Janice Putnam, PhD University Victoria Steel, PhD Laramie · SCCE Higher Education Compliance Conference June 5‐8, 2016 1 Janice Putnam, PhD University ofCentralMissouri [email protected]

SCCE Higher Education Compliance Conference June 5‐8, 2016

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Janice Putnam, PhDUniversity of Central Missouri

[email protected]

Victoria Steel, PhDLaramie County Community College

[email protected]

Designation of a Compliance Officer Development of Compliance Policies Development of Open Lines of Communication Provision of Training and Education Internal Monitoring and Auditing Response to Detected Deficiencies Enforcement of Disciplinary Standards Assessment of Program’s Effectiveness

ComplianceFor each policy, there needs to be a procedure for how to apply the policy, how it is enforced, whom it affects, and who is in charge.

Operational NeedsDeveloping clearly written policies and procedures that are documented, updated, and followed, brings structure to an organization.


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Managing RisksPolicies and procedures serve as a internal control method ensuring consistency across the organization.

Continuous ImprovementConsistently applied policies and procedures assist in the day-to-day decision-making processes.

Examine ethical and tactical policy processes identified in PH

Leverage these processes to improve governance, risk management and compliance in HE

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Complex, highly regulated systems Experts generate successful outcomes in their

target population Lag behind for-profit in innovations

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https://www.eab.com/-/media/EAB/Technology/Student-Success-Collaborative/Members/White-Papers/EAB%20Population%20Health%20Management%20Whitepaper.pdf


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Similar service ethic Patient/student focus Increased efficiency impacts more lives (not

necessarily profit margins)

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https://www.eab.com/-/media/EAB/Technology/Student-Success-Collaborative/Members/White-Papers/EAB%20Population%20Health%20Management%20Whitepaper.pdf

The terms of reference of the Council are: to identify and define ethical questions raised by

recent advances in biological and medical research in order to respond to, and to anticipate, public concern;

www.nuffieldbioethics.org

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The terms of reference of the Council are: to make arrangements for examining and reporting

on such questions with a view to promoting public understanding and discussion; this may lead, where needed, to the formulation of new guidelines by the appropriate regulatory or other body;


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The terms of reference of the Council are: in the light of the outcome of its work, to publish

reports; and to make representations, as the Council may judge appropriate.

The Nuffield Council on Bioethics is funded jointly by the Medical Research Council, the Nuffield

Foundation and the Wellcome Trust.10

Risk Precaution and Proportion Behaviour Change Intervention Ladders Stakeholders and Policy Making Economics Choice Vulnerable Groups, Inequality, and Targeted Interventions Evidence

“Part of the answer to the question of whether or not the state should intervene to protect and promote health depends on the nature and extent of the risk involved, including the degree to which it is potentially under the control of the individual.”



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Statistical/Technical Approach Politics and Culture Perceptions and Judgements Decision Theory

DHS/OFCO/FAPO Version 1.0

No. Subject Score

Answer these questions for program activities: NA 1 2 3 4 5

1. Newness of program2. Expected appropriation for the program in

immediate year following3. Nature of the program4. Recent changes in resource levels5. Impact or sensitivity of the program on

persons or organizations external to the agency


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“In any policy decision, it is furthermore important to consider the seriousness of the problem and the urgency with which it should be addressed…issues that pose severe and urgent threats to the health of many people are rightly prioritised over those that are only ‘possible threats’, affect health in a relatively minor way or involve fewer people.”


Policy Response Test Balance: aim justifies means Suitability: means justifies end Necessity: choice among means



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“The success of public health interventions often depends on more than the cooperation of members of the population. Many different stakeholder groups, including health professionals, the corporate sector, non-governmental organizations (NGOs), institutions of civil society and the media, can have a crucial role to play.”


“All the various strands of opinion and its translation into policy is a matter that politicians and their advisors must consider…[and] can have personal or professional conflicts of interest…”



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Funders Accreditors Auditors Donors Institutional Finance and Administration Compliance Offices/Functions

◦ Program operations: Management, program staff, partners, funding agencies, and

coalition members.

◦ Those served or affected: Patients or clients, advocacy groups, community members,

and elected officials.

◦ Intended users: Decision-makers, such as partners, funding agencies,

coalition members, and the general public or taxpayers.

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http://www.cdc.gov/eval/guide/step1/

• Valuable stakeholders• Inspires and informs about policy and practice activities • Creates space for voices to be heard• Fosters social awareness and change• Facilitates understanding• Contributes to evidence based policy• Prevents hindering of progress

Hovland, I. (2007). Successful Communication: A toolkit for researchers and civil society organizations, RAPID Toolkit, London: ODI (http://www.odi.org.uk/sites/odi.org.uk/files/odi-assets/publications-opinion-files/192.pdf)

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Mapping: Assesses stakeholdersPrimarySecondary Key

Analysis: Importance and interestPowerInterest

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◦ Hovland, I. (2007). Successful Communication: A toolkit for researchers and civil society organizations, RAPID Toolkit, London: ODI (http://www.odi.org.uk/sites/odi.org.uk/files/odi-assets/publications-opinion-files/192.pdf),

◦ Babou, S. (2008). What is Stakeholder Analysis? (http://www/pmhut.com/what-is-stakeholder-analysis)◦ Glassman, T., Reindl, D., Whewell, A. (2011) Strategies for implementing a tobacco-free campus policy. Journal of American College Health. 59(8) 764-768.

Autonomy Challenges:◦ Unavailable ◦ Ingrained habits ◦ Predetermination by industry & media◦ Abundance of options

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http://nuffieldbioethics.org/wp-content/uploads/2014/07/Public-health-ethical-issues.pdf

Change the external circumstances making healthy choices easier to make

Improve individual’s capacity to make healthy choices

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Written information Websites Computer based information and virtual support Training for professionals in communication

skills Coaching and question prompts Decision aides for patients Self management education programs

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http://www.who.int/management/general/decisionmaking/WhereArePatientsinDecisionMaking.pdf

Equity: The fair distribution of benefits and burdens.

Inequities - differences in health unnecessary avoidable considered unfair and unjust

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http://www.who.int/csr/resources/publications/WHO_CDS_EPR_GIP_2007_2c.pdf

Socio-economic status Gender Race or ethnicity Migration history Degree of urbanization Religion

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Advantaged groups show longer life expectancy, better health and more health-promoting behaviors

Evidence links low socio-economic status (occupation, education, income or assets) to poorer health

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Targeting disadvantaged groups

Targeting at risk groups

Universal Provisions

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Engage and empower community leaders Assess needs and readiness Relevant, current local data Sources of influence among groups Culturally oriented education and economics Assistance for local programs Identify contributing factors Tailored messages

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Missouri Comprehensive Tobacco Control Strategic Plan (2016).


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health systems in all countries struggle to effectively implement evidence-informed interventions.

“In low- and middle-income countries…often there is no process…to ensure…scientific evidence…is accessible and translated within the context to the program managers and policy-makers who need them.”

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http://www.who.int/tdr/news/2013/developing_evidence/en/

Most policy makers reportedly “were not trained to distinguish between good and bad data, …

and were, therefore, prone to the influence of misused “facts” often presented by special interest groups.

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Brownson, R. Chriqui, J. & Stamatakis, K. (2009). Understanding Evidence-Based Public Health Policy. Am J Public Health. September; 99(9): 1576–1583.

Quantitative Evidence Hierarchy◦ Systematic reviews◦ Peer-reviewed journal articles◦ Public health surveillance systems◦ Individual programs and policies

Qualitative Evidence◦ Observations◦ Interviews◦ Focus groups

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Electronic information Trust issues Sources of information State to state comparisons

Surveys of policymakers: ◦ priorities, attitudes towards lobbying efforts, obstacles,

attitudes and voting intentions

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Process – enhances policy adoption Content – identifies effective elements Outcome – documents policy impact

Policies evolve as they diffuse Framing is important Partnerships between researchers, practitioners

and policymakers enhance these processes

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Economic arguments varyo different ethical frameworkso different assumptions about health behavior.

Tradeoffs affect policy ◦ Employment and health◦ Employment and design of environment

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◦ Reducing healthcare cost to system◦ Fewer work absences◦ No health related loss of skills◦ Other values: quality and quantity of life, public

good, reducing health inequalities

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Big stick

Aim – to ensure economic efficiency and make best use of scarce resources

May put burden on those with variations indisposable incomehealth behavior

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“Personal behaviors can have a significant effect on health, and therefore a common theme in public health policy is behavior change.”

Public Health Behavior Change Theories Social Cognitive Theory Theory of Planned Behavior The Trans-Theoretical (or Stages of Change) Model


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“A more intrusive policy initiative is…acceptable only if it is clear that it will produce the desired effect and that this can be weighed against the loss of liberty that will result.”

Considerations Individual Freedom and Responsibility Economic Costs and Benefits Societal Costs and Benefits

Do nothing or simply monitor the current situation; Provide information; Enable choice; Guide choices through changing the default policy;


Guide choices through incentives; Guide choice through disincentives; Restrict choice; Eliminate choice.



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Public Health and Higher Education have many commonalities

Nuffield Council on Bioethics has nine Public Health policy process considerations

These considerations can be useful in designing Higher Education compliance and risk reduction policy development processes

These considerations can provide structure for evaluating ethical and evidence elements when assessing compliance policies

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Documents

Janice Putnam, PhD University Victoria Steel, PhD Laramie · SCCE Higher Education Compliance Conference June 5‐8, 2016 1 Janice Putnam, PhD University ofCentralMissouri [email protected]