How to promote compliance with policies and procedures to fulfil your legal responsibilities as a Pharmacist leader

As we all know, Pharmacists have legal responsibilities that we need to comply with to ensure that we operate within the law. This in turn protects the safety of ourselves, our patients and our stores. I recently attended the AJP webinar, ‘avoiding the pitfalls – a practical discussion of Pharmacist and Proprietor responsibilities’. It was a great webinar which if you didn’t attend, I recommend you consider watching as they highlighted so many valuable points. The big take-home message was the importance of well-executed policies and procedures that assist in providing oversight, mitigating risk and show compliance.

Something quite profound that was mentioned was that if you’re a manager and you feel you don’t have the skillset to execute the implementation and oversight of procedures, you shouldn’t be doing the job. Ouch, but so true! Our leadership skills, or lack thereof, can definitely impact our ability to fulfil our legal obligations. This type of pressure has the ability to negatively impact job satisfaction, increase anxiety or in the worst-case scenario, land us in front of the Pharmacy Board.

This got me thinking about policies and procedures, why they work and why they sometimes don’t. I am curious, how many Pharmacists know they have these policies and procedures in place but struggle to get them to be complied with, or, to get people to appreciate the value in adhering to them? While I’m sure there are many circumstances that dictate success, I came back to the fact that the rollout, buy-in and appreciation of such policies and procedures are likely where success or failure occurs.

With this being so, I hope this article provides a practical way to help Pharmacists confidently execute their policies and procedures. Furthermore, I hope it helps you maximise staff engagement in a positive and non-confrontational way.

So what can you do?

  1. Discuss the ‘why’explain to your staff why the policy or procedure is important.
    • Why does the policy or procedure exist?
    • What risk is it mitigating?
    • What area of your service is it improving?
    • What is in it for them?
    • What would be the impact if it wasn’t adhered to and something happened? Who would be impacted?
    • Why are you making a ‘big deal’ about this?
    • Why do you need their assistance?
  2. Talk through the policy or procedurewith them and ask for feedback – I don’t think for a second that a Pharmacist gets lax on the DAA checking or handout procedure because they want to cause harm to Mr Jones. Nor do I think they intentionally not complete a DD count as regularly as they would like because they’re lazy. I also don’t think that Pharmacy Assistants don’t ‘do what they’re told’ just to annoy you either… Ask you staff:
    • Are there any barriers to it being implemented?
    • Are there glaring problems or flaws in the plan?
    • Are there simple fixes?
      • Is more education required? Do they know where to locate hard copies required to be completed? Do they know how to complete them? Can they use the computer program?
      • Is the resource they need to difficult to reach in busy times? Would a relocation of a resource such as a computer or a signout sheet or folder make workflow easier?
      • Does a time need to be allocated to complete a certain procedure?
      • Do priorities need to be adjusted? Does something have to give?
  3. Converse more – You may notice that there are some practical imperfections in the policy or procedure that can’t be executed. Or, you may notice that resources are unavailable or limited which impacts compliance. In these instances more conversations will be needed with:
    • Management or an Owner (if you’re not them) – Regardless of how open your superiors are to discussion, bringing up things you would see important to change can be a tough conversation. Try using the format in ‘A quick guide to a tough conversation (pictured right)’ to guide your discussion.
    • The staff that are involved and that you have already discussed the policy or procedure with – Share the feedback and encourage more. These people directly involved with the day to day action are not only the key to success but the holder of knowledge and view points you probably haven’t even realised. More conversation encourages more transparency which creates more engagement and in turn greater compliance.
  4. Make a decision – If changes need to be made after discussing it with others, make them and amend the policy. Explain again the change and how to execute.
  5. Gain acceptance and create accountability – Actively ask for acceptance whether it be verbally or ideally by getting them to sign they understand the policy or procedure and their role in execution. This has a two-fold benefit.
    • One, it gets them to acknowledge they understand why the policy or procedure is there, how to execute it and their acceptance.
    • Two, it sets the platform for accountability. Once you explain the procedure, you have considered their feedback and they accept it, it provides a point to come back to if they are not compliant.
  6. Follow up and encourage everyone to take responsibility for keeping each other accountable – inevitably things get busy and someone will say ‘I’ll skip the procedure just this once’. The problem is, once can turn to twice and then to everytime very quickly… Follow up on the execution, when you see a scenario where the procedure should be used. Watch from a distance to see it is executed correctly, if not, ask the question: ‘hey, I did I miss seeing you complete X, Y, Z or am I mistaken?’ Give them the opportunity to explain why it happened. If it’s a one off and they acknowledge their mistake, well so be it, if it’s a continued occurrence using the ‘A quick guide to a tough conversation’ may help you address the issue more thoroughly. You can encourage your staff to keep each other accountable by simply suggesting that if they see someone not following a procedure that, for example, requires them to sign some form of documentation, they could say ‘I’ll just grab the sign-out book for you’, or, ‘I’ll jump off this computer so you can complete A, B and C’. By doing this you help generate a coaching culture amongst your team. Everyone helping each other get better through guidance and encouragement rather than dictating and finger pointing.

A quick guide to a tough conversation…

Adapted from Susan Scott’s Fierce Conversations

  1. Name the Issue I want to talk about the effect
  2. Select a specific example that illustrated the behaviour, situation, or in this case procedure, you want to change – For example…
  3. Describe your emotions about this issue – I feel…
  4. Clarify what is at stake – I want to share with you what is at stake…
  5. Identify your contribution to the problem – I recognise that my contribution to this issue is that…
  6. Indicate your wish to resolve the issue – I want to resolve this issue…
  7. Invite the other person to respond – I want to learn your perspective. What’s your opinion on this from where you sit?
An example using this process for a superior in relation to a procedure:

I want to talk with you about the effect that not having an appropriate procedure for DAA changes is having on our quality assurance. For example, the other day, there was a near miss when Mr Jones nearly received a pack that had been packed off an old header with now incorrect medications. I feel really nervous that this is going to happen again and my registration (and yours) may be impacted. This doesn’t even consider the negative outcome that Mr Jones may have endured. I recognise that I have contributed to this problem myself by not adhering to a procedure, not ensuring all old headers were shredded and letting the current process go on for too long. I want to resolve this issue by tightening up the procedure by including a hard copy checklist that needs to be completed when a webster change is executed. Through talking with the DAA packer and the other Pharmacist’s I have identified that the lack of this checklist has increased our exposure for errors. I have also identified that with shift change-overs, this checklist should mitigate some of this risk by ensuring that there was documentation and all facets of a procedure executed. I want to learn your perspective on this. What’s your opinion from where you sit?”

An example using this process for a staff in relation to a procedure:

“I want to talk with you about the effect that not following the DAA hand out procedure is having on our quality assurance. For example, the other day, there was a near miss when Mr Black nearly received Mr Blue’s medications. I feel really nervous that this is going to happen again and that there may be a disastrous outcome for a patient. Also, I am worried that it will open our store and myself up to legal implications. I recognise that I have contributed to this problem myself by not following up on the correct procedure and providing oversight to ensure it is correctly followed. I want to resolve this issue by running through the procedure with you again and explaining why it is so important and how to execute it correctly. I also would like your feedback on how we may make the procedure easier to follow for everyone. I want to learn your perspective on this. What’s your opinion from where you sit?”

A final word

It is my experience that compliance from dictating procedures comes with reluctance. Taking the time to explain the importance of a procedure, provide relatable context, the opportunity for feedback and then saying, ‘can you help me achieve this?’ improves your success and your stress levels.

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