access.”
- The VP of Sales says, “My people hate the training.”
The demonstration is a failure.
What is going on here? Why do these two critical business goals seem incompatible? To understand, let’s look at the underlying forces at work.
Underlying forces can create conflicting goals
Compliance training is an exercise in risk mitigation. It is possible that in the course of doing their work, employees may inadvertently cause harm to themselves or others. In our example, an open fire door can cause more danger in the event of a fire. Regulatory agencies like OSHA require companies to establish processes that reduce the risk of this happening, and they want to see evidence that employees were properly trained on these processes.
Most L&D departments take this one step farther. They assume that compliance means 100% adoption. This sets up a chain of events that can be very disruptive to the business. Setting a requirement of 100% means that any issue with identity management, system access, records of employment status, or reporting hierarchy will create compliance issues that need to be mitigated. These “mitigations” can take on a life of their own, taking up resources and creating a negative employee experience.
Learning culture is important to businesses that understand that each employee’s development is critical to the growth, resilience, and adaptability of the business overall. It is part of a greater trend of focusing on the employee experience. The goal is to make learning easily accessible and relevant.
These two efforts are not isolated from each other: If an employee is frustrated with the process of compliance training, then they will not be open to exploring more learning. If an employee values self-directed learning, they will bristle at mandated compliance training.
The solution? Managing expectations
The solution to this conflict is in setting realistic expectations.
Expectations about compliance
Let’s start with that assumption that we need to track 100% of compliance. Regulatory agencies are aware that there will be issues in maintaining compliance. Changes in organizational hierarchy, temporary or long-term absences, changes in work assignments, and global workforce changes for example, can cause lapses in compliance tracking.
What is important is that you have a remediation plan that is feasible, well documented, and clearly communicated. If someone finds that they have moved into a role with an unexpected training requirement that they cannot meet, they should be able to work through their manager to resolve the issue without causing a regulatory incident.
By setting a more realistic expectation that compliance issues come up and that they can be addressed, the pressure on the system of a zero-tolerance attitude can be avoided.
Expectations about reporting
The next assumption to tackle is the insistence on reporting on 100% of the data. Obviously everyone who is responsible for compliance should be compliant; however, trying to report 100% of the target population all at once has the following drawbacks:
- All issues that are found need to be resolved before the reporting is complete, so it's harder to get at issues fast.
- 100% isn’t realistic so a lot of time is spent chasing down outliers.
- 100% compliance reports are used punitively against business leaders, so they fight back by asking for more granular detail that takes up too much time.
The alternative to the 100% approach is random sampling. When doctors prescribe a blood test, they ask for a sample, not all the patient’s blood. When marketers ask for television ratings, they get sampling, not a survey of every viewer in the world. Statistical sampling is a respected method of determining the state of a system. Why can’t it be used for compliance reporting? Your company’s quality assurance department is probably already using this technique for regulatory reporting. They probably already have an accepted method to use. As long as the process is well documented, it should be acceptable to regulators. Sampling also has these advantages:
- Sampling allows teams to address issues faster
- Sampling processes are easy to document
- Outliers can be spotted more easily
- It’s easier to set expectations with management
Now for the learning culture expectations. Not all learning is about fireworks. There has to be compliance training, and it isn’t always that exciting.
Here’s what you can do to keep it from disengaging learners before they get to the good stuff:
- Set expectations with clear communication: Explain why compliance courses are necessary, and provide clear guidance on getting support.
- Reduce friction for the learner: Make courses as short as possible (understanding that some regulations require a specific amount of time spent by the user in the course).
- Remove barriers to accessing courses and address any issues with user data that can cause erroneous assignments.
- Separate the user experiences: Set up landing pages on the LXP that inspire people to take courses for their development. Communicate about mandatory compliance training with consistent, clearly marked emails.
Businesses need to mitigate risks through compliance training and they have to develop their people to remain competitive. In this volatile environment, no company can afford to let either of these two efforts slide. L&D departments need to focus on setting realistic and clear expectations about how compliance is managed and how a learning culture can be developed—without letting one get in the way of the other.
Explore leadership issues with your peers
Shifting learning culture and adopting new training strategies can be an uphill climb; learning leaders do not need to undertake this challenge alone. Share what works, and explore the strategies and skills required to navigate the needs of today’s ever-changing workplace with your learning leadership peers.
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