This blog post was previously published on the Redilearning blog and is republished here. Redilearning became part of Relias Learning in October, 2015.
Today’s blog post is going to examine compliance efforts from a few different lenses, as well as seeing how you can leverage staff education as the compliance driver, no matter what particular need or lens you are focusing upon. Kind of like the gas in your car’s gas tank, education is usually the primary driver in most compliance initiatives.
So let’s outline a few of these “lenses.”
A timely, effective compliance program will target two main fronts: general compliance (what do I have to do to comply with the laws governing my setting) as well as specific risk issues to your organization that you are trying to address (as in “our claims around [fill-in-the-blank] are through the roof! What’s up with that??”).
Then you may be experiencing an additional need or “lens.” The merger or acquisition in a state or region that is new to you “lens.” The newly acquired may have a different set of criteria, and getting up to speed with those requirements as well as the discovery of risk (how compliant were they when they came into your fold?) and implementing the necessary solutions in a realistic time frame are the hallmarks of this lens.
And that’s at the macro level. If we scratch a little deeper, a good compliance program will also examine what these programs look like and how they behave by employee category. For example, while you can provide the same OSHA education as a baseline for all staff, you will probably want to provide an additional layer of education targeted to position. Housekeeper education may look different than that provided for nursing because they interact with different types of risk. Or you may be experiencing a high rate of injury with a particular job category and are attempting to re-educate on proper body mechanics.
These are the things that keep your compliance officers up at night! Their job is always moving, too, and that’s an additional lens. Take for example, the new survey protocols for nursing homes that are looking specifically at adverse incidents around targeted drugs like anticoagulants, insulin and the like. They have to remain constantly vigilant for the next thing to come down the pike.
We have our own Compliance officer here at Redilearning. Corinne has to be on top of everything all the time. How she manages to do it, I’m not really sure, but she always manages to do it. And she’s so darn nice about it! We’re really blessed to have her, and our clients echo that.
Believe me, they have a hard job. And sometimes they are not “top of mind” to win a Most Popular contest, but the work they do absolutely has our best interests at heart. Safety and compliance are the glue that keeps our roadster between the ditches, if you know what I mean. And they depend on us to implement and follow up on the programs they design to keep us that way. Buy ‘em a cup of coffee the next time you see them. It’s a partnership worth cultivating.
Filling Your Tank With Staff Education and Training
So now let’s look at how education can be leveraged to ensure what we teach is how our workforce behaves – a very fine, but very important point.
While your talented compliance team designs the program, it is up to all of us on the operations side to ensure that we monitor and follow up on the learning we are having our staff participate in. The days are gone when you could simply throw courses at people (which you have to admit, is sometimes what we did for expediency). The bar is being raised, and we have to demonstrate changed behaviors. And believe me, it’s not going back to the old way probably ever again. Too much is at stake.
A recent OIG report offers a simple case study on the importance of education and training in operationalizing compliance.
In 2012, more than three-quarters of long-term care providers maintained policies that addressed federal reporting requirements for abuse or neglect allegations. In other words, providers did a decent job of being compliant on paper.
However, they were less successful in actually walking the walk. Take a look at this:
The FALLACY of Checkbox Thinking
While 85 percent of nursing facilities reported at least one abuse or neglect allegation to the OIG in that time period, only 53 percent of those reports were in compliance with federal standards of reporting abuse suspicions within 24 hours.
To me, this is a crystal clear example of that false sense of security a “check box” mentality provides when really looking at how your work force is internalizing the training hours you are investing in upon compliance issues. These operators probably assigned a course and made a policy, but didn’t dig deep into exactly how people were walking the walk. Full follow up and quizzing or reinforcing content every day on the floor also plays into your first line of defense against lawsuits. If it seems too much trouble to actively participate in discussing training, trust me, it’s way more work to defend a lawsuit.
Keeping up with new-hire orientation and annual training — exactly who needs what training when — can be a difficult task. A good learning partnership with a provider should include:
- Deep compliance resources – Both humans experienced and accredited in this field and resources you can leverage to help you understand the breadth and scope of compliance in the states and business lines you operate within, including Corporate Integrity Agreements.
- A comprehensive technology solution that supports the way YOU train. You should never accept a system that makes you change your process to their system. You should be able to easily document and track both online training and instructor-led training so that you and your field staff can easily produce comprehensive training plan documentation during survey or as a tool to track compliance. If you are still only using sign-in sheets kept at individual units, you are doubling your work and risking falling victim to lost paper documentation.
- Skill demonstration and mastery. This can be extremely helpful during survey. For example, a state surveyor asks you to prove that Jenny knows how to use a gait belt. You should be able to show the surveyor that on Sept. 4 Jenny took an online module on how to use a gait belt; on Sept. 7 she used it in the classroom with an instructor; and on Sept. 9 she demonstrated to her supervisor that she could adequately use a gait belt and her supervisor signed off that she could. This type of skill tracking also can make a difference in legal proceedings when Jenny is no longer on your staff, but you are defending a suit long after she left.
- Communication tools and resources. The technology should enable “just in time” communication and training. Tools that are easy to use and leverage software you already are using – no huge learning curve. If someone gets hurt and you need to get out a policy change or notification/education quickly, you can’t be at the mercy of some arcane tool.
- Reports that make sense and are delivered to you when you want them. No more “fishing” for data.
- Partnerships with industry leading education providers for current, comprehensive content.
So in a nutshell, it’s 4 main areas you need to keep top of mind to secure a compliant workplace:
- Find and leverage a quality education partner that has the expertise and resources to support your goals.
- Support your compliance team in their designing of full coverage compliance programs,
- Make sure the training is delivered and tracked,
- Make sure the behavior is changing by floor observation and interaction.
Relias Learning wants to be your education partner and we are uniquely qualified to help you maintain a compliant workplace and more. Give me a holler sometime at firstname.lastname@example.org or request a meeting with one of our compliance experts here.
Now get your motors running! I gotta go buy Corinne a cup of Joe.