Whether you own or work in a business, compliance is key. Compliance is making sure that you meet all of the requirements relevant to your business - this could be legislation, regulations, best practice, or quality standards. Every business in Australia has compliance requirements, so knowing what they are, and having a system in place to manage these requirements, really puts you in front.
Many people think of quality management as a burden or an "extra", but compliance requirements aren't going away (especially in the human services sector). Remember what I said about embracing compliance? Setting up a quality management system is the easiest way to manage your compliance. Managing your quality management system - that is, actively working in and on it - will make compliance a breeze.
The best way to manage your QMS is to be proactive! Schedule time each week in your calendar for quality management tasks. Schedule different tasks for each week of the months. For example:
Week 1: Review policies and procedures
Week 2: Review complaints and incidents
Week 3: Review governance requirements
Week 4: Review improvement actions
Start with one hour a week - that is only 2.5% of your working week! That is surely worth the investment for the peace of mind that you are meeting your compliance requirements.
Speak to me about how to manage your QMS, and how to make compliance a breeze: firstname.lastname@example.org
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There has been a lot happening in the disability and aged care sectors, but of course one of the biggest things impacting organisations has been the development and release of the new NDIS Practice Standards (replacing all state-based quality standards like the Human Services Standards and Human Services Quality Standards) and the Aged Care Quality Standards (which brought together the Aged Care Accreditation Standards and the Home Care Standards).
These two new standards are not vastly different from what we had before. But they do require some effort to implement in your organisation, so that you can be truly ready for the next time an external auditor comes to visit. Here are three things that you can do:
A consultant like myself can help you with steps 1 and 2 above, but step 3 will always be up to you, and it is a crucial step. Remember to keep records of your transition – include what you’re doing in your Improvement Plan, ensure you have a system for keeping records of any new process (e.g. signing new Codes of Conduct, adding new training to your Training Register).
If you do need help with steps 1 and 2, give me a call! I can work across all states and territories and can currently offer a quick turnaround for your project.
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If you had a bit of a holiday break over Christmas and New Year, welcome back to work - you're probably full steam ahead, because human services never really stops, so here are some quick tips to get your year started right, quality management-wise.
1. Set your internal audit schedule - you might call this process or document reviews. However you do it, for your organisation, make sure you book it in now. Internally auditing or reviewing your organisation SHOULD NOT be ad hoc. Prioritise, based on risk, plan, and book in the relevant stakeholders.
2. Write or review your strategic or operational plans - or at least book in a review for later in the year. Now is a great time to revisit your business priorities. You can do this on a larger scale with your staff and clients, or it might just be a quick review to set some goals for the next few weeks.
3. Book in some time to get client feedback - again, this is about knowing where you are, and setting some goals for 2018. This process does not have to be formal (think paper or online surveys), although it can be. But if you're a small organisation, you might just call up your clients and ask them how last year went with regard to their services, and if they have any suggestions for this year. Record your findings in your Improvement Plan!
4. Schedule in staff training - training staff in human services should also not be ad hoc. You need to look at your client group and the type of services you provide, and tailor staff training accordingly. Schedule it in, book in external trainers if you need to, and evaluate the training afterwards. This is also a good time to chat to staff about their goals for this year, and review last year's performance and goal achievement. Or, book that chat in for later this year now.
I hope you have a great start to 2018. If you're a new organisation, you might be starting to think about your first external audit this year! I can help by checking number 1 from this list off for you, and conducting an audit on your business - see my Pricing page, or contact me.
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It's been a huge year for me at The Quality Nerd, as I followed my dreams and made the business my full-time job. I'm infinitely grateful for my clients that made the leap possible, and I'm very much looking forward to continuing to work with you in 2018.
For 2018, I hope for the following:
1. To support new businesses with their first external audits - if you registered as an NDIS or Home Care Provider in 2017, you will probably have your first audit in 2018. An audit can be scary if you haven't been through one before, but a great way to calm your nerves is to be prepared by having an internal audit. I have over 10 years experience in internal auditing, and I can help you with a desktop audit, or come to your site / office to thoroughly review your records.
2. Continue writing - I love to write, especially policies, procedures, tender applications, and self-assessments! I'm certainly not called a nerd for nothing. In 2018 I would like to support businesses by helping them write documents for their processes that are meaningful, useful, and compliant to requirements.
3. Travel with purpose - this links in with goal #2, in that I'd like to do more pro-bono work in 2018. That's right, if you're a small human services or animal welfare organisation, and you need some support with quality, processes, or management, I offer 1-2 days onsite of my time to help you with your business issues. All I ask is for permission to write a de-identified case study about you.
If you'd like to start 2018 with a business bang, please contact me any time: email@example.com
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Now that you know when to call a finding a non-conformity, the next step is making sure that the non-conformity (or issue or observation) has been closed out. This will usually fall to the internal auditor to do, as being someone who can provide an independent assessment of the effectiveness of the action taken.
I believe best practice is not just to note if an action has been taken, but to also assess if that action has been effective, thus minimising the risk of future non-conformances. This might involve some time spent on a follow-up audit or desktop review. To me it's time well spent - I would rather continue to follow up an issue than write about the same issue occurring in report after report.
The first step in the process is to give people a clear idea of what the issue is and why it's an issue. A statement like the following makes things really clear: "The service is not currently reviewing client support plans within the timeframes set out in the Client Review procedure, i.e. every six months, as monitoring of review timeframes has not taken place regularly."
At this stage you might like to give a direction for action - at the very least, you should give a timeframe for completion, such as: "The service should ensure that all clients that are overdue for review have one completed in the next four weeks."
You could extend this to ensure minimisation of ongoing non-conformity: "The service should ensure that the client review report is monitored weekly and reminders set in relevant staff calendars to ensure that reviews are conducted on time."
You then need to let the service know how their non-conformity will be closed out: "Manager to provide the client review report to the internal auditor by (date)."
Now the most important part is actually following up - mark it in your calendar and keep your word. Sticking to your own rules is a fundamental part of being an internal auditor.
If someone has not been able to close out a non-conformity, set a new follow up time and keep going back until the issue is resolved; also ensure that you follow your escalation processes, particularly if you feel the issue is high risk.
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No matter what activity your organisation is undertaking in regards to quality standards – whether it be internal audit, self-assessment, reviews – at some point someone is going to have to make a call as to whether a finding is a non-conformance to a standard / indicator / expected outcome. When you’re
starting out in internal audit, this can be a difficult point – if you make a conformity call and then an external auditor says it’s a non-conformity, it can have a big impact on your credibility. Same for vice-versa.
If you’ve had auditor training you will know that part of the audit process is that we look at information objectively, so if another auditor came in and looked at the same information, they would come to the same conclusion. That is a good theory, but in my experience it doesn’t always mean that you and another auditor
are going to agree – we are human, and standards are not always written in black and white. You just have to look at the large amount of evidence guides out there attached to standards – they’re in place to try and reduce the degree of interpretation, but sometimes they can complicate things further.
As an internal auditor, your job is to assess your organisation’s information against quality standards to a highly critical degree – you are there to lower risk. But if you’re not sure when an issue is a non-conformity, you’ve come to the right place! Let’s take an example and walk through it.
Human Services Quality Framework – Standard 3, Indicator 3 – The organisation has processes to ensure that services delivered to the individual/s are monitored, reviewed and reassessed in a timely manner.
In every indicator there are key words that will help you determine what conformity is really based on, and what evidence has to be measured against. The key words in this indicator are ‘monitored, reviewed
and reassessed’. Notice that it doesn’t say ‘or’—what this indicator is telling you is that the organisation needs to have processes in place for all three of those things before you can be considered to achieve conformity.
Having processes in place doesn’t necessarily mean that you have a documented procedure—what it does mean is that the organisation must have determined what its requirements are, that all staff involved know
these requirements, and that it’s actually being done. So, a documented process does help, but it’s not an indicator of conformity in this case—that the process actually happens is the indicator.
So, in this case, I would consider a non-conformity to be:
1. Not having defined a process to monitor, review and reassess services within a reasonable timeframe—it might be occurring, but it’s at the discretion of staff.
2. Staff not being aware of what the defined process is, and/or developing their own processes.
3. There is no process in place for either monitoring, review or reassessment, it is not occurring, and this is evidenced by reviewing client records and/or through client interviews.
4. There is a process in place for monitoring, review or reassessment, however it is not occurring as defined, for example, the process is for reassessment to occur every six months, but systemically this is not happening until 12-18 months.
Breaking down indicators in this way helps in two major ways. Firstly, it gives you a framework by which to audit—you’ll be looking at the right things and asking the right questions. Secondly, you will have a logical and understandable way to explain why you have made a non-conformity call.
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When human services organisations starting getting into quality, and governments started thinking about it too, one of the standards that some organisations used to build their systems was the ISO 9001.
In many ways, it makes sense—the ISO 9001 is a good “umbrella” standard. Meaning, it can cover your whole organisation, and, being under a management systems framework, can really help organisations with where to start in setting their quality systems up.
And….then you get to Clause 7. And if you’ve done it or are at this stage, then you might recognise the feelings of despair that many people in human services have experienced when encountering this clause. They might say it really means ‘product/service realisation’, but nothing else about the clause made it any
easier for service organisations to understand how they could conform, must less how it related to us in the first place.
When I first started really getting to know this standard, I found this little gem online: The EyeSore 9001 – a brilliant parody of the standard, but also very, very useful. This resource turned my mind around and I finally started to understand what clause 7 was all about. I’m not going to try and recreate that resource here – I do recommend you read it though – but this is just going to be a little tutorial in clause 7.
Disclaimer – this is a very basic overview. If you would like additional support please feel free to contact me. Here we go:
There are tools available online to help you do a self-assessment to the ISO 9001:2008 standard (like this one), but these are normally just written as per the standard. I hope that the above can help you break things down a little further.
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As a Quality Manager / Internal Auditor, this would have been the number one question I was asked—from all levels of organisations, for both internal and external audits. Below are my three top tips for preparing for
Sidebar: In fact the correct response to any question relating to preparing for an audit is to say “don’t prepare”. The reason for saying “don’t” is that talking about preparing for an audit has negative connotations—that you’re not really doing things right every day. But saying “don’t” can leave people confused and nervous. And, there are definitely things that you can do to be prepared for an audit, so that the time will run smoothly. These tips would apply for internal and external audits, and across most management system or human service standards.
1. Your auditor will provide you with an audit plan, and this document shouldn’t be ignored—it will define scope and criteria, and will probably have a timetable of the day. Look at what the auditor will be assessing—training, client admission processes, complaints process—and have those records ready, such as your training attendance records, referral register or complaints register. Usually, though, auditors will pre-select or select their own client files to view. Having records out and ready saves time on the day.
2. The auditor will need to interview staff (they can interview clients too, but this is always pre-arranged), especially at supervisory level, so it is best to ensure that the right staff are available on the day. You can ask the auditor to set interview times in advance. If staff are nervous about being interviewed, they can usually be interviewed in a group. Preparing staff by sharing the audit plan can also help, if they understand what they’ll be asked in advance.
3. Know your improvements! Standards within human services in Australia operate under a continual improvement framework. So the big thing that auditors will want to discuss is what improvements have been made, how they are identified, and how you have measured them. Have your improvement plan ready.
I do believe that the above are the only ways to prepare for an audit—to do anything else would be dressing up how you really do things. So Be Prepared, but Don’t Prepare.
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No matter the size and scope of your organisation, or your internal audit program, at some point you will have to interview staff and provide feedback (to both staff and management) about your findings.
Being able to pick up non-verbal and verbal cues from people is a vital part of being an internal auditor. From the moment you walk into a service or department, you should be able to "sense" how the audit will go. It's not just about the findings, it is how you deliver the message and how that message is received that counts. Reading non-verbal and verbal cues is also very useful when interviewing staff—many people are nervous about audits, and knowing when to change your interview technique can make a huge difference to the interview outcome.
Some of the basic cues I've picked up over the years include:
1. Eye contact and posture - if people are receptive and engaged, they will look at you and position their bodies to face you. If someone is turning their head away from you and or only looking down at their notebook, it is a sign that they are not interested.
2. Dressing up negative comments and jokes - if you walk into a department and the manager says to you "look out, better hide" or "oh no, weren't you just here?" and then laughs or says "just kidding", you need to ignore the laugh. In my experience, people that are genuinely accepting of the audit process don't feel the need to make comments like this.
3. Defensive comments - these are usually pretty obvious. It is natural for someone to take their work or the work of their staff personally; how you respond will determine your ongoing relationship with that person.
So what can you do if you notice these types of cues?
1. Maintain your professionalism - relax your face and keep a neutral expression (no brow furrowing or lip pursing), and do not respond with sarcasm or negativity of your own.
2. Change your line of questioning or feedback - switching the talk to something positive can relax the other person, particularly if they are nervous. See if you can move the topic onto something neutral or discuss a strength before steering the conversation back to what you were previously discussing.
3. If you really feel like you're losing your audience, sometimes the best thing to do is stop and ask if everything's okay. Invite their feedback on what you're saying—people do have the right to respond and it shows professional integrity on your part.
For further reading about body language, I recently found this comprehensive website, Business Balls (love the name too!).
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A friend of mine, on the day of her first third party audit, posted this picture to her Facebook:
It made me smile because I think this is a fairly common reaction to an audit, or to auditors—watch out, they’re coming!—and of course the ensuing flurry of paper shuffling and panic. But, in my experience, usually once it’s done people say ‘that wasn’t that bad actually’ (as was the case for my friend).
Auditors tend to get a bad rap—we’re seen as boring, pedantic and inflexible. Audits are things to be endured (apparently sometimes by potential auditors themselves! I spotted “Studying this lame subject. Ugh” on a Twitter feed recently!).
Does auditing deserve this? In the years I’ve been auditing I can confidently say ‘no’. Most auditors I’ve worked with are genuinely interested in supporting improvement in the organisations they work with. An auditor with a good attitude goes a long, long way.
I do think, as more and more human services organisations go through a third party audit process, that our reputation and their feelings around the experience will change. In the past year, I’ve definitely noticed that people are starting to take interest in the profession and can see the benefit that auditing and quality management can provide.
If you’re about to go through your first third party audit and are a little unsure about the process, one important thing I learned when I first started out was: your auditor is your business partner. Talk to them about your strengths and what improvements you’re working on. They (should) see themselves as your support service, so see them as that too. Then you won't have to "brace yourself" when an audit comes along - you might find yourself looking forward to it!
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The Quality Nerd loves all things Quality Management and Internal Audit...too much is never enough!