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Formulating policies: essential supervisory tool.

In the June 1985 Issue of MLO, Annamarie Barros told how to develop a policy and procedure manual-must reading for anyone who has to prepare such a document.(1) In a more recent issue of MLO, Dr. Carmel Marts Day skillfully related management problems to policies.(2) Now I would like to focus on the uses of personnel policies and the laboratory supervisor's role in preparing or enforcing them.

As Barros noted: "A policy manual is the lab's most effective management tool and its most neglected one." Policies are broad guidelines for reaching goals or standards and implementing the philosophy of organizations.

Policies have greater "impact than in the past becauseof current issues concerning moral behavior, professional ethics, and patients' rights. Some supervisors serve on institutional ethics committees, which address policy issues.

Generally, the higher the level of its origin, the less specific a policy will be. Supervisors who complain that a policy is too vague fall to realize it may be worded that way to permit modification or provide flexibility in implementation.

In stating what must be done, policies can be as specific as desired. They are backed up by procedures and/or rules. Procedures describe how policies are to be carried out, while rules are restrictions on how the procedures are performed.

A sound policy is one that is needed, achievable, flexible, enforceable, acceptable, understandable, and fair. If these features are not present, it may be better not to have a policy.

Sound policies accomplish a number of important things:

+ They enhance communication, promoting understanding, clarity, and consistency. Knowing what is expected of them, employees feel more confident and police themselves.

+ They eliminate repetitive decision making, standardize responses, and save time.

+ They provide documented controls for performance evaluation and discipline, as required by the joint Commission on Accreditation of Healthcare Organizations and other agencies.

+ Used during indoctrination, they help new employees get off on the right foot. When starting a new job, employees are highly receptive to such information. They will accept policies presented by a credible, well-informed representative of the organization.

Supervisors must understand the intent of policies in order to interpret and explain them. This is important because employees will accept policies only if they know the reasons for them. (When policy changes are made, supervisors should pass out copies to all personnel and get their signatures.(3)

Supervisors should also know how much latitude they have in modifying or establishing personnel policies.

Enforcement of policies should be uniform and fair. This may require overcoming a tendency to overlook transgressions by more valued employees. Staff perceptions of unfairness often translate into Equal Employment Opportunity Commission grievances.

We usually refer to policy manuals when disciplinary problems flare up or when disputes arise about privileges and benefits. We should, but often don't, think of policies in many other cases, such as introduction of a new service, productivity or quality assurance problems, time management problems, complaints about laboratory service, morale problems, repetitive questions, and scheduling problems.

Say your laboratory has introduced a new service-collection of specimens at outpatients' homes. After a phlebotomist is mugged in a high-crime section of town, you realize you should include a policy concerning out-of-bounds areas.

If inpatients complain about cold breakfasts because of late blood collections, you need a rule specifying when phlebotomists must complete their rounds. If, in a short span of time, several employees ask questions about handling specimens from AIDS patients, they are really telling you that a policy is needed on an important issue.

A policy must be written out; if it is unwritten, it does not really exist. Figure I shows the 10 steps required to formulate and maintain a policy.

Before undertaking this activity, make certain you have the authority to do so. It is also wise to discuss any proposed change with the person you report to.

The introductory policy statement should include the purpose of the policy. If the policy is required by a regulatory or accrediting agency, that should be stated. Sometimes a definition is also needed. For example, a policy on sexual harassment should refer to Section 703 of Title VII of the Civil Rights Act of 1964. It should also state exactly what is meant by sexual harassment (see Figure 11).

Here are some personnel policies that supervisors are usually responsible for planning or enforcing: orientation program; work schedules (daily assignments, compensatory time, meal and coffee breaks, vacations, overtime, and call-backs); staff meetings; visitor control; and the use of radios, telephones, and computers.

Insecure supervisors divorce themselves from unpopular policies. They may say to employees: "Don't blame me for that stupid policy" or "Management expects you to do this." Even worse, they ignore a policy or depend on someone else to enforce it. As a result, they and the organization lose the respect of employees.

What supervisors should do is report policy deficiencies to higher management. Policy manuals should be reviewed annually and modified as needed. Obsolete policies should be eliminated.

A lack of policies, unnecessary policies, and poor policies all cause problems. Management by crisis prevails when no policies exist. Managers waste time on repetitive decision making and answering questions. Uncertainty and conflicts abound.

Unnecessary policies, on the other hand, entangle the organization in red tape. They are often created by weak managers to avoid confronting disciplinary problems.

Frustrated by Mickey Mouse rules, employees may soon become careless about essentials--errors of omission occur when forms to be filled out are unnecessarily complicated, for example. It is said that when Rene McPherson took over the Dana Corporation (among America's "excellent" companies, according to Tom Peters), one of his first acts was to bum a thick stack of policy manuals.

Then there are poor policies. Whether they are unclear, weak, unfair, or illogical, these guidelines spawn confusion, create obstacles to effective performance, and force numerous exceptions.

When actual practices stray from policies and procedures, or when practices turn into unwritten policies, trouble brews. Lax adherence to policies may cause legal problems and endanger staff morale.(2) Here are some particularly hazardous areas:

Employment issues. Illegal questions in interviews. Premature promises of raises or promotions. Faulty descriptions of duties or performance standards.

Indoctrination programs. Incomplete or poorly supervised programs. Overrating poor performers at the end of their probationary phase.

Scheduling. Discrimination in work, holiday, overtime, or callback schedules.

Handling of problem personnel. Faulty counseling and disciplinary action. Sexual harassment. Inadequate processing of complaints and grievances.

Avoid unnecessary trouble. Set and adhere to sound policies.

1. Barros, A. Developing an effective policy and procedure manual. MLO 17(6): 28-33, June 1985.

2. Day, C. M. Three diagnostic clues to management problems. MLO 19(8): 74-79, August 1987.

3. Fitzgibbon, R J., and Snyder, J.R. "The Laboratory Manager's Problem Solver," p. 37 Orabell, N. J., Medical Economics Books, 1985.

The 10 steps in formulating and maintaining a policy

1. Define the need for a new policy or a revision of an old one, and describe its purpose.

2. Determine if the need is great enough to warrant a new policy or policy change.

3. Consider solutions other than policy making.

4. Gather data and input from others, especially those who

would be affected by the policy.

5. Check the rough draft for the following:

Compliance with institutional philosophy, goals, and policies.

Completeness, clarity, and understandability.

A description not only of "what" (policy statement), but of "how" (procedure) and of any special restrictions (rules).

Its acceptability by persons affected.

Ease of enforcement.

6. Circulate rough draft or discuss with others. Get approval

from your own supervisor.

7. Modify the draft if necessary.

8. Publish the final document. Insure that everyone affected

gets the message and understands it.

9. Enforce the policy fairly and uniformly.

10. Modify or eliminate the policy when appropriate.

How to strengthen a policy

Original sexual harassment policy

"Sexual harassment has long been recognized as a violation of Section 703 of Title VII of the Civil Rights Acts of 1964. Harassment on the basis of sex, whether it is physical or verbal, by any employee of the hospital is forbidden and will result in disciplinary action. Any employee who experiences sexual harassment should contact the director of human resources."

Major weaknesses of the above:

Sexual harrasment is not defined.

Harassment by non-employees (i.e. physicians, salespersons, members of the board) is excluded.

The full procedure is not spelled out.

Reformulated sexual harassment policy and procedure

Policy statement

Our policy is that all personnel will work in an environment free from sexual harassment. All allegations of sexual harassment will be actively investigated, and if it is determined that harassment has occurred, appropriate disciplinary action will be taken. This may include discharge of the offending employee.

Reason for policy

Sexual harassment violates Section 703 of Title VII of the 1964 Civil Rights Act against sexual discrimination in employment. Acts that constitute sexual harassment include, but are not limited to, sexual advances and suggestions where:

1. Submission to such conduct is either an expressed or implied condition of employment.

2. Submission to, or rejection of, such conduct is used as a basis for an employment decision affecting the harassed employee.

3. The conduct has the purpose or effect of substantially interfering with an affected person's work performance or creating an intimidating, hostile, or offensive work environment. This kind of conduct includes unwelcome or personally offensive activity, such as:

Repeated sexual flirtations, advances, or propositions.

Repeated verbal abuse of a sexual nature, sexually related comments and joking, degrading comments about an employee's appearance, or the display of sexually suggestive objects or pictures.

Any uninvited physical contact or touching, such as patting, pinching, or constant brushing against another's body.

Procedure

By harassed employee:

1. Firmly confront the person. State how you feel about the actions and request that the person stop immediately.

2. It the sexual harassment continues, report this to your immediate supervisor. If the latter is the perpetrator, report this to his or her supervisor, or to the director of human resources,

3. If you believe that inadequate action is taken to resolve your complaint, go directly to a senior administrator or to the chief executive officer.

By management:

1. The manager to whom the complaint is made reports the complaint immediately to the director of human resources.

2. Investigations must be confidential. They usually include conferring with the parties and witnesses.

3. If the investigation reveals that the complaint is valid, prompt disciplinary action designed to stop the harassment and to prevent its recurrence will be taken.

Failure to take action may result in dismissal of the manager to whom the complaint was made.
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Author:Umiker, William O.
Publication:Medical Laboratory Observer
Date:Feb 1, 1988
Words:1768
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