Transcript Document

Remediation: When is it Gold?
An Alternative Response to Complaints
Claudia Skolnik
Nora MacLeod-Glover
Ontario College of Pharmacists
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Presentation Overview
• Philosophy behind Remediation
• ‘Nuts and Bolts’: Creating the Processes
• Putting it into Context
– Case reviews
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Who are we?
Investigations & Resolutions
• Investigation
• Creative processes
• Solution based
• Responsive & accountable
• Viewed as punitive
Continuing Competency
• Assessment
• Identifying practice
weaknesses
• Solution based
• Proactive & accountable
• Educationally based
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Shared Objectives
• Improve quality of care
• Reduce the risk of harm
• Infuse meaning into our processes &
outcomes
• But – different “receptors”
Collaboration was a natural evolution!
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Different Receptors of
Information
Regulatory Receptors
of Information
Registration –
Entrance to Practice
Practice Review
/Inspections
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Complaint/breach
Investigations
Shared Processes
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Assessment
Evaluation
Remediation
Enforcement
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
The ‘Nuts and Bolts’:
Creating the Processes
1. Find your legislative authority
− Complaints Committee Authority
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Take appropriate action not inconsistent with the
laws
− Discipline Committee Authority
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Terms, Conditions and Limitations
Professional misconduct to breach a term, condition or limitation
− Discipline referral
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Illusion of choice
− Access your Quality Assurance Enforcement
legislation
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
The ‘Nuts and Bolts’:
Creating the Processes
2. Gather your facts
− Adapt your investigation
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Gather all relevant information
Not just “what?” but “why?”
Anticipate Committee interest in remediation
Consult with Continuing competency re:
remediation opportunities
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
The ‘Nuts and Bolts’:
Creating the Processes
3. Create your remediative solution
– Obtain Remediation Assessment & Education
Plan
4. Guide the Committee review
– Confirm practice deficits
– Consider suitability of remediation
– Justify the reasonableness of the remediation
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
The ‘Nuts and Bolts’:
Creating the Processes
5. Undertaking
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Recognition of need for improvement
Definition of enforceability
6. Decision and Reasons
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Demonstrate value of remediation
Accountable/reasonable
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
The ‘Nuts and Bolts’:
Creating the Processes
7. Compliance Monitoring
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Consent to information release
Follow up mechanisms
Conclusion & confirmation of success
Further enforcement if non-compliant
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
The ‘Nuts and Bolts’:
Competency Consultation
1. Maintain your remediation tool box
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Know your remediation opportunities
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Develop & maintain a network of educators
Review programs and assess suitability
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Rely on education frameworks
Examine learning objectives
2. Examination of Practice Deficit
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Complete a review of the investigation
Probe & obtain further information
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
The ‘Nuts and Bolts’:
Competency Consultation
3. Analyze case to find root cause
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Examine each issue addressed in investigation
Define the practice gap
Identify the remediative potential
Match the remediation recommendation to the
practice gap
4. Create the Remediation Assessment &
Education Plan
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Includes an assessment component
Be open and creative!
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
The ‘Nuts and Bolts’:
Competency Consultation
5. Submit to staff/Committee
6. Respond to staff/Committee questions and
modify, as required
7. Address the Committee on remediation
issues
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Putting it into Context
Case Review (J.L.)
• 29 incidents, over 2 years , hospital setting
– Dispensing errors
– Poor recordkeeping
– Abdication of responsibility
• Terminated from employment
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Case Review – J.L.
• Investigation
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Gathered documentation
Interviewed co-workers
Member’s response
Obtained a continuing competency assessment
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Case Review – J.L.
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Root Causes
Ineffective communication
skills*
Poor therapeutic knowledge
management and application
Rote prescription processing
skills
Inadequate error management
skills
Lacks awareness of
professional accountability
Remediation
• IPG program participation
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Applied therapeutics
Communication skills
Basic Professional practice lab
Professional Practice Theory
including drug information
sessions and jurisprudence
• Effective communication
strategies program
• Confronting Medication
Errors program
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Case Review – J.L.
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Committee endorsed remediation option
Negotiation (two communication programs)
Undertaking – contracting terms
Final Committee decision
– Ordered remediation
– Oral caution
– Rationalize the decision and suitability of
remediation
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Benefit Analysis – J.L.
• Extensive Remediation
– Lengthy and expensive
– Not a specified committee power
• Cost and time effective
• Avoided complicated discipline case
• Appropriate & meaningful
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Putting it into Context
Case Review (N.S.)
• Member disciplined
– Failed to identify excessive narcotic
prescriptions
• Discipline order
– Suspension
– Term, condition and limitation re: remediation
• Failed remediation – breached condition
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Case Review – N.S.
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Negotiated attempts for compliance
Failed again
Is breach Discipline or Competence based?
Consultation with Continuing Competence
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Case Review – N.S.
Root Causes
• Lacked basic
interviewing skills
• Deficiencies in
communication skills
• Weak therapeutic
knowledge base
Remediation
• IPG program
– Language of Patient
counselling
– Communication skills
• Therapeutic study,
three of:
– Print coursework
– Live lectures: IPG
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Case Review – N.S.
• Obtained Education Plan
• Used discipline for breach as leverage
• Negotiated Enforceable Undertaking
– Failure to result in enrolment in the QA stream
• Success!!!!
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Benefits Analysis – N.S.
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Effective monitoring
Meaningful process
Averted need for Discipline
Achieved improved quality outcome!
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Why Remediate?
• Professionals come to work with intention
to do good
• Distinguish between conduct and practice
– Theft/fraud vs patient care shortcomings
• Principles of CQI
– Quicker solutions
• Penalties options may not be effective
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Mining for success
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Institutional philosophy of CQI
Openness to modify processes
Creative interpretation of legislation
Meaningful and valid remediation options
Draw upon unique skills of individuals
Culture of interdepartmental collaboration
Educate committees and get their buy-in
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona
Speaker Contact Information
Claudia Skolnik, Manager, Investigations & Resolutions
[email protected]
Nora MacLeod-Glover, Manager, Continuing Competency
[email protected]
Ontario College of Pharmacists
483 Huron Street, Toronto, Ontario M5R 2R4
Tel:416-962-4861 Fax:416-847-8282
www.ocpinfo.com
Presented at the 2005 CLEAR Annual Conference
September 15-17
Phoenix, Arizona