Responsibility? Daniel M. Baer, MD. Downloaded from by guest on 25 August 2018
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1 Continuing Education Whose Responsibility? Daniel M. Baer, MD 423
2 424 feature Or is it a shared responsibility?while most educators and laboratory professionals would agree that professional development requires lifelong learning, it is difficult to find statistics that directly bear this out. In the absence of clear statistical correlation, we still know that many of the tests, methods, and instruments used only a few years ago have been replaced by new methods and the old ones discarded. Like professionals in other fields, laboratory professionals cannot decide to stop learning new skills. Some new learning is the responsibility of the laboratorian and may even be optional. Learning new areas of competence to broaden one s opportunities probably falls within that arena. Education for new tests or instruments introduced into the laboratory may be the responsibility of the employer. Regulatory agencies and accrediting organizations have an interest in ensuring that laboratorians receive training to remain competent and to perform their duties safely. Often, the professional s ambition to add expertise will be at his or her expense, while educating staff in new methods is the employer s expense and won t necessarily increase the employee s earning power. What Is Continuing Education? For the purpose of this article, continuing education (CE) includes all educational activities that are pertinent to a person s professional skills, activities, interests, and growth. It also includes training relevant to the person s job, such as patient safety, fire and disaster training, and other training required by regulatory and accreditation agencies. A list of some CE categories is given in [T1]. Some regulatory and accreditation agencies have more restrictive definitions of continuing education. For some of these, the education must be provided by an accredited organization, and the contents must be closely related to the person s professional activities. Continuing Education Categories People engage in continuing education for many reasons. Sometimes it is for the benefit of the employer or to improve job performance. Some continuing education is mandated by regulatory or accreditation agencies and is oriented toward patient or employee safety. Some educational programs are undertaken to satisfy intellectual curiosity or to enhance professional skills. Continuing Education Categories Initial orientation to a job Training for a specific task, test, or equipment Continuing competency training for work tasks Cross-training for new laboratory tasks Professional growth and career advancement Management skills Patient safety Personnel safety Mind stretching New developments in career area Workplace issues such as sexual harassment T1 Initial Orientation to a Job When a person starts a new job, the employer usually provides an orientation session to acquaint the new employee with information about the institution, the specific job, and tasks required for the job. The Joint Commission on Accreditation of Healthcare Organizations (JCAHO) requires orientation at 3 levels: orientation to the institution and its policies and rules; orientation to the department and its work environment; and orientation to the specific job, equipment, and procedures. Brigg Franklin, MA, is responsible for new employee orientation at the Veterans Affairs Medical Center (VAMC) in Portland, OR. He explains that the objective of orientation is to acquaint the new employees with the work environment, culture, and essential facts about their new place of employment. In their orientation, everything from the Medical Center s rules and regulations and information about safety to parking information is covered. The Occupational Safety and Health Administration (OSHA) requires that information be provided about infection control, bloodborne pathogens, and other safety matters before employees begin work, and the Equal Employment Opportunity Commission requires that new employees are informed about equal employment opportunity and sexual harassment. Our agency, the Department of Veterans Affairs, expects us to tell new employees about human resources issues including rules about leave, retirement, and promotions. We have a customer service orientation that helps new employees deal with our customers, the veterans, and the public. There is conflict resolution training, and we inform the employees about the provisions of the Whistle Blowers Protection Act. After employees are oriented to the Medical Center, they are oriented to their specific departments and jobs by their supervisors. Franklin adds, I recently saw a report that showed that employees who go through a good orientation program become more proficient at their jobs than those who don t. The reason for this is probably that oriented employees are more confident in doing their work. For this reason alone, it is in our interest to take the time to orient new employees. Training for a Specific Task, Test, or Equipment The employer is responsible for ensuring that whenever an employee takes on a new task, he or she has appropriate training. The vendor usually provides training for new equipment. Chris Demiris, marketing manager for immunoassay systems at Roche DiagnosticsM, offers industry s perspective on the vendor s role in providing training to competently operate new equipment. He says that when a vendor places a new system at a customer site, it must provide sufficient technical and operational training to the designated laboratory staff. The training can take the form of in-lab training or off-site training at the vendor s training center. He says that in today s
3 feature laboratory environment, because of the potential for interruptions, in-lab training is less effective than training center based education. It is the vendor s responsibility to train their customers sufficiently to enable them to use the equipment as intended. Generally, the lab will send a senior level staff member or someone with equipment acumen to attend the courses held off site. These individuals are trained to a high level so that upon their return they can function as lab experts or trainers for the remainder of the staff. He adds that vendors who are highly customer-focused provide additional training via local and national meeting seminars that offer the opportunity for CE credits. Such sessions involve lectures on current uses of the product, new technologies, and emerging clinical practices. Training and CE support is one criterion that a lab should use for selecting new systems, says Demiris. Demiris describes the reasons vendors provide training. It makes good business sense to train customers on a vendor s systems. Service calls are reduced, satisfaction with products increases, and overall costs to serve the market are lower. Customers can better implement their new systems and provide better patient care. Customers are placing increasing demands upon their vendors for training to assist in dealing with staff shortages and turnover. Continuing Competence Employers are required to assess employee competence. When there are deficiencies in employee competence, employers are required to provide remedial training to correct the deficiencies. Asked how priorities are set for required CE topics, Kathy Smith, RN, clinical educator in the education division at Portland VAMC, says, Our department is concerned about education that is related to staff competence and ability to perform their duties. Obviously, our educational resources are limited, so it is important to put our education funds where they will do the most good. She says that her department first determines if there are any new guidelines, procedures, or performance standards that staff must know. Then they do a formal needs assessment using written questionnaires with job-related questions. Because the questionnaires are anonymous, those completing them do not feel at risk. The data from these questionnaires and from incident reports are then carefully evaluated. We look for any information that indicates a problem or lack of knowledge. Our intent is to identify levels of knowledge and skill so we can plan educational activities to address them, Smith says. Finally, they use focus groups to help decide on the most important educational efforts for the year. These groups are made up of an assortment of employees in the target group, which provides many perspectives on needs. The information we get from focus groups is excellent. The process itself can be time-consuming, but this grouping of participants allows for quicker data collection. Patient and Personnel Safety A number of regulatory and accreditation agencies such as JCAHO and OSHA require annual training for all employees in topics such as bloodborne pathogens, chemical hygiene, and fire and disaster preparedness. Employer-Required Workplace Topics Employers frequently have training topics that are required for their employees. Such topics might include a discussion of workplace issues such as diversity training or training to prevent sexual harassment or workplace violence. Employee-Initiated Education Laboratorians often want to learn about new developments in their field, management training, and education for professional growth and career advancement; such education might include exposure to a new area to stretch the mind. Juanita Petersen, MBA, MT(ASCP), manager of the core laboratory at Oregon Health Sciences University Hospital in Portland, OR, was able to earn an MBA with much of the tuition paid by her employer. She evaluates her education this way: My curiosity in getting additional education was fueled by my interest in learning something beyond the laboratory. Petersen wanted to explore job opportunities available to medical technologists and thought that business classes would expand her knowledge and give her an advantage. Another strong motivator was the opportunity available from her employer that enabled her to take graduate-level classes at a significantly reduced rate. She was not, however, initially convinced that her additional education would benefit her laboratory career. Petersen says, But the more classes I took, the more I was able to see how business principles applied to the laboratory. I cannot claim that my additional education helped me secure any particular position. However, I gained more confidence in my ability to take on new assignments, I increased my understanding of the forces that have an impact on the laboratory, and became a stronger, more effective employee. Types of Continuing Education Programs Available Continuing education can take many forms [T2]. Although some of these can be undertaken by an individual as a self-study activity, others are group activities or, because of their cost, could not be easily paid for by an individual laboratorian. Many laboratories have in-service conferences. These are usually conducted during daytime work hours and because of work schedules can only reach a portion of the staff. Because of reductions in staff that have become necessary with reduced budgets, this kind of training is less available than it once was. On-the-job training is frequently a one-to-one training activity. Although an employee might be able to independently review an equipment manual or test procedure, much of this kind of training takes place with an experienced employee demonstrating and explaining procedures. 425
4 feature Workshops and courses usually require the laboratory professional to take time away from work and may involve travel to another city. Because of the time loss and tuition and travel expense involved, it is difficult for many technologists to take advantage of this kind of continuing education. Teleconferences and subscription programs such as Check- Sample, TechSample, and CheckPath usually involve a group of laboratorians in a single laboratory. The teleconference requires participants to meet at a specific time in a meeting room to listen to the conference. Subscription programs with printed materials can be read at any time. These programs, however, may be too expensive for an individual technologist. Most of the professional societies publish journals that contain educational material. Reading journal articles conforms with most groups definition of continuing education. Some journals, such as Laboratory Medicine, offer some articles with CE credits that will be recognized by accreditation or regulatory agencies. A variety of self-study programs are available for the laboratorian. These come in a wide range of forms: printed materials, videotapes, CD-ROMs, and the Internet. Types of Continuing Education (CE) Programs Available Employer-provided in-service or on-the-job training Workshops and courses Professional society and educational organizations Manufacturer/vendor Teleconferences Subscription programs (eg, CheckSample) Self-study courses Publications with CE credit Journals and books T2 Regulation and Accreditation Regulatory and accreditation requirements drive much continuing education. At the national level, Clinical Laboratory Improvement Amendments (CLIA) 88 have placed the responsibility for an adequately trained staff in the hands of the laboratory director by stating that the laboratory director must ensure that policies and procedures are established for monitoring individuals who conduct preanalytical, analytical, and postanalytical phases of testing to assure that they are competent and maintain their competency to process specimens, perform test procedures, and report test results promptly and proficiently, and whenever necessary, identify needs for remedial training or continuing education to improve skills. 1 If there is any doubt as to whether the laboratory or the employee is responsible, the rule states that the technical consultant (as defined in the CLIA rule, a technical consultant is a designated technologist, pathologist, or doctoral scientist) is responsible for identifying training needs and assuring that each individual performing tests receives regular in-service training and education appropriate for the type and complexity of the laboratory services performed. 2 There are other CLIA references to training provided by the laboratory. JCAHO makes it clear that institutions that it accredits must provide employees with training and continuing education related to their duties and patient and personnel safety. 3 OSHA requires training of staff who are exposed to workplace health hazards about bloodborne pathogens 4 and chemical hazards. 5 At the state level, 9 states that license medical technologists have CE requirements [T3], and 37 physician licensing states and territories require continuing education for each license renewal period. Some employers have developed their own CE requirements for employees. The Department of Veterans Affairs, the nation s largest health care organization, requires that each employee have 40 hours of continuing education annually. Half of the training hours must focus on patient and work safety. The employee can receive this education through a variety of means, The Continuing Education (CE) Hours Required by the Nine States That Require CE for Medical Technologists State Hours Required T3 426 California Florida Louisiana Montana Nevada North Dakota Puerto Rico Rhode Island West Virginia 12 Annually 24 Biennially 12 Annually 14 Annually 20 Biennially 20 Biennially 36 Triennially 30 Biennially 10 Annually
5 feature Continuing Education (CE) Responsibilities Responsibility Employer Employee T4 Choice of the educational content Selection of training methods, instructors, and training materials Documentation of training Ensuring that employees comply with regulatory requirements Competency compliance and remediation Providing time to receive training Providing facilities for training Providing funding for training Assigns training mandated by regulatory and accreditation agencies; assigns training needed to do job Provided when employer arranges for training program Required to document mandatory training; may also choose to document all education taken by employee Must document education required by regulatory agencies Must assess job competence and provide remedial education, if necessary Provides paid time for required training; may choose to provide paid time for other CE Supplies facilities for mandatory training Mandatory training or CE performed at the request of the employer is done at no expense to the employee; many employers cover all or part of the expense of CE requested by employees Selects education topics to enhance job knowledge, advance career, or satisfy intellectual curiosity Selected when employee chooses educational program Must give employer documentation of mandatory training; employer may request documentation of all education Must give employer required documentation Must demonstrate job competence and attend necessary remedial educational programs Employees engaging in CE often do so during nonpaid time Employees engaging in CE often do so away from the job Employees often pay all or some of the cost of CE engaged in at their request including self-study and reading. Some of the required training topics are prescribed, such as fire, disaster, and workplace health hazards. Other CE topics are the employee s choice. Some credentialing organizations have developed CE requirements for their members and diplomates. The National Credentialing Agency (NCA) requires 36 hours of continuing education every 3 years for recredentialing of clinical laboratory scientists. The considerations for continuing education include the following: Choice of the educational content Selection of training methods, instructors, and training materials Documentation of training Ensuring that employees comply with regulatory requirements Competency compliance and remediation Providing time to receive training Providing facilities for training Providing funding for training So Whose Responsibility Is It? Employer The employer, and specifically the employee s supervisor, is responsible for ensuring that employees are competent and able to perform their duties safely. CLIA and the accreditation agencies maintain that the employer is responsible for continuing education to maintain competency and safety. Some employers have policies that require them to provide education on certain subjects. It is to the employer s benefit to have a well-trained, proficient, and up-to-date workforce. Many employers believe that providing continuing education opportunities to staff is a good investment. This ensures that there is a pool of qualified employees available when there are positions of higher responsibility to fill. Continuing education, provided at the employer s cost, is also a powerful recruiting and retention tool in a tight labor market. Employee One strong characteristic that differentiates professionals from other workers is the professionals responsibility for self-improvement and keeping up-to-date in their technical and professional knowledge. It is the responsibility of professionals to seek out educational opportunities that enhance their professional growth and career advancement. If available, laboratorians should also take advantage of education provided by their employers. Both Employer and Employee Offering a unique perspective on the relative responsibilities of employers and employees is Deborah Burton, PhD, RN, director of education at Portland VAMC and president of the Oregon State Board of Nursing. Accountability for assessing and maintaining competency of all staff rests squarely with the 427
6 feature employer, particularly for the hospital-based laboratory when the hospital is accredited by JCAHO. She adds, however, that responsibility for professional continuing education is shared by the employer and the employee, with support from CE departments. Professional laboratory staff holding licenses or credentials from external organizations such as ASCP or NCA have legal and ethical obligations to maintain competency, irrespective of where they work or their specific job title. Balancing ongoing competency with the imperative to continually improve operations, bring new equipment and services, and develop staff to their full potential is challenging, but can also create healthy partnerships for supervisors and educators. In the end, these partnerships can produce improved, efficient, state-of-the art patient care while also maintaining a high degree of job satisfaction for professional, technical, and administrative laboratory personnel, says Burton. Responsibility for continuing education, thus, is a shared responsibility. Although the employer should plan and provide time and funding for mandatory training required by the regulatory and credentialing agencies and training directly related to job tasks, the employee also has educational responsibilities [T4]. Many employers have policies that provide some paid time and tuition reimbursement for continuing education. But it is reasonable for employees to engage in CE activities during nonduty hours and to pay some of the cost of their continuing education. This is especially true when this education is for the purpose of career advancement, promotion, or exploration of new fields. For the sake of competent personnel performing duties safely and competently, each party must share in the responsibility for continuing education. 1. Code of Federal Regulations, CLIA Final Rule, 42 CFR (e) (13). Available at: 2. Code of Federal Regulations, CLIA Final Rule, 42 CFR (b) (7). Available at: 3. Joint Commission on Accreditation of Healthcare Organizations Hospital Accreditation Standards. Oakbrook Terrace, IL: Joint Commission on Accreditation of Healthcare Organizations; (Standards LD.2.8, EC.1.5, EC.2.9.2) 4. Code of Federal Regulations, Bloodborne Pathogens Regulatory Text, 29 CFR (g)(2)(ii)(c). Available at: 5. Code of Federal Regulations, Occupational Exposure to Hazardous Chemicals in Laboratories, 29 CFR (f)(1). Available at: Daniel M. Baer, MD, is Professor Emeritus, Department of Laboratory Medicine, Oregon Health Sciences University, Portland, OR. 428
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