We didn't specifically define the term “in a timely manner”. Certainly, I think the results that we found indicate that the issue was more than just new hires who hadn't yet gotten around to taking the course.
I think that is always going to be the case. I think it would be very rare that an organization will get to 100%, because there will be new hires.
Again, I think some of the comments we've heard on this issue mean that there does need to be some reflection on the mandatory aspect of this training. We've heard some things like transient employees, student employees, and things like that. The departments have now said that the training is mandatory for everybody. If it doesn't need to apply to students or somebody else for whatever reason, then don't make it mandatory for them. On the other hand, maybe there should be some other type of program for the transient employees and the student employees.
I think the problem we ran into was that the departments had made this mandatory for every employee in the organization, no matter what. What we're hearing is that most of them are saying that they're actually applying it more on a risk basis, which could make someone ask why then it is mandatory for everybody. If it's only the ones who are the riskiest that this really applies to, then make it mandatory for them, and perhaps adopt some other approach for the rest.
We didn't actually determine the timeliness, but I think there are some fundamental changes the departments need to make, to make sure that the people who are getting the training get the training, and that they get it as quickly as they can. I think it will be up to them to define timeliness. In the end, I think it will come down to a judgment on the reasonableness of their definition of timeliness.