proactive decision-making, healthcare compliance

Jay P. Anstine is a compliance professional and consultant in Colorado. He is writing a series of articles on compliance culture for the YouCompli blog. This post looks at proactive decision-making.

A few months ago, I went whitewater rafting with my family here in Colorado. It’s something I enjoy doing because it’s a sharp contrast from my professional life where I often have time to think about the decisions I make. When you’re on the river, Mother Nature doesn’t give you a lot of time. The part I really enjoy is the moment just before you enter the rapids, the point of no return. You’re going in, and you’d better be ready.  

During this float, my wife and I were talking with our guide about navigating the boat down the river. He said something that I thought was interesting as it relates to making decisions. He shared an adage among river guides known as “400-40-4.” That is, at 400 feet you have to make a decision about where you want the boat to enter the rapids. At 40 feet, you had better start making that move, because at 4 feet, it’s too late. 

I have thought a lot about this concept and how it relates to a culture of compliance. For example, does an organization make proactive decisions about regulatory changes when there is still time to adjust? Does it wait until the last minute? If a compliance officer is notifying leaders to decide at 400 feet, and they choose not to act until 4 feet, is that behavior supporting a culture of compliance?  

Below are three steps that may help get your leaders to make decisions farther upstream.  

Step #1: Visualize Your Path. 

One way to establish a culture of proactive decision-making is to set a clear path for your leaders. Think of a new regulatory change as a set of rapids. Your organization is the boat heading toward it. When you’re guiding a boat down the river, you need to know where on the river you want the boat to enter the rapids, and at what angle do you want the boat facing when you go in (that is, frontwards, backwards, 15º, 45º angle, 90º).  

(Note: Our guide told us 45º is often the ideal position.) 

In the context of a regulatory change, you need to visualize your organization’s path toward the effective date.  That means identifying your key decision-makers and what role they will play. It means determining when decisions need to be made, and what deliverables need to be produced (e.g., policy revisions, new forms, checklist). 

Visualizing a clear path before your work begins positions your organization to proactively make decisions early: 400 feet out from the effective date. It will also help put you on a path to communicate clear expectations. You also give clinical leaders time to anticipate the change and participate in decision making, rather than feeling rushed or like they can’t be involved. They are better able to own the response to the regulatory change and champion it to their teams. 

Step #2: Communicate clear expectations. 

Another tip is setting clear expectations. 

If you’ve ever been on a river with a guide, you know they tell you exactly when to paddle, what direction, for how long, and when you can stop. The same approach can be applied when addressing a regulatory change that affects your organization. 

During a kick-off meeting, and any subsequent ones, be very detailed with your decision-makers about what you need from them. More specifically, what decisions they need to make, when they need to make them, and what deliverables you need from them.  

If you’ve ever been rafting, you know before you get in the boat, your guide will give you “the safety lecture.” That means covering topics like what happens if someone goes in, what can cause the boat to flip, and what to do if it does flip. Essentially what is happening here is the guide discussing expectations if you or the boat are not in compliance with the river.  

The same concept applies to communicating about expectations with your decision-makers. If the organization is not in compliance by the required date, what happens? Is there a grace period? Are there fines and penalties, if so, how much? Will a government agency be enforcing compliance?  

By setting clear expectations, you are making a more informed leader, which encourages proactive decision-making and a smoother rollout of policy and procedure changes. 

Step #3: Address instances of overwhelmed-by-perception. 

A proactive decision-making culture can also be fostered by addressing times when decision-makers are what I like to call overwhelmed-by-perception (OBP).  

Perceptions can define our reality, which affects our behavior. Often what holds up a decision is the perception about how a regulatory change affects a leader’s department. Sometimes this perception is based on a false reality. To overcome this challenge, identify and address any knowledge gaps. There are a few different approaches you can take. 

First, visualizing a clear path and communicating clear expectations, as noted above, will minimize instances of OBP. Additionally, understand your decision-makers’ point-of-view and listen to their feedback, good, bad, or ugly. Having this information better positions you to reduce OBP. Finally, communicate in a way they can relate to. I have found decision-makers will ignore what they don’t understand. In “Compliance Committee Engagement” I mentioned using similarly situated stories and business impact to engage compliance committee members. The same concept can apply to reduce OBP.

By addressing OBP, you are ensuring perceptions are not based on a false reality, which can improve your organization’s ability to make decisions more quickly. 

If you want to shift the mindset of your leaders to act more quickly, you need to foster an environment of proactive versus reactive decision-making. If you can get them to proactively make decisions, you will improve your organization’s culture of compliance.  

Sometimes larger organizations look at change initiatives and say they’re too big to move quickly – that change and decision-making move at a pace similar to turning a tanker ship. 

But here’s the thing – the smaller boats like river rafts don’t turn on a dime. Experienced river guides see the rapids coming, make decisions about their course, and move before it’s too late to successfully orchestrate. The timelines might be longer in large organizations, but the discipline is the same. If you want your organization to be more nimble in making decisions, like that of a river raft, a 400-40-4 mindset can help. Time, clarity, communication, and compassion toward overwhelm can all help you equip your leaders to participate in decision making and own the decision once it’s made.  

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