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Remediation: When is it Gold? An Alternative Response to Complaints

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

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Remediation: When is it Gold? An Alternative Response to Complaints

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  1. 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

  2. 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

  3. Investigations & Resolutions Investigation Creative processes Solution based Responsive & accountable Viewed as punitive Continuing Competency Assessment Identifying practice weaknesses Solution based Proactive & accountable Educationally based Who are we? Presented at the 2005 CLEAR Annual Conference September 15-17 Phoenix, Arizona

  4. 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

  5. Different Receptors of Information Presented at the 2005 CLEAR Annual Conference September 15-17 Phoenix, Arizona

  6. Assessment Evaluation Remediation Enforcement Shared Processes Presented at the 2005 CLEAR Annual Conference September 15-17 Phoenix, Arizona

  7. The ‘Nuts and Bolts’: Creating the Processes • Find your legislative authority • Complaints Committee Authority • Take appropriate action not inconsistent with the laws • Discipline Committee Authority • Terms, Conditions and Limitations Professional misconduct to breach a term, condition or limitation • Discipline referral • Illusion of choice • Access your Quality Assurance Enforcement legislation Presented at the 2005 CLEAR Annual Conference September 15-17 Phoenix, Arizona

  8. The ‘Nuts and Bolts’: Creating the Processes 2. Gather your facts • Adapt your investigation • 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

  9. 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

  10. The ‘Nuts and Bolts’: Creating the Processes • Undertaking • Recognition of need for improvement • Definition of enforceability • Decision and Reasons • Demonstrate value of remediation • Accountable/reasonable Presented at the 2005 CLEAR Annual Conference September 15-17 Phoenix, Arizona

  11. The ‘Nuts and Bolts’: Creating the Processes • Compliance Monitoring • 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

  12. The ‘Nuts and Bolts’: Competency Consultation • Maintain your remediation tool box • Know your remediation opportunities • Develop & maintain a network of educators • Review programs and assess suitability • Rely on education frameworks • Examine learning objectives • Examination of Practice Deficit • Complete a review of the investigation • Probe & obtain further information Presented at the 2005 CLEAR Annual Conference September 15-17 Phoenix, Arizona

  13. The ‘Nuts and Bolts’: Competency Consultation • Analyze case to find root cause • Examine each issue addressed in investigation • Define the practice gap • Identify the remediative potential • Match the remediation recommendation to the practice gap • Create the Remediation Assessment & Education Plan • Includes an assessment component • Be open and creative! Presented at the 2005 CLEAR Annual Conference September 15-17 Phoenix, Arizona

  14. The ‘Nuts and Bolts’: Competency Consultation • Submit to staff/Committee • Respond to staff/Committee questions and modify, as required • Address the Committee on remediation issues Presented at the 2005 CLEAR Annual Conference September 15-17 Phoenix, Arizona

  15. 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

  16. Case Review – J.L. • Investigation • 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

  17. 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 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 Case Review – J.L. Presented at the 2005 CLEAR Annual Conference September 15-17 Phoenix, Arizona

  18. Case Review – J.L. • 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

  19. 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

  20. 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

  21. Case Review – N.S. • 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

  22. 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 Case Review – N.S. Presented at the 2005 CLEAR Annual Conference September 15-17 Phoenix, Arizona

  23. 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

  24. Benefits Analysis – N.S. • Effective monitoring • Meaningful process • Averted need for Discipline • Achieved improved quality outcome! Presented at the 2005 CLEAR Annual Conference September 15-17 Phoenix, Arizona

  25. 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

  26. Mining for success • 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

  27. Speaker Contact Information Claudia Skolnik, Manager, Investigations & Resolutions cskolnik@ocpinfo.com Nora MacLeod-Glover, Manager, Continuing Competency nmacleod@ocpinfo.com 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

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