I have tried to keep things pretty
high minded here, but I have to let off a little steam.
I probably spent half of last
year reading ill-conceived policies and procedures. Reading policies is part of
my job and I always try to take a fresh look at any policies I am asked to read.
Now healthcare organizations often have no idea what policies they have. I
guess this tells you how important the policies are to the day-to-day
activities of the organization. I read one policy that was nearly 100 pages
long, obviously drafted at great expense by outside counsel to the
organization. How truly DUMB do
you have to be to write 100 page policy!!!! And the organization paid for this exercise
that would have received a C- in law school. GRRR!!!!!
Why are we writing these
policies? Why doesn't it matter to the people who write them if anyone can
understand them. I think a lot of times
the person writing the policy imagines themselves waving the policy in front of
the jury or a prosecutor and saying, "You can clearly see that we don't
condone this!" In 40 years in this business in every type of situation you
can imagine, I am 100% certain that this situation has never arisen.
I hold the compliance officers to
blame too. Part of your job is get employees and others to act in accordance
with the policies and procedures. If no one, including you, can actually
discern what the policy says, how can you hold people accountable to these
I actually think it might be
better to run a company with no policies and procedures and hold people
accountable for their decisions. Would there be legal risks in doing this?
Sure. But it might be worth it to have a company in which people are
copyright 2013 Mark Pastin