The following excerpts are from Chapter 2: Monitoring and Ensuring
Compliance. The full report provides detailed findings on compliance
training and internal communication methods.
Compliance Training
While the level of responsibility that compliance teams hold over
training varies, almost all compliance groups play some role in the
training of other functions. Some groups develop and deliver all
training to do with compliance, whereas others simply provide input to
the training done by the departments themselves. Figure 2.1 [chart
appears in full report] shows that 81% of compliance groups provide at
least some training to other functions, while only 19% do not provide
any training to other departments.
Figure 2.2 [chart appears in full report] illustrates the share of
compliance departments that deliver training to specific functions. For
instance, 71% of compliance departments conduct training for individuals
in marketing. Over half of compliance teams train other functions in
their companies, such as medical affairs, business development,
regulatory, legal and R&D…
Maintaining Open Lines of Communication
Compliance executives agree that open lines of communication, whether
formal or informal, go a long way in furthering the ongoing compliance
efforts at their companies. Whereas tools like reference manuals are
certainly useful, MSLs and other staff benefit more fully when they also
have the opportunity to ask questions of their superiors or of the
compliance team. Compliance leaders should foster a culture of openness
by encouraging questions and feedback and by directing various
department leaders to do so as well. With this in mind, departmental
personnel will not be hesitant to sound questions off of their peers and
leaders, and they will ultimately make fewer blunders.
One way to maintain open communication on compliance topics is to
hold frequent meetings. Such meetings need not be companywide or even
directed by the compliance department, but they should include at least
some representation by the compliance department. For instance, a
company’s vice president of medical affairs would do well to hold
quarterly question-and-answer sessions for medical science liaisons. The
sessions should have at least one compliance officer present to ensure
that compliance-related statements are accurate.
Aside from meetings, which are sometimes difficult to arrange and
orchestrate, other excellent ways to keep communication lines open are…