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Introduction

Hi, my name’s Dan Bond. I’m the Learning and Development System Manager for Hull University Teaching Hospitals NHS Trust up in Hull.

What does compliance mean for your organisation?

Our trust values are: care, honesty and accountability. And actually having staff that are compliant means that we have staff that are trained, and if we’re talking about providing the best care to our patients, that means we need staff that are up to date.

They understand all of the latest legislation, but also the latest thinking on a whole range of topics. So if we’ve got staff that are compliant, that means that they have done all of the learning that we would consider they need to better provide good care to our staff and patients.

And also we are accountable. So, individually, staff are accountable for making sure that they are compliant with all the training that we said they need to do, but also we as an organisation are accountable to our regulators, so the CQC, and to a whole load of other organisations that we are involved with to make sure that the staff that we have are compliant and are providing the care that they should be providing.

When the Care Quality Commission inspects us, one of the things they will look at is compliance against training. Not necessarily just as a number in itself, but because if your organisation is not compliant, that is a wider sign of - you haven’t got the right systems in place to make sure that things are working properly.

So the CQC looks at things like, is the organisation well led and part of that good leadership is that the board knows what the compliance looks like for the Trust and is putting systems in place to make sure that it remains high.

How do you assess behavioural compliance?

It is tricky. We obviously do an awful lot of reviewing of incidents and never events and what have you, and particularly if something is as serious as being a never event, something that should never happen, then there is a pretty extensive investigation as to, well, how did we end up having this problem?

But anytime that something goes wrong, there is a team that is looking at, well, why did it go wrong? And quite often they’ll be looking at things like, actually, are the staff that were involved compliant with the training related to what went wrong?

How do you manage compliance with a high-volume and mobile workforce?

So a lot of what we would consider compliant is nationally led. So, there is a list of topics that every NHS member staff should be compliant with, and in a lot of cases there’s also, how frequently should they be doing that training to be considered compliant? So actually some of it is very much localised, but a lot of it, it would be the same whichever NHS organisation you went to and the advantage of that is that if you do training in other NHS organisations, as long as it’s being done to the same standards, we can often accept that training.

So particularly for staff groups like junior doctors where they move between organisations sometimes every six months, that’s really important.

So then they're not having to do training over and over again. But equally, if you work in a number of different organisations at the same time, then we would also want to be able to share that so that you’re not having to do the same training twice in two different places. To enable that movement of data between NHS organisations, we had an interface developed between the NHS Business Authority, who run the National HR Systems and Chambury Learning Solutions, who are our Totara partner, and that then allows a set of data to be exchanged both from us out to other Trusts and other Trusts to us.

What is the user experience of compliance?

This is the new version of our front page, and I’m very much trying to move to a situation where we surface as much data as we can, so that people know what they need to do. So for instance, I’m logged in as a test user. I have a section here which tells me these are the outstanding topics which I should have done.

I’ve also got graphs on the right hand side telling me for learning that recurs, so things you have to do over and over again, what am I compliant with and what am I not? What is coming up for being due and for topics that are once only, again, what am I outstanding for and what do I need to do? If I click through, then what you can see is a list of topics that are outstanding, ones that are going to expire, when they’re expiring, things that I’ve done previously and are now compliant with, and also the same information for my team. So I don’t just want to know - am I compliant? I want to know for the people I’m responsible for, are they compliant?

So if I go into the “Once only” topics, I can see for my test users, these ones need to do the Major Incident training, for instance. As I say, it’s trying to give staff the option of making it as easy as possible. So there are buttons for the various bits of what is my required learning, reporting on things, so as a manager of people, I would have a list of reports here, which I can then run through and see for my extended team: what is their compliance like? When are they booked onto training?

So one of the courses that we’ve used an awful lot of Totara features for is our Neonatal ICU Induction. So when you are a new nurse working on the neonatal intensive care unit, there is a huge amount of learning you have to do in the first 18 months you’re working there. Because even having been trained as a nurse, there’s a lot of very specific things when working with tiny babies. So we use a range of activities in here from simply giving people access to workbooks, et cetera, to tick lists. So, the activities that you would do for the admission of a baby and you as an individual would have experienced staff who, when they’ve observed you doing that particular activity, will then give you a tick to say, yes, I’m comfortable that they’ve understood how to do it. We’ve also got some self-directed learning for things like doing drug calculations because working with very tiny patients means that the way you calculate the drugs that are been given to them is a bit different because it’s very tiny amounts and very tiny numbers. And equally, we’ve also used the assignment activity so that if you’ve got some paperwork that’s been signed off and you then need to better submit it to the team as evidence, you can then have it printed, signed, scanned in, and you can just send it to the appropriate team and they will then mark it off as complete.

What role does performance management play in maintaining compliance?

Yeah, so at the moment, we would expect managers to be having conversations with their members of staff during annual appraisals, where they’ll be looking at compliance with them and saying, are you compliant with your training setting objectives to say you should be compliant with your training? When we are looking at moving potentially towards Totara Perform, one of the reasons for that would be so that we can more tightly integrate things like training compliance with appraisals, with check-ins, et cetera, so that there is much easier ways to check: Are you compliant with your training? It’s part of the appraisal rather than something you just discuss and make notes about.

We’re looking at talent management as well, and part of that’s gonna be not just compliance, it would also be other learning that helps you to move towards that aspirational position of we would like to progress you in your career.

Which Totara features support your compliance programmes?

We use certifications and programs to push learning out to staff and there are, as with any of these things, a number of different ways that you can achieve compliance with training. So what we are looking at is to say, actually, for this group of staff, what are the appropriate ways that they could become compliant with their training?

So for example, if I was to go into my fire safety nonclinical, it says: You could do a webinar or you could do new learning. Or you might be the department nominated fire officer and therefore you could do either the e-learning or the face to face version of that, or potentially you are a first responder, so you are one of the first people on on site, or even potentially you are going to be doing the evacuation or extinguishers training that a clinical member staff does because you are appropriate to handle those things.

And the same would be true of programs as well. We can say these are a number of different ways that you can do it, but what drives those programs and certifications is dynamic audiences. So when you are identifying a member of staff and to say, which sets of training should they be doing, it’s sometimes quite a complex picture.

It’s fairly easy to identify that a doctor or a nurse is a clinical member staff and should do a set of training that reflects being clinical. But we have hundreds of different jobs in the NHS and part of that is some of those jobs don’t necessarily easily fit into clinical or non-clinical. So therefore we need to go tailor everyone’s training individually to their role and what’s appropriate for them.

But equally for a lot of it dynamic audiences and being able to identify based on bits of staff data, how is your job coded? Which department you work in? Do you have staff assigned to you? Then allows us to add new staff to the system and not have to think, now we have to add training manually to them.

The system automatically picks up, it knows you’re a nurse, you work in A and E, you therefore need to do X, Y, and Z training because you work in A and E, you also need to do this specialized A and E training that is only for staff there. So some of it is in custom fields. So there’s quite a lot of staff data that comes from our HR system and we use the HR import to update from the HR system a couple of times a week, and based on a lot of that data, we can then form a pretty good picture of what is your job like, how are you coded, what training should you be doing? We’ve also got hierarchies as well for things like - your department sits within this group of departments, which sits in this wider group - because sometimes the training is everyone that sits in that wider group needs to do it except for this department, so we can have quite a finely grained control over who should be getting X, Y, and Z bits of training, and in some cases, actually they will do the same training, but on different schedules, so we’ll push out the same training to one group as to another, but say this group needs to do annually and this group needs to do every three years.

We do use dashboards a little bit to surface that data and make it obvious to people what they’re needing to do and reporting as well.

And we’re trying to encourage managers to take ownership of their staff's learning and what their compliance is like, and also trying to get individuals to take ownership of their own learning. So if we give them the information of this is what you need to do, this is what you should have done, we would then expect those staff to be looking at that on a regular basis and checking, am I going to expire for something? Do I need to update myself? And we wouldn’t just expect it to be a central function of our human resources team, nagging departments and saying, your compliance is only this for this topic. We would expect managers to be looking at it and identifying, we’d expect individuals to be doing the same.

We use some notifications, so we don’t want to overwhelm our staff with hundreds of emails from the system saying: you are required to do this, this is expiring. But we are moving towards a place where we will start to send some notifications. Particularly in areas where it’s quite important that we maintain a really high level of compliance, and it’s not always easy to get that.

How do you report on compliance internally and externally?

Internal reporting, we obviously use Totara reports, dashboards, et cetera, but we also do, we pull a lot of data out and we put into our business intelligence solution trying to enable the right people to see the right information. In terms of our regulators,
that’s a relatively ad hoc thing of the regulator comes in, they inspect us, they say, can you show us the compliance for these topics? And what’s really nice with Totara is it’s really easy to be able to report that out. I know that other organisations really struggle. They’re asked, can you show us what the compliance is for these individuals or for this area or for this topic? And they have real problems doing a sort of out of cycle report for what is that compliance or even to dig down into the data in the way that the regulators would like.

How do you know if your compliance programmes are a success?

You can obviously look at the numbers. So you can say, is this particular area, is the whole organisation meeting its key performance indicators? Are we hitting 85% compliance for this topic, or 95% for that? But it’s also about the things that do or don’t happen outside of it. So are we having less incidents with people using moving and handling equipment wrong? Are we having more people who are having a positive experience of treatment with the organisation because we’ve integrated equality and diversity training into everyone’s learning.

I suppose the other thing that we can see as a real success is not necessarily that our compliance has improved, but our compliance has stayed the same when there’s been external influences. So when Covid happened, initially an awful lot of organisations had a pretty sharp drop in their compliance because suddenly they’re unable to do any face-to-face training with staff. And there was a bit of a cliff edge of all those staff that were coming up for renewal couldn’t renew anymore, Because we’d got a culture of actually people picking out the most appropriate route for their completion, a lot of people are very comfortable with using e-learning, so therefore, our compliance rates very much didn’t change when Covid started. And we’d then be able to reintroduce some face-to-face and some and some webinar training. So actually we’ve done really well to be able to keep things as they were.

What tips do you have for other organisations with compliance requirements?

I guess the first one is get your audiences right, because dynamic audiences in Totara are a really powerful feature. And if you can drive those audiences in an intelligent way, if you can build them automatically, rather than having to do a lot of manually adding individuals to sets of training, it will make your life easier, but also it will give a really fine grained control over: Who should be doing what? Do we have the right set of people?

I guess also, get your data surfaced. Make it, put it in front of people so that they can see this is the compliance for myself, this is the compliance for my team. If you are a leader in the organisation, this is the overall compliance for the organisation because that
then, if they’ve got the data, they can then act on it.

And finally, it’s about giving staff the ability to do the right thing. So make it easy for them. Don’t make it difficult for them to stay compliant. Say to them, these are things you need to do to stay compliant, because ultimately staff want to be on the right side of that. They want to be looking after their patients effectively, and that means making sure they’re up to date and know what they’re doing.