Policy Management Essentials: An Interview with IntraVires - Part 1

If you've ever worked within the policy management space, you quickly learn how complex it can become. There are many factors to evaluate including; establishing a guiding policy, appointing the proper policy team and coordinator, adopting a charter, and setting expectations and achievable goals. 

We sat down with the legal professionals from IntraVires Healthcare Compliance Consultants to help give organization's a better idea on how to get their policy management process off the ground and keep it running as steadily as possible. Below is part 1 of the interview series.

Interview By: J.P. Cervo

Interviewees: Shelley Koltnow & Dan Fisher

Etactics: Shelley, the focus of today’s interview is on best practices when it comes to policy management. Would you start us off by defining what best practices are and how to identify them in the policy and procedure process?

Shelley: To find out what your best practices are, folks can look at past experiences to better identify what their organization does well and then compare those to objective standards established by other organizations. From there, a benchmark can be set to guide how the process can be improved.  Repeating this cycle allows an organization to move the needle toward better performance through continuous improvement. 

Comparing your performance each time, possibly at the end of each meeting via a group discussion, can help to recognize and establish key performance indicators, or KPI’s,  as benchmarks for those processes that the organization seeks to improve.

When members own the process, so in this case the policy coordinator and the policy committee, they will be more likely to solicit feedback. They might send surveys from time to time, see if others feel the process is in line with the stated goals and objectives, and continually follow the processes as established or as agreed to enhance the reliability. The more reliable a process is the more likely it will be successful. The organization can review and revise parts of it that aren’t working as expected.

Etactics: Can you explain what a benchmark is in the policy management process? How can you identify what those benchmarks are and use them moving forward?

Dan: A good note to make about benchmarks is that they’re temporary. They evolve. Whenever you establish your indicators for how your policy process should go or what best practices you find, those benchmarks can change over time as your policies change, your organization changes, or best practices change. So when you really set your standards and are aware, they are able to evolve and mature.

Establishing a benchmark is a great way to help measure your reliability. That way you, you can physically see if you are working towards the goals you’ve set and determined if you’re on track.

Etactics: During conversations we’ve had in the past, you’ve stressed the importance of creating a guiding policy to memorialize the policy management process. How can an organization incorporate these elements into their guiding policy so that it becomes both repeatable and functional?

Shelley: We’ve mentioned in the past about how important it is to have a policy that lays out all the steps of a reliable policy management process. But as a recap, a guiding policy has to contain those components.

A guiding policy explains the steps in the policy management process. It creates a roadmap that process owners follow and then, as both Dan and I have mentioned, it also makes sure that that process is reliably followed. From there, the policy coordinator, who we mentioned is the designated person to lead this management process, and the policy team, that will be created to support that person and process, establishes a format for the policy manual and the individual policies themselves so that they’ll all be consistent.

Etactics: Another critical step in establishing the policy and procedure management process is designating a Policy Coordinator. How can you determine who the best candidate is to fill the position? '

Shelley: It’s important for a Policy Coordinator to be able to manage the process and there’s two errands that lead into that. First, they need to have the skill set, of course. Second, they need to have the bandwidth to able do it. There has to be some consideration for the person’s ability to have the time to do this job well.

We also recommend that the organization has recognition for this position in a couple of different ways; the person’s job title, or compensation. The management should really endorse a whole process of recognizing the effort that is going to be made by the policy coordinator, especially because this person is going to be accountable to perform job instructions specific to that responsibility. 

A couple of KPI’s for the policy coordinator; 

  1. Are they successful in the first six months in meeting the job instructions that was created for the job instructions or responsibility?
  2. Are they meeting the requirements or measurements on their job instruction going forward and that could really be combined with an annual job review that’s already being performed by the organization?

Etactics: You’ve mentioned how assembling a team to support the policy coordinator is important. Can you reiterate the importance of having this team and who should be considered to fill these positions?

Dan: Policy team members have to be willing to participate and be invested in the policy process and management needs to be copacetic with those members. A few factors to keep in mind are; members having the time to serve, a distraction from their daily jobs, and their willingness to serve.

They don’t need to be high-level personnel, so executives or senior directors don’t necessarily need to be the one to serve on the policy team. It can be processed owners, employees who are more knowledgeable about a certain smaller area of the company, or it can be the subject matter experts who are familiar with the policy process.

I think the most important factor to keep in mind is that the team members want to participate. Putting them on a team can be a good way to motivate them and building a team that works well together can quickly build momentum. A policy team’s membership should be representative of the whole organization to make sure that the team has a holistic view of the company and whenever policies come through, members can be subjected to matter experts in their respective area.

Etactics: The first duty of the policy team is to develop and adopt its charter which serves as the backbone when the team needs inspiration. What parameters should be included in the charter so the policy team is authorized and able to fulfill it?

Shelley: The charter is really like the constitution for the committee so it’s important to put in issues that pertain to membership on the team; like how members are going to be appointed and re-appointed, defining terms of membership, who nominates members, and attendance requirements. For example, charters may say that members must attend at least three quarters of the meetings, either in person or by phone.

It may also include whether or not the organization will allow a member to send a substitute or  what steps to follow if a member needs to be replaced. For example, if a person leaves the committee because their roles or responsibilities within the organization change, how do you replace that person and what’s the process.

The charter should also address the meeting requirements such as how often, what time of day, and where the meeting will take place. You can add in other ways of holding these meetings like whether or not telephone meetings or Skype meetings will be acceptable if everyone is in a different locations. Along with setting the requirements for the meetings, someone should be appointed to take minutes and have clear guidelines on how the minutes should be taken. Finally, it should explain how the charter will be amended if any provisions need to be added or removed if it changes during the policy process.

Etactics: How do you decide the roles and expectations for the different members of the policy management team?

Dan: A great way to make sure that people know what role they play in the policy management team is to set expectations before the team meets and the policy process kicks off. Anyone could have the opportunity to become an author that would write or co-author a policy and possibly delegate their writing to a support staff member or co-author. Though anyone can stop being an author, normally sponsors are senior directors or executives who are held accountable for their specific area of the organization along with reviewing policies that relate to their area of expertise and supporting the authors.

A couple of KPIs to consider with the policy management team:

  1. The policies should be submitted with an author and sponsor listed. This helps the organization see what roles everyone played in the policy making process.
  2. The policies should be submitted before they expire to show strong communication between the authors, the sponsors, and the team.