From Enforcement to Compliance
through Best Practices and
Provider Support Services
Presented by Sandra Wooters and
Debra Avery, PA Dept. of Public
Welfare, Adult Residential Licensing
Provider Support Services is:
• Services designed to encourage voluntary
care improvement;
• Services that protect the public by helping
providers to increase their knowledge,
thus improving services and rules
compliance;
• A strategy for improving consumer
protection while reducing the
proportional effort that might otherwise
be directed at enforcement.
Provider Support Services is:
(Cont.)
The “hidden backbone” of
consumer protection.
Provider Support Services:
From Enforcement to Rule Compliance
Special Challenges Faced by Facilities
Caring for Low Income Consumers
• Experienced licensor’s are sensitive to
the different compliance issues for small
facilities, rural facilities, low income
facilities, chain operated facilities, etc.;
• In these times of economic uncertainty
Providers are being asked to do more
with less money, and with less support
from community social services
agencies.
Goal: Affordability
“No
worthwhile strategy can be
planned without taking into
account the organization's ability
to execute it…”
(Former Honeywell CEO Larry Bossidy
and business consultant and author Ram Charan
in their book titled Execution: The Discipline of
Getting Things Done)
Goal: Affordability (Cont.)

It is wrong to assume that maximum quality is
the ultimate goal.
Should every hotel be built to the same
quality as The Ritz?
Simplify, and where appropriate, reduce the
number of procedures and process that
reflect how work actually gets done.
 Help identify strategies unique to the
environment and population served.
 Approach compliance in a positive and
supportive manner.

Goal: Affordability (Cont.)
Some of the best tools include:
• A three ring binder
• A highlighter
• A hole punch
• A rubber finger
Goal: Advice, not rule enforcement!
• All advice, however formal or informal it may
be, must always leave the other person
completely free to accept or reject it!
• Suggest options generally available, or available
in that provider’s particular situation, which
would achieve compliance with the rule.
• Inquire what are the needs of the
provider…many times their actual needs are
not based on a regulation but end up affecting
regulation compliance.
Goal:Accountability/Responsibility
• Place and keep responsibility for
compliance on the provider;
• The licensor should encourage but not
become over-invested in the provider’s
success;
• The goal is to build self-reliance and
managerial competence among providers;
• Tie updated processes to individual job
responsibilities.
Goal: Accountability/Responsibility (Cont.)
• Accountability is external. It is an
agreement to be held accountable by
another for your operation or results.
• Responsibility is internal. It’s a feeling of
ownership. True responsibility stands out
because people are leading, learning,
correcting, and improving. The sign of a
healthy, high-performing facility.
Goal: Use a “Systems Approach” to
Problem Solving
• View “problems” as parts of an overall
system and solution, rather than react to
a specific part, outcome or event;
• Consider all possible interactions
involved with the problem situation;
• Consider three types of changes;
changes in structure, in procedures, and
in attitudes.
Goal: Use a “Systems Approach” (Cont.)
• What Happened?
• Why did it happen?
• What can be done to prevent it from
happening again?
• How often is the system going to be
monitored and by whom?
Goal: Provider Self-Sufficiency
Build a network of provider support.
Achieved thru use of self, agencies
and the community at large.
Goal: Provider Self-Sufficiency (Cont.)
• What are the strengths of the provider
and staff?
• What agencies and community
organizations have resources to offer to
the facilities?
• Encourage the provider to reach out to
other providers who have been
successful following the rule.
• Help the Provider develop a monthly
provider network meeting.
Tools




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Tools must be affordable and easily achievable
by both staff and administration.
Tools should be designed in a proactive
approach to rules and not reactive.
Tools should include auditing, review,
observation and training.
Tools should be used daily, weekly or monthly
in an effort to reduce repeated non-compliance.
Develop a team approach to compliance. Help
the staff understand the rules which will
empower the staff to join the process.
Best Practices
Some of the best tools include a 3 ring binder, a
highlighter, hole punch and a rubber finger!
 Create a good policy and procedure manual
that can also be used to train staff.
 Encourage the development of a licensing ready
book.
 Review a non-compliance report and assist in
the development of an auditing, review or
observation tool. Be sure the steps are easy to
understand, who is responsible and how often
will the non-compliant area be monitored,
audited or observed.

Best Practices (Cont.)

Utilize a “Walk About Workshop” to instill
a new system designed by the staff. Walk About
Workshops, or instant in-services, are key to
helping staff gain a greater knowledge of a rule
and how to fix the rule once observed.
The Walk About Workshops are 15 minutes or
less of training that can be completed at each
staff’s work station, in the office, or in the break
room. Review the process with all of the staff
involved in that process. Don’t’ forget to get staff
signatures!
Best Practices (Cont.)
 Staff must understand what happened and why
it was non-compliant. Work with the staff on
how to achieve compliance. They usually know
why an event happened, and can help develop a
good “system” to prevent it from happening
again. Ongoing staff training on regulations is
one of the best methods to achieve compliance.
Best Practices (Cont.)

An example of a simple observation tool to
reduce physical site non-compliance is a one
page foldable tool that fits into the staff’s
pocket and reminds the staff of what to observe
to reach rule compliance. The physical site is
ready for inspection at anytime!
Best Practices (Cont.)

An example of typical non-compliance is
medication documentation errors. Med errors
can be easily identified by staff, if trained on
what to look at on the Medication
Administration Records. Ask the medication
staff “how do you end or begin your
shift”…..the answer should be “check the
medication administration record for missed
documentation at the beginning and end of each
shift”…..encourage the staff towards this
approach…..this is an easy, no cost
fix…alas….……a reduction in documentation
errors!
A Strong Provider Support Component is
one that:
• Increases compliance and consistency in
regulatory compliance
• Improves relationships between licensees
and licensors
• Reduces the need for sanctions
• Reduces time licensors spend on
inspections and complaints
• Increases support for sound regulation
• Increases support for consumers
Conclusion
Provider Support Services do more than
give providers tools and technical
support.
They also model a value and goal that
should be the heart, soul and the driving
force of every human service care facility
or agency.
Provider Support Services is the link
between licensing and provider
compliance.
Resources
Commonwealth of Pennsylvania Provider
Support Program tools
 Commonwealth of PA’s 2011/2012
inspection results
