From Enforcement to Compliance through Best Practices and Provider Support Services

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From Enforcement to Compliance through Best
Practices and Provider Support Services

• Presented by Sandra Wooters and Debra Avery, PA
  Dept. of Public Welfare, Adult Residential
  Licensing

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Provider Support Services is

• Services designed to encourage voluntary care
  improvement
• Services that protect the public by helping
  providers to increase their knowledge, thus
  improving services and rules compliance
• A strategy for improving consumer protection
  while reducing the proportional effort that might
  otherwise be directed at enforcement.

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Provider Support Services is (Cont.)

• The hidden backbone of consumer protection.

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Provider Support ServicesFrom Enforcement to
Rule Compliance
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Special Challenges Faced by Facilities Caring for
Low Income Consumers

• Experienced licensors are sensitive to the
  different compliance issues for small facilities,
  rural facilities, low income facilities, chain
  operated facilities, etc.
• In these times of economic uncertainty Providers
  are being asked to do more with less money, and
  with less support from community social services
  agencies.

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Goal Affordability

• No worthwhile strategy can be planned without
  taking into account the organization's ability to
  execute it
• (Former Honeywell CEO Larry Bossidy
• and business consultant and author Ram Charan in
  their book titled Execution The Discipline of
  Getting Things Done)

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Goal Affordability (Cont.)

• It is wrong to assume that maximum quality is the
  ultimate goal.
• Should every hotel be built to the same quality
  as The Ritz?
• Simplify, and where appropriate, reduce the
  number of procedures and process that reflect how
  work actually gets done.
• Help identify strategies unique to the
  environment and population served.
• Approach compliance in a positive and supportive
  manner.

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Goal Affordability (Cont.)

• Some of the best tools include

• A three ring binder

• A highlighter

• A hole punch

• A rubber finger

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Goal Advice, not rule enforcement!

• All advice, however formal or informal it may be,
  must always leave the other person completely
  free to accept or reject it!
• Suggest options generally available, or available
  in that providers particular situation, which
  would achieve compliance with the rule.
• Inquire what are the needs of the providermany
  times their actual needs are not based on a
  regulation but end up affecting regulation
  compliance.

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Goal Accountability/Responsibility

• Place and keep responsibility for compliance on
  the provider
• The licensor should encourage but not become
  over-invested in the providers success
• The goal is to build self-reliance and managerial
  competence among providers
• Tie updated processes to individual job
  responsibilities.

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Goal Accountability/Responsibility (Cont.)

• Accountability is external. It is an agreement
  to be held accountable by another for your
  operation or results.
• Responsibility is internal. Its a feeling of
  ownership. True responsibility stands out
  because people are leading, learning, correcting,
  and improving. The sign of a healthy,
  high-performing facility.

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Goal Use a Systems Approach to Problem Solving

• View problems as parts of an overall system and
  solution, rather than react to a specific part,
  outcome or event
• Consider all possible interactions involved with
  the problem situation
• Consider three types of changes changes in
  structure, in procedures, and in attitudes.

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Goal Use a Systems Approach (Cont.)

• What Happened?
• Why did it happen?
• What can be done to prevent it from happening
  again?
• How often is the system going to be monitored and
  by whom?

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Goal Provider Self-Sufficiency

• Build a network of provider support.
• Achieved thru use of self, agencies and the
  community at large.

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Goal Provider Self-Sufficiency (Cont.)

• What are the strengths of the provider and staff?
  
• What agencies and community organizations have
  resources to offer to the facilities?
• Encourage the provider to reach out to other
  providers who have been successful following the
  rule.
• Help the Provider develop a monthly provider
  network meeting.

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Tools

• Tools must be affordable and easily achievable by
  both staff and administration.
• Tools should be designed in a proactive approach
  to rules and not reactive.
• Tools should include auditing, review,
  observation and training.
• Tools should be used daily, weekly or monthly in
  an effort to reduce repeated non-compliance.
• Develop a team approach to compliance. Help the
  staff understand the rules which will empower the
  staff to join the process.

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Best Practices

• Some of the best tools include a 3 ring binder, a
  highlighter, hole punch and a rubber finger!
• Create a good policy and procedure manual that
  can also be used to train staff.
• Encourage the development of a licensing ready
  book.
• Review a non-compliance report and assist in the
  development of an auditing, review or
  observation tool. Be sure the steps are easy to
  understand, who is responsible and how often will
  the non-compliant area be monitored, audited or
  observed.

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Best Practices (Cont.)

• Utilize a Walk About Workshop to instill a new
  system designed by the staff. Walk About
  Workshops, or instant in-services, are key to
  helping staff gain a greater knowledge of a rule
  and how to fix the rule once observed.
• The Walk About Workshops are 15 minutes or less
  of training that can be completed at each staffs
  work station, in the office, or in the break
  room. Review the process with all of the staff
  involved in that process. Dont forget to get
  staff signatures!

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Best Practices (Cont.)

• Staff must understand what happened and why it
  was non-compliant. Work with the staff on how to
  achieve compliance. They usually know why an
  event happened, and can help develop a good
  system to prevent it from happening again.
  Ongoing staff training on regulations is one of
  the best methods to achieve compliance.

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Best Practices (Cont.)

• An example of a simple observation tool to reduce
  physical site non-compliance is a one page
  foldable tool that fits into the staffs pocket
  and reminds the staff of what to observe to reach
  rule compliance. The physical site is ready for
  inspection at anytime!

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Best Practices (Cont.)

• An example of typical non-compliance is
  medication documentation errors. Med errors can
  be easily identified by staff, if trained on what
  to look at on the Medication Administration
  Records. Ask the medication staff how do you
  end or begin your shift..the answer should be
  check the medication administration record for
  missed documentation at the beginning and end of
  each shift..encourage the staff towards this
  approach..this is an easy, no cost fixalas.a
  reduction in documentation errors!

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A Strong Provider Support Component is one that

• Increases compliance and consistency in
  regulatory compliance
• Improves relationships between licensees and
  licensors
• Reduces the need for sanctions
• Reduces time licensors spend on inspections and
  complaints
• Increases support for sound regulation
• Increases support for consumers

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Provider Support Services do more than give
providers tools and technical support.
Conclusion
They also model a value and goal that should be
the heart, soul and the driving force of every
human service care facility or agency.
Provider Support Services is the link between
licensing and provider compliance.
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Resources

• Commonwealth of Pennsylvania Provider Support
  Program tools
• Commonwealth of PAs 2011/2012 inspection results