In NIATx system-level Change Projects, Change Teams work to eliminate system-level barriers to effective service delivery. Making system-level changes serves many purposes, and one of the most important is to lead by example. In making changes at the system-level, you address the issues of your customers—the provider agencies—in the same way that providers address the needs of their customers.
By considering provider agencies as the customers of regulatory or reimbursement services from the state (or another regulator or payer), you can use the same tools that a provider uses to identify the barriers faced by clients seeking treatment. Ask providers what system-level processes or policies create barriers to providing quality service.
Systems leaders need to walk through their own processes to understand what providers experience. Some walk-through ideas to consider:
Identify a Change Project based on the results of your walk-through and discussions with providers, form a Change Team, and use the PDSA model of rapid-cycle change to make improvements.
Regulatory changes take a long time in most places. Do you have waiver authority? Waiving regulations for some agencies for a short period of time can be one way to test out a regulatory change (the DO in the PDSA Cycle). Involve the providers when rewriting the regulation. They will be able to help you identify pitfalls of changed language and the unintended consequences of removing barriers in a certain way.
System-level Change Projects often expose long-held beliefs about regulations or paperwork that are false or obsolete. Some procedures become institutionalized based on the preferences of a single licensing or contract reviewer. Staff members may continue to adhere to a rule that no longer exists. Treatment agencies may unwittingly use multiple forms to satisfy one requirement.
As a former SSA used to ask providers, “Show me where it is in the regulation. Is it a licensing requirement? A contract requirement? In Medicaid regulation? If it isn’t there, then you don’t have to do it, no matter who told you you do.”
Study the change: If you have piloted a change using waiver authority with a small group of agencies, measure how it worked. Did it decrease the amount of time they spent doing some aspect of their process? Has it improved their ability to see clients more quickly or to see more clients or to spend more time in engaging clients rather than filling out paperwork? What is the feedback from the providers? Are you ready to change the regulation?
If you have gone through the regulatory change process, how much negative feedback did you get with the rule change? This is one measure of how helpful it is and how involved the providers have felt in the process.
Act: There are three things you can do after a pilot, just as there are for providers: adapt, adopt, abandon.