In this week’s guest post, CompliSpace’s Principal Consultant and Sector Lead Education, Craig D’cruz, draws on his decades-long experience in schools to explain why policies matter and how you can use them to improve outcomes for consumers, staff and your organisation.

Why Have Policies?

Let’s start with an example.

If a critical incident occurs in your organisation – for example the unexpected death of a consumer – what will staff and management do?

This is NOT the time to start to develop plans. This is not the time to decide which staff to organise and communicate with or how to communicate with families and relevant health professionals.

If you have current and compliant policies and procedures, you already have a plan. In this case your Incident Management and Resident Care Policies will list the steps that need to be followed, including requirements related to mandatory reporting and other compliance areas.

There may be further assessments, planning, decisions and additional required actions to be completed, but you can rely on policies and procedures without wasting time figuring out next steps. Additional tweaking may be required, including a review of the entire process at the end, but relying on the prepared and trusted policy will allow you to focus on the things that matter: consumers, families, the wider community and staff.

Having been involved in many critical incidents that sadly involved deaths of parents and students in schools, including some by suicides, I can assure you that having a policy to follow, especially during a time of mourning, allows your organisation to deal with the issue empathetically and effectively without having to waste time wondering how best to help everyone who has been affected. You can rely on the process, and this allows you to focus on people and their needs.

So why else does an organisation have policies?

• to ensure that the organisation meets its strategic goals and objectives
• to manage risks
• to meet legal requirements and remain compliant with regulations such as the Quality Standards and requirements for policies and procedures (e.g., Standard 8 and the role of Governance)
• to maintain and enhance reputation
• to meet the requirements of funding
• to meet the requirements of clients
• to attract and engage prospective new consumers
• to create desired behavioral outcomes that are critical to the development of a positive organisational culture. And above all:
• to support staff to provide the best possible care and service outcomes for consumers.

Therefore, you have policies to ensure that what you say that you do, you do. Policies ensure that your organisation achieves the quality of care and services, behavioural outcomes and organisational culture that you wish for your staff and your consumers.

Policies and procedures are the first step toward achieving individual responsibility by clearly establishing expectations with respect to the conduct, scope of practice, accountability and responsibilities of all staff members.

What Makes A Good Policy?

A good policy, despite all the rhetoric, is basically a document that is written for an intended audience and therefore provides a solid control for a risk.

In simple terms, policies and procedures:

• need to be readily accessible to your workforce and relevant stakeholders and reviewed accordingly
• are a strategic part of your training and competency program
• require a practical application
• need to be maintained to ensure planned outcomes are achieved.

Good polices clearly communicate the why, what, who, how and when of the risks that are being controlled and ensure that requirements are clearly understood and can be readily enacted by staff, volunteers and contractors to whom the policies may apply.

What Should Be In A Policy?

The design of an organisation’s policies and procedures is up to each organisation. However, a very general rule of thumb is to include:

• the name of the policy and a reference code (if applicable)
• the date the policy was approved (and by whom)
• version management, as part of the information management process
• a list of any related or linked policies and/or legislation
• a policy owner who can field inquiries about the policy (preferably by role)
• a brief overview of the issue the policy is addressing
• definitions of important terms or key language
• the scope of the policy and the intended audience
• legislation and best practice that impacts the policy and used to reference key information
• a policy statement and
• the procedures or guidelines that staff need to follow.

The policy statement must indicate the organisation’s position on a particular matter. It needs to be clearly written to provide direction, expected behaviour, accountabilities, and responsibilities.

While the policy expresses the organisation’s position on a particular issue, the procedures detail how the policy is to be enacted or implemented. Procedures may stand alone but they are usually associated with a policy. They set out the actions that should be taken to give effect to and achieve policy outcomes.

How and Why Do You Use Policies?

Policies are valueless if they are not well-known, clearly understood and implemented fully by all staff.

Therefore, all staff should be trained in the policies of the organisation that are applicable to them. They need to know clearly what is expected of them (responsibilities and accountability) and how to implement the policies and procedures effectively.

Regulators are quick to find if an organisation has simply created policy as a check box compliance action. They will often question staff about their understanding of policies and will observe staff in the workplace to ascertain if the policies are actually embedded within the employee’s practices and behaviour. In other words, regulators, including the Aged Care Quality and Safety Commission, will check to see if the policies are part of the culture of the organisation.

However, the threat of being assessed by a regulator should not be the only reason for using policies.

Policies provide the scaffolding for the actions of employees. They not only protect your organisation against risks, but they also protect staff, too.

If an organisation has well-managed, up to date policies, and if it ensures that staff are trained in how to apply the policies within their roles and scope of practice, then employee behaviour and practices will align with the policies. And if behaviour aligns with policy, it will also align with the organisation’s cultural expectations.

Sometimes, organisations can feel like they are ‘drowning’ in compliance and policies. That is, until there is an adverse event or critical incident. When something happens and there is a policy and a set of procedures for the organisation and the staff to follow, they do not have to ‘think’ about the machinations involved in managing and resolving the issue or incident. If staff follow the policy and procedures, management and resolution will happen. An organisation can control the risk far more effectively because they are more able to focus on the people involved in the issue. And isn’t that what duty of care is all about?