Preparing to Draft Policies

Submitted by troy.murphy@up… on Wed, 12/06/2023 - 13:14

In this section you will learn to:

  • Review and evaluate existing policies and context to identify policy development needs.
  • Research, consult, and facilitate discussion to support policy initiatives.

Supplementary materials relevant to this section:

  • Reading D: Infection Control in Allied Health Practice
  • Reading E: Managing Psychosocial Hazards at Work – Extract 2
  • Reading F: Discrimination and Harassment Policy Template
A venn diagram depicting reviewing and drafting

In this section of the module, we will be looking at the first two stages of the policy development process: reviewing existing policies and drafting new ones. One of the reasons that we are pairing the review and drafting steps is that core aspects of review keep happening throughout the development process. As such, it is not so much a separate stage but the thing that you will start with and then continue through all the other steps when you develop a policy initiative.

Sub Topics
A group of medical professionals discussing

As we have already mentioned, many policy initiatives don’t start with the development of a whole new policy from scratch, but with the review and adaptation or addition to existing policy documents. Even where you are developing a new policy from scratch, that policy is unlikely to be a ‘standalone’ policy, because it will sit within and interact with the broader set of policies and procedures for your organisation. So, while you may be developing a policy initiative in an area that is not covered in any current policies, you still need to review the existing policy documents to make sure that you have an accurate grasp of the current polices. You must make sure that the initiative you are developing is consistent with the responsibilities and processes outlined in other policies or that you identify other aspects of policies already in place that will need to be updated and include updates to these within your policy development initiative.

When we review policies, for example, we often notice that there are details that are out of date. Imagine you are working in an allied health practice in Queensland. You will necessarily have policies already in place relating to issues of the detection and reporting of child abuse or other significant risks to children within your organisation. However, if these were developed prior to the recent legislation change – making failure to report a reasonable belief that child sexual abuse has occurred or is occurring a crime – the existing policies and procedures will not be consistent with current Queensland law.

Or consider the state/territory government changes in the requirements relating to the operation of healthcare practices during the covid19 pandemic – many organisations had to quickly update their policies and associated practices to meet the new requirements. Similarly, specific types of allied healthcare provision have their standards or registration requirements updated every few years, which means that pre-existing clinical policies need to be updated to reflect these context changes. Professional expectations also change over time, with some behaviours becoming unacceptable and new standards being set, so procedures regarding the behaviour and tasks of both administrative and clinical staff need to be reviewed and updated on a regular basis.

Policy development needs can also be identified through feedback and, particularly, complaints processes. Both internal (staff and managers) and external stakeholders experience the real-life effects of organisational policies, so reviewing feedback and complaints to identify areas for potential policy improvement is essential. For example, staff complaints about unsafe or inefficient processes and client complaints about staff or management practices that create difficulties accessing or benefitting from the service are never pleasant to hear, but they do us a major favour by clearly directing us to a policy review need.

Case Study

Monia is the manager of a medium-size allied health clinic in a regional centre in South Australia. Until the covid19 pandemic, the practice had offered the occasional telephone consultation in extreme circumstances but no other telehealth services, and they had struggled to adapt to the surge in demand for telehealth as restrictions on movement came into effect. While the adjustment process was highly stressful and created issues for both the organisation and its clients, over the years since the pandemic started Monia has received increasingly positive feedback about the benefits of more flexible service delivery methods from practitioners and their clients. This has led Monia to consider the inclusion of additional digital health technologies into the practice.

Her ultimately aim is to have multiple digital health technologies, which she thinks will provide a more streamlined process for clients (e.g., by having their claims processed digitally at time of payment), increase security (e.g., through establishing the use of a secure messaging system), improve accessibility (e.g., through further developing the range of telehealth services provided), and regularly gather valuable information about the population of the community (by using digital information-gathering tools and an up-graded clinical records system).

Monia is aware that the practice had only started using a clinical records system a few years before the pandemic and started accepting email referrals even later. Prior to this, the practitioners had kept paper files and referrals were via letter or fax. Monia knows that some staff and have struggled with this change and that many found the sudden need to adapt their practice to include telehealth early in the pandemic extremely stressful. She is concerned that some staff do not have the knowledge or skills yet to adapt to the changes she would like to make and, more worrying, that some will resist attempts to change the practice further. She has got the sense from some staff that they believe the move to adopt digital health technologies “has gone far enough”. While Monia is sure this transition needs to happen for the practice to remain viable and that it is an important part of making their service as effective and accessible as possible, she knows that not all her stakeholders are likely to agree.

Self-Reflection

Consider Monia’s aims, the values she is seeking to enact, and the organisational context she faces. What challenges do you think she is likely to face as she starts developing new policy initiatives? What information and supports will help her gain the acceptance of her staff for the changes she will make? What would you do in Monia’s position?

Reviewing and evaluating existing policies

Two people using a laptop while holding paper documents

So, what are we looking for when we review and evaluate current policies and procedures?

A venn diagram depicting reviewing and drafting
  • Areas of professional or organisational responsibility that should be covered in policy but are not.
  • Guidance that is out of date.
  • Instructions that are inconsistent with legal or professional responsibilities or general good practice.
  • Guidance that does not reflect practices as they are currently being performed. (Note, however, that this may indicate I need to change practice rather than policy or both practice and policy.)
  • Specific procedures that are not sufficiently clear to guide staff in meeting their responsibilities.
  • Policy gaps or limitations relating to areas of change social expectation. One example of such an area is the increasing recognition that culturally diverse people – including people from marginalised ethnic groups, people with a range of care needs or responsibilities, people with varied family structures, and LGBTQIA+ people – need and deserve inclusive, welcoming, and flexible service provision. Many service providers have policies and procedures in place that, while well-meaning, do not facilitate inclusive and adaptable practice to meet the range of needs present in our community. It has taken many years – many decades, in fact – of social advocacy for this issue to be taken seriously across the broad range of services and updating policies and practices to be more welcoming, inclusive, and responsive is a current trend and policy development. (You might like to keep this in mind, given that current trends in policy development is a key piece of knowledge evidence for this unit.)
Self-Reflection

We mention several trends in policy development in the first section of your Study Guide and have mentioned another one here. Take some time now to look into ideas for policy development (many are discussed online) and see if you can identify further trends that you might need to take into account as you develop policy initiatives.

Self-assessment processes

hands and writing on document with pen

There are many self-assessment tools available for organisations and practitioners to use that can help identify areas in which further policy initiatives or training are required. Many of these are also freely available online and you will be introduced to several of them across the course of this unit.

Let’s look at one, from the Australian Allied Health Leadership Forum’s (2020) Infection Prevention Control in Allied Health Practice. This is an example of a quality resource of the kind you might use in researching and developing policy initiatives, as we discuss shortly, aiming to, among other things, “provide an immediately actionable summary of the NHMRC Guidelines and other evidence as applicable for Allied Health clinicians and practice staff”, to forward “the NHMRC’s aim of promoting and facilitating the creation of safe healthcare environments through the implementation of evidence-based practices that minimise the risk of transmission of infectious agents”, and give “guidance to support the safe continuation of essential services during the current and any future pandemics” (p. 6). They provide information about what should be done, as well as a checklist of what is actually being done in the practice, and links to further resources. Let’s start by looking at the self-assessment checklist for hand hygiene. (We encourage you to download and use the full document, which you can find here.)

Text Yes No Action Required/Evidence
Does your practice have a hand hygiene policy and procedure in line with NHMRC Guidelines?      
Do you make hand hygiene products readily accessible to increase compliance?      
Are all staff trained in correct hand hygiene practices      
Are the hand hygiene facilities in your clinic adequate for the tasks being undertaken?      
Do you demonstrate hand hygiene in front of clients?      
Do you promote and facilitate hand hygiene among your clients?      
Do the hand hygiene products you’re using meet requirements; are they compatible with one another?      
Are all staff compliant with policies in place?      
Is there a designated hand-washing sink in client communal areas?      

(AAHLF, 2020, p. 15)

Clearly, if the answer to the first item is “no”, we have a policy development need. Note that this may mean there is no policy and associated set of procedures in place or that the existing policy does not comply with the current National Health and Medical Research Council (NHMRC) guidelines. In the first case, the action required would be the development of such a policy; if the latter, then a policy update is required; we would record the action required in the designated column. If the answer to any other questions are “no”, a new or updated policy may be needed but, since all of these are basic to hand hygiene and so should be included in the policy, then there will need to be work done on improving practices so that staff behaviour upholds the policy. You will find other processes that need to be detailed in procedures in Reading D.

Reading D

Work through the extract of the AAHLF infection control guidelines. Note the specific focus on guiding practice policy, the specific aspects of allied health practice that need to be considered, and how the AAHLF’s guidelines provide information that is tailored to allied health workplaces, making the resource more appropriate to guide your policy development than generic infection control resources.

Case Study

Monia is confident in her own use of technology and is keen for the practice and its clients to get the benefits that she believes integrating digital health technologies will bring. She works through the AHPA’s general and digital literacy self-assessments, which confirms her sense that she has the knowledge and capabilities required. However, she is concerned that the practice itself may not be ready for the ‘digital revolution’. For example, while she is familiar with general good practices relating to cybersecurity and privacy, she is aware that several staff members have had to be counselled to improve their practices in relation to their use of online portals, logging out of applications and their computers when they are not directly using them, and varying their passwords.

Monia considers three options: undertaking a full-scale digital inclusion plan in which she works on rolling out all the major health technologies she thinks will benefit the practice and its patients at once (i.e., instituting digital claims processing, secure messaging, increased telehealth service provision, use of My Health Record, and upgrading their clinical record-keeping system), breaking up the roll-out to focus on one health technology at a time, and giving up the plan altogether. She decides to go with a ‘middle way’ approach, starting with the roll-out of one initiative and building upon this with each successive initiative.

In deciding which to focus upon first, Monia considers the risks to clients and the organisation, as well as the current community and industry expectations for healthcare services. She decides that the first initiative will focus on the introduction of secure messaging and the phasing-out of fax, letter, and email communications wherever these communications involve client information. As she starts planning stakeholder engagement, Monia creates a brief presentation highlighting the risks to client information posed by maintaining insecure communication practices and the speed and convenience of transitioning to secure messaging. She then moves on to researching the secure messaging platforms in use among the other services in her region.

Watch

Once you have identified a policy development need, it is time to undertake the research and consultation that will help you develop your sense of how your policy initiative will look. (In fact, you have probably already done some research as you explored the need – reading updated government regulations or finding an appropriate self-assessment tool, for example.) It may be tempting to jump straight into drafting an initiative that you think will meet the development need you have identified, but without initial research and consultation it is much less likely that the initiative you develop will be effective. Policy development that is undertaken with insufficient research or consultation, for example, risks failing to address:

  • Key legal or professional concerns or responsibilities, such as updated legislation, codes of practice/ethics, or community expectations.
  • The needs of key stakeholders, such as workers and practice clients or vulnerable groups.
  • The barriers to and practicalities of implementation.
Watch

Research Methods and Tools

close up. scientists conduct research in a modern laboratory .

Many of the skills you are learning throughout this course will be incredibly useful to you in the research phase. Simple online, searching provided that you critically evaluate the resources you find (more on that below), will not only provide useful ideas for policy development, but also help you hone your policy initiatives so that they meet legal and professional requirements and address community expectations in relation to policy development and organisational practice. You may even find templates or example policies, such as the model work health and safety policies and procedures that state and territory governments around Australia produce that you can use as a starting point when you draft your own policies and procedures. (For your assessments in this unit, however, note that any policy or procedure that you draft needs to be entirely your own work!)

A diagram depicting research, critical evaluation and policy development

What kinds of resources are likely to be useful to you?

  • Legislation from the federal Australian government or your state/territory government, and occasionally regulations from your local council (these can relate to site use, disposal of waste, etc.)
  • Professional standards, whether for organisational administration and management or the provision of clinical services. Looking at the resources provided by professional associations can be very useful here, as can documents discussing the standards considered good practice by similar health or service organisations.
  • Information about community standards and expectations, including trends that relate to addressing previously un-addressed policy needs.
  • Key rights that your practice needs to uphold, such as human rights and the rights of people with disabilities PWDs), children, culturally and linguistically diverse (CALD) people, and so on.
  • Particular health or social conditions that are relevant to the way that your practice operates, such as the barriers to service access faced by people in your community who are unhoused or living in poverty, the effects of discrimination on local minority groups, and so on.
  • Any requirements associated with government funding or Medicare reimbursement for the services your practice provides.
  • Existing policy frameworks that are expected to be applied within allied health practices. For example frameworks relating to recordkeeping within health services, WHS, the rights of clients accessing health services, financial responsibilities reporting requirements associated with funding or registration of particular professionals, identifying and responding to risks, and so on. (There were several examples of such frameworks in Section 1.)

 

While most of us rely heaving on online research as our major research method these days, there are many other valuable methods and tools available to us. Books in our organisational libraries, that we may own or purchase, or from libraries can be invaluable. While most of us are familiar with public libraries, many professional and academic institutions also have libraries that may be accessible to us. University libraries, often tailored to particular areas of study at a given campus, can be easily overlooked and yet are an incredible source of information. For example, the library at a university campus where nutrition and dietetics is a major area of study will have many books and other resources dedicated to research and practice in this area. Many of these will be highly specialised and so less likely to be available from public libraries or general bookstores. Even better, many university libraries allow use by library patrons who are not students at those universities, through other membership pathways. So, you might like to check out your local universities and see what they offer to the public and whether you can become a member. (One major benefit of university libraries is that they are staffed with professionals whose job it is to help library patrons source particular types of information that might otherwise be difficult to identify.)

Critically Evaluating Sources and Resources

A person focused on reading documents

We have already mentioned online searching as a great starting point for research provided that it is combined with critical evaluation, and the same goes for resources found using other methods and tools. (Critical evaluation is so often mentioned in relation to online research because, when we use online search methods, we are highly likely to find many resources that are out of date or simply inaccurate.) If we were to use inappropriate resources in the development of our policy initiatives, our policies could be problematic in many ways and, in the worse cases, could lead to direct harm to stakeholders or serious legal troubles for staff, managers, or the organisation as a whole. So, we need to critically evaluate the resources we are considering using and then only use those that we can reasonably determine to be appropriate to influence our policy development.

When engage in critical evaluation, we are considering the nature of the resource, its quality, and it’s likely relevance to our policy development need, so we answer questions like

  • What is the resource? Is it a publication aimed at guiding professional and operational behaviour or processes, sharing important information about safe and evidence-based practices, or providing updates about legislation changes? If so, it may be appropriate to inform organisational policies and so we continue with the critical evaluation process. However, the vast majority of resources are not appropriate, so there is no need to go any further with critical evaluation – we need to put the resource aside and start evaluating another one.
  • Is it relevant? Once we know the resource is of a suitable type, we need to consider whether it is relevant to our policy area of interest. Naturally, the vast majority of resources will be irrelevant to any particular policy initiative or policy development need regardless of their quality, so we need to limit the resources that we use to guide our policy development to those that are actually relevant to the policy development need in question. We also need to consider the broader context in which we are developing a policy initiative. Location may be critical – an excellent Victorian resource, one that would be entirely relevant for addressing policy development for a Victorian practice, may misdirect you if it relates to specific Victorian legislation or requirements if your practice is in the Northern Territory (NT), were different legal and other requirements may apply. While you may use the resource for developing general knowledge and ideas for good policy, you will also need to find a similar resource that specifically complies with the NT’s requirements.
    Note, however, that resources that cannot be relied upon to inform the policy specifically may be useful in its implementation. You may find information that has many good ideas for work behaviour, workplace structures, types of meetings and reporting, and other things that your do not need to be codified in policy but which you practice could usefully experiment with or which could help staff or other stakeholders understand the policy initiative, for example.
  • Who produced this resource? Is this a credible author or publisher? Is this author or publisher likely to know what they’re talking about? For example, if the author or publisher is the same body that is responsible for regulating a particular area of practice, such as the Safe Work and Work Safe authorities in each state and territory, it is likely to be highly credible, while a blog by someone who says that they know about WHS needs a great deal more critical evaluation if we are tempted to use it to guide our policy development process! Other credible sources include:
    • Established research bodies, which are often associated either with governments, universities, or specialised organisations.
    • Recognised and accredited organisations that administer, audit, or advise on organisational matters.
    • Professional associations, such as the associations for occupational therapists, dieticians, physiotherapists, psychologists, and other allied health professionals. These are usually national or state/territory based and provide codes of ethics and practice, legislation and regulation updates, and other resources that are tailored to the allied health area.
  • Is this resource up-to-date? A resource may be very high-quality and produced by a completely credible source and yet be unreliable because it is simply out of date. Allied health regulation and funding, for example, has changed significantly over the past two decades, so there are many excellent sources that are no longer valid to guide policy development, simply because they are not current. It is particularly important, as you research, to make sure that information regarding legal responsibilities is up-to-date. (You can find all Australian and state/territory legislation online – each government has a repository of its laws.)
A diagram depicting engage in critical evaluation
Reading E

This reading – another extract from the Queensland Government’s guidance for managing psychosocial risks – provides an example of the kind of resource you might use in developing or updating your practice’s WHS policy. You will be working through the application of these guidelines to a health and community services organisation, which has many psychosocial hazards similar to those in allied health practice, especially practices that carry out home visits.

A group of people discussing policies

Consultation is, quite simply, the process of involving others and garnering their input into a process or project. In the policy development process, we need to consult all (or, where this is impossible, representatives of all) stakeholders and may benefit from consulting other people, too.

"Consultation"
  • the action or process of formally consulting or discussing.
  • a meeting with an expert or professional, such as a medical doctor, in order to seek advice.
Watch

Key Stakeholders in Organisational Policy

Stakeholders are simply the people or groups affected by something your organisation does or may do (Tarode & Shrivastava, 2022). In the context of policy development, our key stakeholders are those people affected by the policies and procedures or other guidance that we develop and implement within our organisation. Our staff members are almost always among the key stakeholders in any policy development initiative, but there are many other potential stakeholders:

  • Our client population, of course, is a key stakeholder in many initiatives, including those related to service delivery (clinical care, fees, client engagement, etc.).
  • For administrative, financial, communications, and governance related policies and, funding bodies and practices with whom we collaborate, among others, join our internal stakeholders.
  • The general community or a particular subsection of the community is often a key stakeholder. For example, there are many health problems that disproportionately affect marginalised groups and so representatives of these groups can be invaluable sources of input and collaboration when we develop policies that relate to client engagement and care, decide what services to offer and how (e.g., outreach as well as clinic-based), identify and address barriers to service access, and so on.

As you read about initiatives or examples of policies that are currently in place, get into the habit of identifying who the key stakeholders are. It will be particularly important to notice whether a person or group you consider to be a key stakeholder does not appear to have their rights or responsibilities adequately addressed within a given policy development process.

"Stakeholder"
  • A stakeholder is a person, group or organization with a vested interest, or stake, in the decision-making and activities of a business, organization or project. Stakeholders can be members of the organization they have a stake in, or they can have no official affiliation.

Consultation means gaining input from stakeholders or other sources of valuable information within the policy development process. The effectiveness of your consultation can determine the effectiveness of your policy initiative, because stakeholder consultation:

  • Helps you identify aspects of the policy development needs you are likely to miss by bringing in diverse perspectives.
  • Facilitates the identification and reduction of barriers to policy implementation.
  • Engages people who will be affected by the policy initiative in its development, enhancing the likelihood that it will be acceptable to those who need to implement and abide by it.

Internal Stakeholders – Staff and Managers

mixed race business people listening to educational lecture

Whenever you develop a new policy initiative, you should expect to consult, at minimum, practice staff and managers. In doing so, you can get the thoughts, ideas, and concerns of people directly responsible for implementing policies. This is often essential to developing a workable policy update.

For example, you may be developing a procedure that will require administrative staff to complete records in a way they are not familiar with. Its only by consulting with all administration staff that you are likely to identify challenges or problems in implementing your initiative, because it is these staff who are most familiar with the way that administration is undertaken; the constraints on the administrative processes that are currently in place (e.g., hardware currently used, internet connectivity and speed); and the capacities, skills, and knowledge of administrate of workers that may enable, or create a barrier to, policy implementation. As a result of consulting with the administration workers, you will be in a better position to develop a procedure that is practical and efficient, as well as being able to identify in advance (and therefore develop ways of overcoming) barriers to implementation. If the procedure requires that a particular software be used, for example, you must know whether staff are able to use that software or whether training will be required before the procedure can be implemented, if you are to be successful in making this update. Such consultation can also help to identify alternatives to the option you are currently considering. A staff member with experience using that program at a previous workplace is very well-placed to provide feedback about its utility and usability, whether it is likely to fit in with other software programs and administrative procedures in place, and so on. They may even know from experience that there is an alternative product that is more user-friendly or will integrate more easily with the other records management systems in use at your practice.

External Stakeholders – Practice Clients

Your practice clients are another fabulous source of insight (and one that is underused when policy initiatives are developed). Policies relating to interactions with clients and the provision of clinical services, for example, can only benefit from getting the ideas and feedback of the clients whom those policies are in place to serve.

One example of a structured set-up for getting the input of such stakeholders is taken from a youth focused allied-health and medical service in Brisbane, Queensland. They established a youth reference group that meet regularly to discuss the practice operations and approaches to the issues of its clientele, and among their responsibilities they reviewed and provided feedback on proposed changes to organisational policy, procedure, and practice. This proved invaluable. The proposed changes were, of course, developed by the allied health professionals and managers within the organisation and, while very well-informed and well-intentioned, this meant that there were aspects of some policies (or their enactment) that were problematic for the youth clients of the organisation. The reference group, being made up of members of the broader group of practice clients, was able to give feedback that helped the organisation develop ways of working that better met the needs of their whole client group.

Community Engagement

Community consultation is regularly undertaken by governments and some large organisations as they develop particular policies or projects, but it can also be useful for smaller organisations, such as allied health and community services. Many services have, for example, set up programs only to find that they service delivery is not meeting the needs potential clients. By pro-actively working with these groups in the development of initiatives, organisations are able to develop a better sense of what programs are needed and how barriers to access can be managed.

Perhaps the best examples of community engagement come from Aboriginal community controlled health organisations (ACCHOs) and Indigenous Allied Health Australia (IAHA), which have detailed processes for community engagement in the formation and development of their policies and practices. Many community services also develop relationships with local Indigenous Elders, who provide input into service planning and delivery; these are models that allied health practices can also benefit from. Similarly, if your practice is looking to engage members of CALD groups in your area, for example, it would be a good idea to speak with representatives of these groups or the local multicultural organisation. Other groups that may be of particular interest to allied health practices include people with disabilities and other chronic health conditions; again, speaking with representatives and organisations who can potentially link you with community members who could provide input is a good idea.

How you approach members of community groups for consultation is a critical matter. These groups are not obliged to help or consult businesses or organisations, and they often work very hard with limited resources to forward the wellbeing of the people they represent, so approaching with respect and courtesy is essential. It can be useful to contact professional or community organisations directly to enquire about their capacity to consult with you or to facilitate an introduction to community members who may consult with you. You need to clearly communicate your purposes in seeking consultation and any benefits that can be provided to those who provide input (e.g., payment for their time). Where there are established protocols for making contact, it is important to follow these. For example, there may be an Elder or community leader you need to establish a working relationship with before you are introduced to or have permission to approach other community members.

Where you have established connections with community representatives or have a consultation group who regularly provide input into your organisation’s policies and practices, these can be long-term relationships with protocols for regular consultation. A short-term consultation relationship may involve one or more consultation methods that the consultant or group of consultants consider appropriate. It is important to involve the consultant(s) in developing the format of the consultation, exploring their preferences for options such as:

  • An interview with the consultant.
  • A series of meetings.
  • A series of email or letter exchanges with ideas and draft documents presented to the consultant for review and feedback.
  • The completion of feedback surveys from a number of relevant community members.

Established practices within a particular group may also be applied where appropriate, such as a group of Aboriginal consultants involving the person seeking consultation in a yarning circle or the outcomes from a yarning circle. However, because these are cultural practices, it is only appropriate for people who do not belong to the group to be involved where this is at the explicit invitation of the group. It has been very common for non-Indigenous healthcare providers to inappropriately involve themselves in or try to take over culturally specific forms of communication and practice, so practice managers who are not familiar with and connected to the traditional owners of the land on which they work need to be sensitive in the ways they attempt to engage Indigenous consultants.

Professional Consultation

Other professionals are a common source of consultation and developing policy initiatives, especially when it comes to major policy changes, is formed by other professionals. Lawyers, either general lawyers (who are often in established relationships with practices) or lawyers focused on specific areas of law may be required to provide guidance or review proposed policy changes to make sure that these comply with legal responsibilities. For example, auditors can be brought in to review practices and suggest updates to policy in order to meet quality standards frameworks; accountants can review financial policies to identify weaknesses; and so on. Similarly, professional organisations that work to increase culturally responsive practice or provide guidance on working effectively with the cultural or ethnic groups they represent can be found in many areas and can provide valuable guidance.

Consultation and Stakeholder Engagement

Close-up of two employees and lawyer shaking hands and smiling while sitting at the desk

Consultation often takes place in formal meetings or other conversations, but there are other methods to consider. Whether it is the use of communications technology to engage people who would otherwise be unable to be involved or using surveys and other methods for written submissions, employing a wide range of methods including, but not limited to, discussions is important. Where discussions are undertaken, it is also essential to consider limitations on how honest or critical those being asked for input may be and how the environment may be set up to make honest feedback more likely. Asking staff to provide input that may be viewed as critical of management, for example, is unlikely to be as effective in a meeting where those managers are present than in a private discussion with an individual staff member where they are assured that any feedback passed on to management will be de-identified.

Now let’s consider some different consultation strategies in current use.

  • Policy development committees or sub-committees are groups of staff and managers within organisations that are specifically set up to review and provide feedback on the drafting of policy initiatives (or to develop policy initiatives themselves). There may also be committees or subcommittees that don’t specifically focus on policy but on particular areas of clinical or operational practice; these can be consulted when policy initiatives are focused upon the same area. For example, if you have a large enough practice to have a committee focused on a particular aspect of clinical work, it would be a good idea to meet with them to discuss policy initiatives that relate to clinical service delivery.
  • Letters or emails can be sent to staff or clients with specific questions or aspects of the policy initiative described and followed by a request for feedback.
  • Staff and client surveys can be circulated and promoted within the practice or online. When using surveys, it is a good idea to provide multiple methods of completion, such as having an easy-to-use online platform as well as a submissions box in the practice for paper versions.
  • Meeting with affected groups is another of those invaluable often overlooked methods of consultation. This can happen as part of regular team or staff meetings for internal stakeholders, so this is more common, but it is just as important for external stakeholders. For example, you might meet with the Indigenous elders of your community, members of a marginalised group, or a group of people with a specific need (say, occupational therapy for their primary school-age children) that your practice is hoping to meet. If you manage the consultation process well, this is likely to provide insights and help you identify potential issues with your policy proposal that you have not been able to identify yourself.

How do you respond to input? This will be a huge factor in the effectiveness of your consultation. First and foremost, you need to show your respect and appreciation for the time and effort that the people you are consulting with have put in. (This applies whether or not you agree with the perspectives they have shared!) Making your requests and responses to consultation respectful and encouraging goes a long way towards what is called stakeholder engagement in consultation processes (this is another of those health policy trends we have been talking about).

The concept of stakeholder engagement has been of increasing interest among researchers, funders and policy makers, as successful system transformation and improved financial performance have been demonstrated when healthcare professionals are engaged. Despite the growing interest in and perceived importance of stakeholder engagement, there is currently no single widely accepted definition of engagement or agreed on engagement process.

Norris et al sought to conceptualise stakeholder engagement in the context of healthcare improvement initiatives. Specifically, the researchers interviewed a variety of stakeholders and arrived at a conceptual model of engagement highlighting three major components: individual participation, connecting around a purpose and meaningful interactions and dialogue. Within each of these components, there are strategies that further inform and describe stakeholder engagement.

(Duncan et al., 2023, p. 2)

A diagram depicting...

Some strategies for stakeholder engagement include things we have already talked about, like providing a variety of methods for consultation and adapting these to meet group or individual needs. Stakeholders also tend to appreciate being informed of the outcomes of their consultation and are more likely to engage in future consultation if they do, so make sure that you get the contact information for everyone you consult with (provided they are willing to give it) and let them know what the outcomes of the consultation are. If you are consulting with the group that meets regularly, you might attend a follow-up meeting to tell them about these outcomes; if you sent out a survey by email, you might conclude the process with an email telling everyone who made a submission what has happened since the feedback was received. For example, if you adapted a policy initiative so that an issue relevant to those you consulted is now addressed, tell them; similarly, if you have taken an idea that they presented and worked that into the policy initiative or your implementation plan, tell them and thank them for their valuable input.

Reading F

This reading is the suggested workplace discrimination and harassment policy suggested by the Australian Human Rights Commissions (AHRC) and guiding information. Note the definitions and details provided, such as links to legislation, to help staff gain a thorough understanding of the issues the policy is designed to address.

Good Practice in Consultation

Of course, simply asking people for their thoughts isn’t always going to garner the responses that we need if we are to develop effective policy initiatives. As with all aspects of communication it is not just what we do but how we do it that is critical. For example, plenty of organisations claim to want honest feedback from staff about how they can improve. But if the feedback staff give is regularly ignored or staff concerns are minimised, this behaviour will communicate much more strongly to staff that this feedback is not actually wanted regardless of how often managers say they want it. We increase the likelihood that we will get useful and honest responses from those we consult with by providing flexibility in how input can be given; phrasing our requests for and responses to input positively and respectfully; and, where appropriate allowing for anonymous input. Crucially, we encourage trust and continued engagement when we show that we have taken input seriously when it drives changes in the policy initiatives we are developing.

As already mentioned with surveys, it is good practice to provide multiple methods by which feedback can be provided. For example, staff are regularly on site or in virtual communication, so there are plenty of opportunities for detailed consultation, through face-to-face or through online meetings, emails, chat functions on communications platforms, and staff surveys. Because you will have a sense of staff capacity to engage with detailed written or verbal information, you can also tailor your consultation methods in a way that is appropriate to these professional people. You may know that your staff prefer emails to lengthy discussions in meetings and so email your plan to everyone and ask for responses; but if you know that your staff feel overloaded by emails, you might choose to set up a quick poll on your internal communication platform instead. Similarly, where staff members have particular communication preferences or needs these are more likely to be known to you than are the communication preferences or needs of many other stakeholders, and so are you a better position to meet them than when you are consulting with community groups, for example.

Practice clients, however, are much less regularly on site and will have a wide range of educational and professional backgrounds, while general community consultation will ideally involve people who have never set foot in your clinic. This needs to be taken into account as you develop consultation mechanisms. You are also much less likely to know what particular communication preferences or needs are among these people and, as such, you need to develop consultation mechanisms that are inviting and practical for a diverse range of potential consultants.

If communication is happening in writing, your writing needs to be very clear and straightforward, with short, simple sentences and paragraphs. If you are consulting with people for whom English is not a first language, you may need to use translation services or interpreters. Similarly, where the people who are consulting with need to use assistive and augmentative technologies (ATT) to communicate, you need to make sure that the communication mechanisms you set up allow for this. This may mean setting aside time to meet individually and for longer with some people or groups than it does for others; that you consult with some people in a group meeting, others in individual meetings, and still others by online or by encouraging them to email or post their input, for example.

It can be a good idea to develop consultation ideas with the input of an organisation or representative very familiar with the range of needs you are seeking to meet. For example, if you are developing a policy initiative with the intention that your organisational information and processes will be more accessible for people with intellectual disabilities (ID), working with an organisation that specifically works with people who have ID will is likely to make your consultation efforts much more effective.

Supporting Documentation

You may need to develop and provide documentation to support your consultation efforts. If you want feedback on a current policy, for example, you will need to provide a copy of the policy to those you are seeking feedback from and give them plenty of time to read and reflect on it before asking for their feedback. Other forms of documentation it may be helpful to provide include:

  • An overview of the policy development process with information about how their input will help shape the outcome.
  • Research (or a summary of research findings) into the issue you are attempting to address through your initiative.
  • Information about updated legal, professional, or community conditions that you are trying to address through your policy initiative.
  • A report on the ways in which existing policies are operating and how your policy initiative will seek to make improvements.

The structure of the documents you provide needs to be carefully developed in order to be appropriate to the specific people you are seeking to consult. A full research report may be appropriate for clinical staff who have the educational background to make sense of it, for example, while a simply worded summary would be more appropriate for most other groups you may consult. Similarly, a formal report may be appropriate to provide to internal stakeholders but be off-putting to a community group.

Note, too, that there may be specific sources of research and consultation that your organisation requires in the policy development process. If this is the case, these should be outlined in existing organisational policies, and you need to make sure you follow them. Ideally, these should be based on good practice principles and so will provide useful guidance.

Responding to conflicts and other challenges

As you consult with different individuals and groups, you are likely to hear different positions. At times, outright conflict may develop between stakeholders over what the nature of the policy issue is or what appropriate solutions may be. You will be responsible for addressing conflicts and other challenges in stakeholder engagement positively. This is sometimes called responsible leadership and it is increasingly recognised as essential given the serious social and environmental problems we face, and the range of stakeholders who are actually affected by the decisions that organisations made (which helps to address the bias that many leaders have toward some stakeholders and against others; Pless et al., 2021).

To respond to challenges effectively, you will need to:

  • Model respectful communication to all stakeholders.
  • Communicate honestly and genuinely with all stakeholders, inviting them to share their opinions and helping clarify their concerns. This includes showing respect for each stakeholder and taking their concerns seriously, even if you disagree with the positions some stakeholders are taking.
  • Moderate communication between stakeholders, such as through the use of meeting facilitation skills.
  • Critically evaluate the different perspectives that are held or ideas shared, and consider options for compromise or negotiation.
  • Make changes to policy initiatives where these are appropriate to the policy issue and consistent with the practice’s legal and ethical responsibilities.
Case Study
A female medical researcher talking to a colleague

Monia starts her research with by searching for the most recent resources she can find relating to the use of secure messaging by health services. Among other documents, she finds that the AHPA’s Digital Health Toolkit for Allied Health Providers is up-to-date and practical in focus, and she saves this to share with staff as the initiative progresses.

Monia contacts the managers of other health practices in her region and several allied health practices in Adelaide to get information about the secure messaging services they use. She finds that there are a variety in use, each with particular benefits and drawbacks, and makes a provisional decision to purchase the one most commonly used by the local GP clinics and public health provider, to enhance compatibility with these services. As she seeks the input of these services, Monia also asks for their feedback on their experience of referring to or collaborating with her clinic, making note of the comments of several local GPs that there are difficulties and avoidable delays when compared with their communications with services that have already implemented secure messaging. Monia also discusses her initial thoughts on the initiative with the practice’s solicitor to make sure that her understanding of the risks and benefits of the current communication system and use of a secure messaging system is accurate.

Over the following weeks, Monia holds meetings with clinical and administrative staff to outline the need to progressively integrate health technologies into the practice system and that this will start with the introduction of secure messaging. They discuss the need to change the communication system and Monia gathers ideas from staff about how the roll-out of a secure messaging system could work. She encourages staff to either approach or email her with any concerns or questions they have, openly acknowledging that the transition will have challenges and assuring all staff that they will training within work hours.

to help familiarise them with the new system. While many of the staff members are keen to have the new system in use, Monia is aware that there are some hesitant staff who do not want to speak up about their concerns in front of her peers and who may not want Monia to know they are concerned, so she puts a box in the office hallway where notes with concerns or questions can be dropped anonymously. She starts a practice of sending a brief email each week outlining where the initiative is up to, notifying staff of further consultation or information sessions, and addressing any concerns or questions she has received. While she finds that some staff members respond with appreciation to her emails, she also realises that others are not reading them – for example, she receives the same questions repeatedly despite their being answered in earlier emails. She also realises that few staff follow the links she shares to resources discussing the benefits of secure messaging or its applications.

To gather patient feedback, Monia develops a brief survey that patients can complete while in the waiting room and drop in a submissions box. This survey gathers information about patient satisfaction with referral processes and situations in which Monia’s staff are collaborating with other service providers, as well as patients’ view of the security of various communications methods. She discovers that, while older patients are often satisfied with the security of the current methods, young and middle-aged patients are more concerned about security and positive about the implementation of secure messaging. In addition, several survey responses indicate that there have been challenges in getting inter-service communication happening effectively, especially for patients leaving hospital with rehabilitation needs or referred by their GPs for assistance with making healthy lifestyle changes. The patients’ views of the prospect of instituting a more secure and speedier communication system are overwhelmingly positive.

This section covered how to identify policy development needs as well as the necessary methods of researching, consulting, and facilitating discussions and consultation efforts to support policy initiatives.

Module Linking
Main Topic Image
A person writing policies
Is Study Guide?
Off
Is Assessment Consultation?
Off