SCCE Higher Education Compliance Conference June 5 8, 2016

Transcription

1 Janice Putnam, PhD University of Central Missouri Victoria Steel, PhD Laramie County Community College Designation of a Compliance Officer Development of Compliance Policies Development of Open Lines of Communication Provision of Training and Education Internal Monitoring and Auditing Response to Detected Deficiencies Enforcement of Disciplinary Standards Assessment of Program s Effectiveness Compliance For each policy, there needs to be a procedure for how to apply the policy, how it is enforced, whom it affects, and who is in charge. Operational Needs Developing clearly written policies and procedures that are documented, updated, and followed, brings structure to an organization. 1

2 Managing Risks Policies and procedures serve as a internal control method ensuring consistency across the organization. Continuous Improvement Consistently applied policies and procedures assist in the day-to-day decision-making processes. Examine ethical and tactical policy processes identified in PH Leverage these processes to improve governance, risk management and compliance in HE 5 Complex, highly regulated systems Experts generate successful outcomes in their target population Lag behind for-profit in innovations Papers/EAB%20Population%20Health%20Management%20Whitepaper.pdf 6 2

3 Similar service ethic Patient/student focus Increased efficiency impacts more lives (not necessarily profit margins) Papers/EAB%20Population%20Health%20Management%20Whitepaper.pdf 7 The terms of reference of the Council are: to identify and define ethical questions raised by recent advances in biological and medical research in order to respond to, and to anticipate, public concern; 8 The terms of reference of the Council are: to make arrangements for examining and reporting on such questions with a view to promoting public understanding and discussion; this may lead, where needed, to the formulation of new guidelines by the appropriate regulatory or other body; 9 3

4 The terms of reference of the Council are: in the light of the outcome of its work, to publish reports; and to make representations, as the Council may judge appropriate. The Nuffield Council on Bioethics is funded jointly by the Medical Research Council, the Nuffield Foundation and the Wellcome Trust. 10 Risk Precaution and Proportion Behaviour Change Intervention Ladders Stakeholders and Policy Making Economics Choice Vulnerable Groups, Inequality, and Targeted Interventions Evidence Part of the answer to the question of whether or not the state should intervene to protect and promote health depends on the nature and extent of the risk involved, including the degree to which it is potentially under the control of the individual. 4

5 Statistical/Technical Approach Politics and Culture Perceptions and Judgements Decision Theory No. Subject Score Answer these questions for program activities: NA Newness of program 2. Expected appropriation for the program in immediate year following 3. Nature of the program 4. Recent changes in resource levels 5. Impact or sensitivity of the program on persons or organizations external to the agency DHS/OFCO/FAPO Version 1.0 5

6 In any policy decision, it is furthermore important to consider the seriousness of the problem and the urgency with which it should be addressed issues that pose severe and urgent threats to the health of many people are rightly prioritised over those that are only possible threats, affect health in a relatively minor way or involve fewer people. Policy Response Test Balance: aim justifies means Suitability: means justifies end Necessity: choice among means 6

7 The success of public health interventions often depends on more than the cooperation of members of the population. Many different stakeholder groups, including health professionals, the corporate sector, non-governmental organizations (NGOs), institutions of civil society and the media, can have a crucial role to play. All the various strands of opinion and its translation into policy is a matter that politicians and their advisors must consider [and] can have personal or professional conflicts of interest 7

8 Funders Accreditors Auditors Donors Institutional Finance and Administration Compliance Offices/Functions Program operations: Management, program staff, partners, funding agencies, and coalition members. Those served or affected: Patients or clients, advocacy groups, community members, and elected officials. Intended users: Decision-makers, such as partners, funding agencies, coalition members, and the general public or taxpayers Valuable stakeholders Inspires and informs about policy and practice activities Creates space for voices to be heard Fosters social awareness and change Facilitates understanding Contributes to evidence based policy Prevents hindering of progress Hovland, I. (2007). Successful Communication: A toolkit for researchers and civil society organizations, RAPID Toolkit, London: ODI ( 24 8

9 Mapping: Assesses stakeholders Primary Secondary Key Analysis: Importance and interest Power Interest Hovland, I. (2007). Successful Communication: A toolkit for researchers and civil society organizations, RAPID Toolkit, London: ODI ( Babou, S. (2008). What is Stakeholder Analysis? ( Glassman, T., Reindl, D., Whewell, A. (2011) Strategies for implementing a tobacco-free campus policy. Journal of American College Health. 59(8) Autonomy Challenges: Unavailable Ingrained habits Predetermination by industry & media Abundance of options 26 Change the external circumstances making healthy choices easier to make Improve individual s capacity to make healthy choices

10 Written information Websites Computer based information and virtual support Training for professionals in communication skills Coaching and question prompts Decision aides for patients Self management education programs 28 Equity: The fair distribution of benefits and burdens. Inequities - differences in health unnecessary avoidable considered unfair and unjust _GIP_2007_2c.pdf 29 Socio-economic status Gender Race or ethnicity Migration history Degree of urbanization Religion

11 Advantaged groups show longer life expectancy, better health and more healthpromoting behaviors Evidence links low socio-economic status (occupation, education, income or assets) to poorer health 31 Targeting disadvantaged groups Targeting at risk groups Universal Provisions 32 Engage and empower community leaders Assess needs and readiness Relevant, current local data Sources of influence among groups Culturally oriented education and economics Assistance for local programs Identify contributing factors Tailored messages Missouri Comprehensive Tobacco Control Strategic Plan (2016)

12 health systems in all countries struggle to effectively implement evidence-informed interventions. In low- and middle-income countries often there is no process to ensure scientific evidence is accessible and translated within the context to the program managers and policymakers who need them Most policy makers reportedly were not trained to distinguish between good and bad data, and were, therefore, prone to the influence of misused facts often presented by special interest groups. Brownson, R. Chriqui, J. & Stamatakis, K. (2009). Understanding Evidence-Based Public Health Policy. Am J Public Health. September; 99(9): Quantitative Evidence Hierarchy Systematic reviews Peer-reviewed journal articles Public health surveillance systems Individual programs and policies Qualitative Evidence Observations Interviews Focus groups Brownson, R. Chriqui, J. & Stamatakis, K. (2009). Understanding Evidence-Based Public Health Policy. Am J Public Health. September; 99(9):

13 Electronic information Trust issues Sources of information State to state comparisons Surveys of policymakers: priorities, attitudes towards lobbying efforts, obstacles, attitudes and voting intentions Brownson, R. Chriqui, J. & Stamatakis, K. (2009). Understanding Evidence-Based Public Health Policy. Am J Public Health. September; 99(9): Process enhances policy adoption Content identifies effective elements Outcome documents policy impact Policies evolve as they diffuse Framing is important Partnerships between researchers, practitioners and policymakers enhance these processes Brownson, R. Chriqui, J. & Stamatakis, K. (2009). Understanding Evidence-Based Public Health Policy. Am J Public Health. September; 99(9): Economic arguments vary o different ethical frameworks o different assumptions about health behavior. Tradeoffs affect policy Employment and health Employment and design of environment

14 Reducing healthcare cost to system Fewer work absences No health related loss of skills Other values: quality and quantity of life, public good, reducing health inequalities 40 Big stick Aim to ensure economic efficiency and make best use of scarce resources May put burden on those with variations in disposable income health behavior Personal behaviors can have a significant effect on health, and therefore a common theme in public health policy is behavior change. Public Health Behavior Change Theories Social Cognitive Theory Theory of Planned Behavior The Trans-Theoretical (or Stages of Change) Model 14

15 A more intrusive policy initiative is acceptable only if it is clear that it will produce the desired effect and that this can be weighed against the loss of liberty that will result. Considerations Individual Freedom and Responsibility Economic Costs and Benefits Societal Costs and Benefits Do nothing or simply monitor the current situation; Provide information; Enable choice; Guide choices through changing the default policy; Guide choices through incentives; Guide choice through disincentives; Restrict choice; Eliminate choice. 15

16 Public Health and Higher Education have many commonalities Nuffield Council on Bioethics has nine Public Health policy process considerations These considerations can be useful in designing Higher Education compliance and risk reduction policy development processes These considerations can provide structure for evaluating ethical and evidence elements when assessing compliance policies 46 16