Part Two: Tips for Training Device Reps
Device Regulation Alert: Safety, Compliance and Reimbursement News, July 23, 2007
In this second of a four part series on the importance of compliance training, we'll tell you when, who, and how to train device company representatives.
When to train
Continually train your sales staff because laws, regulations, and circumstances change and new guidance develop. Train employees at the time of hire and also train them annually, says healthcare attorney Michael Manthei, a partner with Holland & Knight LLP. Things change over time and people learn through repetition, he explains.
Who to Train
Spread compliance training beyond your front-line sales staff to others in your organization.
Train high-level executives and board members, too since upper level support often represents the key to a successful compliance program, says Manthei.
If the people at the top don't understand the compliance concerns facing the overall business they won't recognize situations that require attention. If upper management doesn't know how compliance requirements change from year to year they could potentially let lower-level staff make bad decisions for the company, he explains.
Take additional time to train your audit committee and other staff. As the saying goes, "an ounce of prevention is worth a pound of cure."
How to train
Match your compliance training programs to the roles of those in the class. Try to avoid the one-size-fits-all approach, says Manthei.
For example, focus rep training on their interactions the healthcare professionals they deal with regularly. Representatives dealing with physicians and other providers that use or prescribe the company's devices must be trained in rules concerning issues such as gifts to providers, provider education, and entertainment.
Training for a medical science liaison, or someone connected to grant-making functions would focus more on the compliance issues related to those activities, says Manthei. Similarly, people who determine pricing and discount structures don't normally interact with healthcare providers but they need to understand how market share driven discounts or exclusive arrangements implicate the anti-kickback statute, Manthei explains. Finally, executives, management and the board need a high level view of everything and need to know about all the issues, he says.
Editor's note: In the next part of our series we'll address in more detail how to decide what issues to focus on when training your representatives.
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