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How Just Culture Impacts Compliance

Sally McCabe | Nov 30, 2016

When we speak about Just Culture in our industry, we usually talk about its impact on patient and provider safety. When we talk about errors, our mind shifts to those errors that cause or had the potential to cause patient harm.

A true Just Culture, however, has a far broader reach and impact on an organization. One important area that is significantly impacted by a Just Culture, or lack of one, is compliance.

EMS, like the rest of the healthcare industry, is heavily regulated. How we staff, stock and operate our ambulances is dictated by regulations. How we obtain and maintain business relationships is dictated by regulations. When, what and how we document is dictated by regulations. How we safeguard our documentation is dictated by regulations. What, when and who we bill is dictated by regulations.

There are federal, state and local, regulations that govern the way we do business. Most are not taught in EMT or medic courses. Many are still unknown by those who have elevated through the ranks from EMT to paramedic to leadership roles. That should be enough to scare the heck out of most organizations. It should scare them enough to send every one of those promoted to leadership roles straight to PWW's Certified Ambulance Compliance Officer course which is excellent and definitely NOT just for compliance officers.

The Compliance Program Guide for Ambulance Suppliers developed by the Office of the Inspector General (OIG) contains 7 elements:

  1. Development of Compliance Policies and Procedures
  2. Designation of a Compliance Officer
  3. Education and Training Programs
  4. Internal Monitoring and Reviews
  5. Responding Appropriately to Detected Misconduct
  6. Developing Open Lines of Communication
  7. Enforcing Disciplinary Standards Through Well-Publicized Guidelines

In this post, I want to focus on the two which are greatly influenced by the existence of a Just Culture.

At the very core of a Just Culture is the act of responding appropriately to detected misconduct. Was the behavior a result of human error, at risk behavior or reckless behavior? Is there a problem with the system or process in place that leads to a high likelihood of human error? Is the appropriate response system change and/or training, coaching or punitive action?

Too often, leaders do not look at the cause of the behavior and jump immediately to punitive action. System issues are never corrected, poor behaviors continue and, if discovered, more punitive action is taken.

Developing and encouraging open communication is another vital component of a Just Culture. This component is greatly influenced by whether or not the response to detected misconduct was appropriate in the mind of others who find themselves making the same errors. How many are going to report their mistakes or what led to them if they are certain that they will be punished?

Equally as damaging to a successful compliance program are the leaders who do nothing when compliance issues arise or concerns are raised by others. This sends a clear message that compliance is not important.

These leaders underestimate the important role that accountability plays in a Just Culture. There is a very big difference between responding appropriately to detected misconduct and not holding yourself or others accountable.

 An organizations's reaction to, response, transparency and communication to staff afterwards will dictate whether or not employees believe that their organization believes compliance is important, that their concerns will be taken seriously, that their anonymity is guaranteed and that they will not be retaliated against.

Make sure that the message that you send to your staff is the one you want them to hear.

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