Scaling up Your Culture of Compliance and Safety: Why it Matters!

Congratulations! You successfully acquired a record number of practices during the past year. Now what? How smooth was the onboarding process? What safety and compliance issues were identified?

Whether you are just launching a DSO or group practice or scaling up, the foundations of compliance must be in place. 

Regardless of the size of your organization, it’s imperative to establish a culture that encourages staff to speak up when there is a concern, or if a safety mishap occurs. In healthcare, this is known as “blame-free reporting.” According to Patient Safety Net (PSNet), a division of the Agency for Healthcare Research and Quality (AHRQ), a blame-free environment is one where individuals can report errors or near misses without fear of reprimand or punishment. 

A blame-free culture dates back to the medical errors crisis in 1999-2000. It allows for staff to feel safe reporting mistakes or concerns without fear of repercussions. If a safety issue can be rectified and steps put into place to prevent it from recurring, that’s the best possible scenario. Doing so avoids potential injury—to staff or patients—as well as saving the organization money (think workers’ compensation or patient lawsuits).

Here are three key factors to consider when establishing and scaling up your culture of compliance.

1. Having the right people in the right leadership positions who will champion your culture of compliance and safety.

While every organization seeks to reduce loss, protect its assets, and safeguard patients and staff alike, what follows after that? How are your safety champions selected and what support is provided? Is your safety culture by design or default? Safety doesn’t happen by accident! Be sure your “safety champions” are truly committed to safety, and not just giving it lip service.

Staying current with compliance issues in today’s workplace can be challenging. To address and manage compliance updates, plan for ongoing continuing education and membership in key organizations for your safety champions. Doing so ensures a successful robust program. After all, many Compliance Directors and Chief Compliance Officers have outstanding clinical expertise and experience but may need assistance developing compliance savvy, not to mention ongoing support. 

2. Creating a safety communication plan. 

Commitment to safety includes effective communication at all levels, from the clinical teams to supervisors and managers, including the C-Suite executive team. A solid communication plan ensures that everyone receives a consistent message across the organization. Consistency minimizes confusion and clarifies expectations. 

Here are some typical questions to consider, whether developing a new safety communication plan or evaluating your current one.

• What is the safety topic or message you wish to relay?
  
  Leverage organizational data, such as loss run reports, incident reports, employee suggestions/complaints, or trending safety topics to select, then prioritize your message.
  
  Suppose, for example, you notice a rise in your workers’ compensation (WC) claims related to needlesticks. Your first concern is for team safety and OSHA compliance (remember the post-exposure follow up protocol). Second is the financial impact to the organization. A rise in WC claims represents potential increased costs in terms of higher WC premiums and indicates an area you should explore related to OSHA and CDC compliance. Such a situation could affect numerous areas of risk (think employee safety, regulatory issues, and financial risks). Addressing this trend would yield a positive impact throughout the organization.
  
  When considering clinical safety, decide if your message should be single-focused, such as sharps safety, or more general compliance-focused. There are numerous safety topics impacting the entire organization. Topics are diverse and range from fire safety and workplace violence to use of personal devices for accessing the organization’s network. 

• Who is the audience?
  
  Determine whether you will be addressing the clinical teams only or the entire organization. And let’s face it, even business office team members need to be equipped to answer a variety of patient questions—and they are the front-line staff should an inspector show up for an unannounced inspection. 

• How will you deliver your message?
  
  Decide whether your message will be delivered top-down or perhaps sent directly to the doctors and teams. You may find that certain topics may be better suited to a particular mode of delivery. In other words, a new safety initiative may be best presented from the top-down versus a clinical message, such as sharps safety, that lends itself to doctors/teams.
  
  Part of the “delivery decision” will include determining which format to use to present your message, whether it be hosting an informal chat, organizing a formal educational event, recorded sessions, or any other means that would be most effective given the message and size of your organization. 

3. Establishing accountability.

When establishing accountability, think about responsibility and closing the loop. Having layers of support and checks and balances is a must! Part of your selected safety message will most likely include action items and behavior adjustments. This would be the case with a sharps safety message as you may introduce new protocols, techniques, or even safety engineered sharps. Establish accountability measures as part of your pre-launch planning in order to effectively close the communication loop and ensure maximum success. With the sharps safety example, will you close the loop with a post quiz, checklists, or maybe feedback surveys? Another aspect of accountability is monitoring over time for continued success. Certainly, in this example, a reduction in sharps injuries would be one measure of success.

Think of communication, safety, and compliance as a continuum. Developing a safety plan and implementing blame-free reporting moves you closer to achieving a just culture with high reliability for safety and compliance. Remember Rome wasn’t built in day and not all of your compliance concerns will be resolved immediately. Yet ultimately you will be prepared to meet the ongoing challenges of an ever-changing regulatory landscape.

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About Linda Harvey

Linda Harvey, MS, RDH, is a nationally recognized dental risk management and regulatory compliance expert who works with dentists and their teams of all sizes to navigate regulatory requirements and mitigate risk. Linda has corporate risk management experience and has been recognized as a Distinguished Fellow in the American Society for Healthcare Risk Management.

About the Dental Compliance Institute

The Dental Compliance Institute provides train-the-trainer education and certification for HIPAA and OSHA regulatory compliance and dental risk management. DCI compliance coursework carries the distinction of being Quality Matters™ Certified.

DCI was founded in 2014 by Linda Harvey, RDH, MS, HRM, DFASHRM, one of the dental industry’s most respected key opinion leaders on the topics of regulatory compliance and risk management. Harvey founded DCI with the vision of providing dental professionals with the most up-to-date expertise and training they need to thrive in a heavily regulated industry. The DCI vision also includes developing confident and competent compliance expertise at the practice level.