What she's thinking of is called PC365, and it's Gallagher Bassett’s (GB's) nurse-triage system (goal is to prevent unnecessary hospital visits that might be able to be handled alternatively). Please connect her with Martha Turpin, the GB Claims Account Coordinator for Catalyst, for her to get more information. Martha's email is martha_turpin@gbtpa.com (and don't sweat not having answers on this, we're not expected to know the claims management mechanics, just the data as it informs safety)
There isn't one available for the Catalyst members yet. It's one of the longer term offerings I hope we can knock out, (year two), but there's nothing canned and ready to go at this point. Jen's skills as an OT lends itself perfectly to the development of this, but it's not the first 4 columns, and our focus (pun intended!) has been squarely on finding and training people for those first 4 columns since we got the word we were getting Catalyst. I know it's not the answer you were hoping for, but it's the only one we have for now.
This one's a little tougher because I think she's indirectly asking if we can help with it. And, while we have the talent to do so, it's out of scope for the first year/three visit strategy. If you can, please let her know that it's not a Catalyst funded service at the member level for this year, however you've submitted it both for consideration as a webinar for the whole captive, and also as an action item for the second year. I'd also let her know that if she's looking for something more customized and timely, we can do that but her company would be direct billed for that service.
Perfectly understandable. I'd let her know that we will be positioned to offer that training to her people virtually, and when the time comes we'll have flyers developed that explain the login information (it's quite easy).
Please feel free to send him the raw data file that came with your ELA packet. Please also let him know that any inconsistencies he finds should be addressed with Gallagher Bassett directly, since we have no control of the integrity of the data or ability to make corrections to it. He can reach out to Martha Turpin, the GB Claims Account Coordinator for Catalyst, to discuss his claim’s data questions. Martha's email is martha_turpin@gbtpa.com
Many times the client we are reviewing the report with will question the data ("there's no way my lag time is that I we turn any accidents within 24-hours" or "name doesn't sound familiar to me, it must be someone else's claim and miscoded to my company" or "you're telling me this claim is still open but it's supposed to be closed"). These, and other, questions regarding the Enhanced Loss Analysis data is a pretty common occurrence but should be directed to claims management rather than their risk control consultant. The members often don't understand the difference between the two services and don't know who to reach out to with their questions. When this happens, we ask that the consultant send the Excel file after the Loss Review visit to the member to review for any inaccuracies they see. We also ask that the consultant direct the member to reach out to GB Claims (Martha Turpin at Martha_Turpin@gbtpa.com) for any potential correction. We do as much as we can to stay out of the way from trying to broker those conversations - it's out of our lane:)
His request for a week ahead for the data is a weird one, but we can make it happen. We just need to let the ELA team know that in this case, we'll need the data 10 days before the visit, because the client has asked for the data a week out. (We don't typically share the data that far ahead of time - I prefer to email it to them the day before - but that's just to avoid the likelihood that they do what I think this guy is going to do - a deep dive on the data ahead of time). FWIW though, I can't see this happening with anyone else in Catalyst. I've never (in 25 years) had anyone ask it of me, it's just a weird sitch.
Some companies send several people to the Board Meetings (CFO and an owner, Risk Manager and a CFO, etc), so it's possible that they may have several people who go to the Board meetings and participate - but each member only has one voting Board member.
That may not be the perfect answer for your safety contact depending on why he's asking, but for absolute clarity, they should reach to their broker for clarification. I'm answering based on my observation over the years from several captives. (and this would qualify as one of those questions that we're not required to know, but it's awesome to try to give them the answers that we can).
In that spot, you want to take yourself out of the line of fire as much as possible and tell them that you'll refer it up to Jen and I to follow-up, because the basic services provided through Catalyst - for this year - are the 3 visits. Anything above that would be a customized conversation, and likely one they'd have to consider funding themselves (which we can work with them on pricing for)
Great question! Thank you so much for your attention to detail and understanding that the ELA may be a bit "stale" on the date of the rescheduled visit. In a situation like this, I would suggest that you leave the ELA as it is but include this member's most recent Loss Runs from July 1st through October 21st (four days prior to your visit) in your conversation with the safety contact. I (Jen Huber) have access to these Loss Runs and will pull them for you a few days prior to your visit, highlighting any larger losses, to allow you time to review them. I have included the loss runs for this member from July 1st to today, as an example of what the report will look like when you receive it.
This is understandably a confusing section, so thank you for raising the question. And to be clear, it's inspiring us to make some language adjustment in the ELA to offer clarification for it. The members "should" know about the three visit structure. I put that in quotes because plenty of times they aren't paying attention to the emails that come in, nor the WebEx that we delivered to anyone who would show up on May 5th where the service strategy was laid out.
The section there on leadership training is meant to inspire topics for them to consider in-house for their leaders to go through. It is not included in the standard Catalyst offerings, nor does it have to be delivered by Focus. We have the talent on our team to do so, but we are positioning this as a list of 'good ideas' for them to consider, should they be looking at ways to integrate safety into their Leadership Training curriculum. Realistically, there's no way any consultant on any team could teach all of these topics. So the revised wording that Jen and I are working through with the ELA team will say something that more specifically acknowledges that, and we hope to have some changes on it in short order.
coming soon
I would suggest this claim location issue be directed to GB claims management. You can send the Excel file to the member so they can note any inaccuracies they're reporting. Then ask that the member reach out to GB Claims (Martha Turpin at Martha_Turpin@gbtpa.com) regarding any calais questions or potential correction.
We don't have a Catalyst wide ELA at this point. It's something I think we should do in the future, but right now the ELA team is loaded to the gills with ELA's in process. I know what you're thinking "inclusion of data from a captive-wide ELA could inform the member level ELA's". Great point 🙂 Given the circumstances it will probably wait until year 2 before we do it. we will have finished the first year and can integrate other solid information as well, like payroll, headcount, #of vehicles. It's going to be a data collection nightmare when that happens, but it could be a really great project. But the short answer is for right now, I would fall back on "soft tissue injuries, mostly from patient transfers, and motor vehicle accidents continue to lead the way for losses for the captive". Quantifying it isn't something we can do in the moment, and when that moment comes that we do quantify it.. it will be stale after a few weeks (the actual.dollars/claims associated).
If you mean your member’s operations compared to other members with the same operations then we don’t have that ....(yet) and maybe not ever. GB claims doesn't track this data. We can make a mad run at it next year, but kind of like the other question, it will involve the brokers and a lot of data procurement.
Not at this time, maybe in the future. Please also know that the members have a forum they can communicate through called the Catalyst Member Portal. Jen and I have access to it but our consultants don’t at this time (it would just be one more thing for you to track and it would not be much use since members aren’t using it much). That member portal is a way for them to talk to each other, and if there’s something they’re looking for, it would be a spot for them to say “Does anyone have anything on Topic X, Y or Z that they can share with us as a fellow captive member” .
Also though, in time Focus would love to be putting things together like this. It’s not part of the plan for Year 1, and not likely to be for Year 2 (we have bigger fish to fry for now), but in time… it would be great.
In short - *no*. As Rick would say - “F No”. We want to stay as far away from the Claims Management portion as possible, as it’s not our job and it’s specifically what GB is supposed to do for them (it’s what GB is paid for). We have to be careful of the politics as well, as overstepping our responsibilities into theirs could create easily avoidable static. Our job is only to tap them into conversation if the member says something specific about their claim/s doens’t make sense (in which case you’d be emailing Martha at GB about it, cc’ing the Member, Jen and Rick for her Martha to follow up with the member, and including as much information about the specifics of it as the member mentioned to you.
This is a question for their broker. In fact, any question that includes the word “premium” in it will almost always land on their broker. Please defer to Jen for who their specific broker is and they can ask that person directly. Let’s take ourselves out of the line of fire (pun intended!).
Those programs are available through Focus at an extra cost. We are only authorized to provide the 3 visits for this year. We want to be careful to make sure we’re being diplomatic and not hard-selling extra services, so if a client is asking, I’d say something like “Those are extra service options meant to inspire going above and beyond. Catalyst doesn’t fund them, it would be the members responsibility to pay for those services. And while Focus offers all of them, it’s important to note there are likely other vendors that may be able to offer similar services as well (though we are biased toward our own content, for obvious reasons)”
I just recorded a video actually using this company as an example for how our consultants can navigate the OSHA website... If you want to. There's no requirement for anyone on the team to be a OSHA compliance specialist, so you shouldn't expect the client to expect it of you. However, if they have questions or are interested in finding out more we are happy to show them how that can be done.
In doing the homework there are actually three OSHA inspections that have taken place for this company. I think the ELA only referenced two of them, but it did get the biggest one which was November 19th of 2021. The things they got hit for, I agree with you are likely from their shop area. But the fact that they've had three inspections in the last 5 years could be cause for concern, so please let them know if they'd like to set up some time to talk about options that Focus can assist with, we are happy to do so. This might include us helping them develop A written OSHA response program, training their team on how to respond when OSHA shows up, and or putting their people through in OSHA 10-hour program. And the next question that always comes up is "Is this included in the Catalyst services", and the answer to that is *no*. The only thing that's included are the three visits we are doing this year, any assistance beyond that we would have to have a direct conversation with them about so they understand pricing and what's expected, and for that absolutely take yourself out of the line of fire and tap Jen and I into it.
I just recorded a video actually using this company as an example for how our consultants can navigate the OSHA website... If you want to. There's no requirement for anyone on the team to be a OSHA compliance specialist, so you shouldn't expect the client to expect it of you. However, if they have questions or are interested in finding out more we are happy to show them how that can be done.
In doing the homework there are actually three OSHA inspections that have taken place for this company. I think the ELA only referenced two of them, but it did get the biggest one which was November 19th of 2021. The things they got hit for, I agree with you are likely from their shop area. But the fact that they've had three inspections in the last 5 years could be cause for concern, so please let them know if they'd like to set up some time to talk about options that Focus can assist with, we are happy to do so. This might include us helping them develop A written OSHA response program, training their team on how to respond when OSHA shows up, and or putting their people through in OSHA 10-hour program. And the next question that always comes up is "Is this included in the Catalyst services", and the answer to that is *no*. The only thing that's included are the three visits we are doing this year, any assistance beyond that we would have to have a direct conversation with them about so they understand pricing and what's expected, and for that absolutely take yourself out of the line of fire and tap Jen and I into it.
Optimally - yes. In fact it's a good idea to ask for a conference room to be reserved if possible, if you are doing this in person rather than over Zoom. By putting it directly into pulp stream you save yourself the hassle of having to copy over data later if you were to use a hard copy print out instead. In reality though, it can be done the old fashioned way with pen and paper and plugged into Pulpstream later, it's just a bit technologically inefficient to do so.
No need to attach any of the documents the member sends you to the RMPE.
We recommend you offer dates that are about a month out, and that you send your emails out asking for those dates starting next week, the week of December 12th. Please remember to put Jen in the BCC when you do this, so we know contact has been initiated.
Please also remember that you are hoping the member sends the advance programs to you a week before the visit takes place. That's going to save you time with the member, and allow you to look over their information at a pace that's comfortable for you and in a place that's comfortable for you - and before the visit.
I would suggest not to record this visit. From a practical standpoint it makes sense, but most people feel uncomfortable being recorded and since we are in the business of developing and maintaining the relationships, I would avoid introducing the potential discomfort from having them have to answer the question of whether or not they are okay being recorded.
It's possible to screen share, however I would recommend against it. You may choose to make notes in Pulpstream for their No answers, and can expand in the comments section about it. It's going to be much more comfortable for you to do that if you don't have an audience in the moment.
No, we want it to be a collaborative process and a learning process for the member, as well.
If it is not applicable and doesn’t relate to loss drivers give them a yes so it doesn’t hurt their score. Can also note this in the narrative box of the section.
Should probably be done by March 31, 2022 which is the due date of the RMPE.
I would try not to do that, we are allowing 4 hours so it should be able to be completed in 1 visit.
Sort of….
The 19-item request for information ahead of time will hit them at least twice before you show up - once from Jen and I with the Guide To Preparation for the RMPE, and once from you when you send your first email to set the visit up. In fact, remember we recommend including those 19 items in the calendar invite narrative when you send it as well - which will be the third touch point.
However we are also going to work on a "Pre-Meeting Document Preparation Checklist" to go out with the Member Guide, so it will be there as well.
Great question and we know this is going to come up on occasion.
If that happens, as politely as possible you're going to want to remind them that they joined a captive that was started by private ambulance companies, and expanded to include other health care related operations as well. I'd recommend apologizing that the RMPE can't be all encompassing for all members, however we hope that each member is able to take several points from the document for application to their operation.
(And yes, that's a little bit of tap dancing but it's the truth 🙂 )
Look at loss drivers if there are questions about which supplemental sections to include.
Email the person you met with for the first visit and the safety contacts listed.
No, only when you hit submit is it sent to the email distribution list you enter.
Yes, but ask members to look at their list of recommendations and when you make those we can jump back in and update your RMPE and score.
It will be the consultants making the updates, Rick and Jen will need to discuss with Catalyst additional visit charge or do we tell member we can’t update it til the next contract year
Consultants are only involved in the evaluation and updates, not the tracking of the changes.
Jen will ask who we reach out to at Pulpstream if we need to make changes on the RMPE after submitting.
Culture and OPs 1
There's no industry standard that we know of, but the question speaks more to the peculiarity of the specific job roles. For example, someone assigned to work on a bariatric unit would be expected to be able to lift a certain amount of weight (set by the clinic and/or client) where another member involved in giving vaccinations might have zero focus on weight lifting / manual transfer, but rather the ability to be able to sit for longer periods of time given the office-focused work.
This would be more focused on the member qualifying the person than anything else. In other words, are they giving that responsibility to someone that has safety and health training as part of their background, or are they having anyone who happens to be available do the training. If the fomer, +1 point. If the latter, 0 points.
Incident Reporting
It can be a single person, and it doesn't matter who just as long as someone is looking at the incidents monthly to review for patterns (so the minor accidents don't become major, and the near-misses don't become accidents).
Loss Exposures
OSHA requires BBP training initially and annually thereafter.
1910.1030(g)(2)(ii)(A) - At the time of initial assignment to tasks where occupational exposure may take place;
1910.1030(g)(2)(ii)(B) - At least annually thereafter.
Entry level (initial) is not good enough for a yes, they need to have the annual provision met for points as well.
Auto Liabilities
Great question, and I don't think there's a perfect answer. For Catalyst members running ambulances, for example, I don't think there's a national standard requiring EVOC training to be run (though I think there are some states that do, but I'm not sure which at this point). And, 'driver training' can mean different things to different members. EVOC for ambulance, but basic passenger training for medical staffing (locums). I think the best way to handle it would be to a) make sure there's proof a written Driver Selection Program, and b) ask if they've ran it past their corporate counsel for review (assuming your safety contact doesn't know what's required in the areas they operate). If yes to both, +5 points. If not, 0 points.
Healthcare Services
You're correct of course - thank you for picking up on it. We emailed the program and hopefully either a) the fix is made in the software when we're in there in the future and/or b) the client doesn't notice.
Another solid question. This would be in addition to PC365. PC365 is a nurse triage service. Some of the people on the other end of that service catching the calls may have specific hospitals they know of in the area, but most, I think, don't. (and remember, not all members of Catalyst are using P365 yet - but they should be, it's a money saver for them). So, the question is asking if the member has an existing relationship with a nearby clinic or hospital to intake the injured Catalyst members employees. If yes, +1 point. If no, 0 points.
Due to the high frequency/severity of soft-tissue injuries during patient moves in EMS, it is a best practice to develop an organization-specific patient handling protocol. A generic example is included below. The actual protocol should mention the specific devices available for patient moves, resources available for lifting assistance (additional units, Fire Dept assistance..etc.), and guidelines for when those resources are expected to be utilized.
- Assess the patient's needs and abilities before moving them. This includes evaluating the patient's mobility, cognitive function, and any pain or discomfort they may be experiencing.
- Plan the move. Consider the patient's size, weight, and any medical equipment they may be using, as well as the available resources and equipment.
- Use proper body mechanics when lifting and moving the patient. Keep a wide base of support, bend at the knees, and lift with your leg muscles, not your back.
- Use assistive devices, such as a mechanical lift or transfer board, whenever possible. These devices can help reduce the risk of injury to both the patient and the caregiver.
- Communicate with the patient and any other caregivers involved in the move. Make sure the patient understands what is happening and can cooperate with the move as much as possible.
- Monitor the patient for any changes in condition or discomfort during and after the move. If necessary, adjust the plan or seek additional help as needed.
- Document the move in the patient's medical record. This includes the reason for the move, the techniques and equipment used, and any observations or concerns.
As always, written protocols should not only be documented, but frequently communicated to all who are under their influence.
For sites outside of the organization’s direct influence where employees are expected to respond routinely, a Site Safety Evaluation is a best practice to identify and mitigate potential exposures to workers and patients.
Some of the key component of a Client Site Safety Evaluation:
- Identify any potential hazards at the site. This could include physical hazards such as trip and fall hazards, electrical hazards, or chemical hazards.
- Assess the risks associated with each hazard. Consider the likelihood of the hazard occurring and the potential consequences if it does occur.
- Determine the appropriate controls for each hazard. This could include eliminating the hazard, isolating it from workers, or implementing engineering controls such as guards or barriers.
- Request implementation of the controls from the client.
- Record the results of the safety evaluation and any corrective actions taken. This will help ensure that the site remains safe for workers and that any hazards are addressed in a timely manner.
- Review and update the safety evaluation on a regular basis. This will ensure that the site continues to meet safety standards and that any new hazards are identified and addressed.
Email to member from RG -
A couple of thoughts on this - because our team deals with helping clients on that end routinely - but I should note up front that it is out of scope for what Catalyst has agreed to for us for regular servicing this year. We can absolutely set something up to allow for some virtual training that speaks to it, but there would be some side billing that goes into it, if that is something you're interested in.
I should also note that we offered it (OSHA recordkeeping training) as a potential Catalyst Webinar topic for 2023, however it was ranked the lowest of all 16 topics we presented to the Catalyst membership. Given the fact that we are going to be starting the safety audits / Risk Management Program Evaluations this month, I would hypothesize that we are going to find a lot of folks have this area as a blind spot. Time will tell on that data.
OSHA does have a page dedicated to this topic and you can find it by clicking here. The information is relatively straightforward, but inevitably oddball questions come up, and the straightforward information can get a little foggy. Please also note, their forms (the 300 and 300A are the only ones you need, as the 301 is covered by the Catalyst First Report of Injury) can be downloaded here as well.
If it's of interest for us to set up some time with someone on your team for 1:1 training, please let me know and we can put something together to try to make that happen (but again, it would be out of scope from the Catalyst servicing agreement, thus direct bill).
Thanks,
-rg
PS As a reminder of what is covered for Catalyst Risk Control servicing for 2022-2023, I'm attaching the Webex from May 5, 2022 for your convenience.
They did - but it's was not well received. They hated the format for that audit, since much of it had *nothing* to do with healthcare things like Confined Space, Welding, Trucking.... etc. They hated it, as a group, so much that the first thing that Jen and Rick had to do was work with a panel of their volunteers to recreate it to become.... the RMPE. So using the previous audits would be kinda pointless, and could trigger a few.
We sorta punt. The existence of that option is a holdover from the old safety audit. In our case, we won't be doing that unless, by chance, we're on site. Then we have that option, but in reality ….. we've rarely done it (on the traditional side). It's kinda weird to collar someone in front of their boss and say "Can you give me an example of ____"
We’ve got a video on this that Curtis worked on (I think/thought we touched on it previously, but not sure. Jen/Curtis, can you please include that link? It might be on TMZ for Catalyst.
It should be a standalone statement, usually the first or second page of the safety manual - and signed off by senior management (hopefully owner/President). Having a generic statement ‘somewhere’ doesn’t cut it for this. Policy statement is meant to communicate commitment and should be posted prominently in the safety manual (at a minimum), and possibly in the workplace (that would be the A+)
This should be someone credentialed as an MRO. If they have those qualifications in house, I think this is ok. Outside of Catalyst (since most other companies aren’t healthcare) this is outsourced to the local clinic when done properly.
You can think of this as a Red Alert type claim. If the client doesn’t know what it is, it’s safe to assume it’ll be a No answer, but FYI - it would be something the client is indicating should be handled specially by GB - like a fatality, catastrophe, or suspicion of fraud.
TPA is the Third Party Administrator - for Catalyst that’s Gallagher Bassett. There’s an online claims management system that members can/should go through called Risx Facs (pronounced “Risks Facts”) and / or Luminous. I’d ask the client if they have used either system directly and if not, they get a No (and a recommendation for them to reach to Gallagher Bassett to help them get setup for the training)
No idea what Fitresponder is, I think it’s just a vendor that Captive Resources (Catalyst creator) has referenced. Any specific stretch flex program will do (they can even create it in house, but the key is that it’s used.
Not sure how applicable it is given the fact that everyone has a phone these days.
Catalyst doesn’t have anyone in particular that’s used for this. In the past, members could use purchase things like this and submit them to Catalyst - however that option has been terminated. FYI - but not to be shared with the member - Those dollars for purchases came out of their risk control budget - which we draw on, it’s how we get paid. The practice resulted in former risk control firms to disengage from replying to clients
Globally Harmonized System (for the classification and labeling of chemicals). This was previously known as Hazard Communication (or Haz Comm), the OSHA regulation dealing with the employees Right To Know about the chemicals they work with. Fun Fact: Outside of California, this is the most frequently cited OSHA regulation for all but one of the last 15 years. Inside of California, though, Injury Illness Prevention Program is the most frequently cited (and is more general to the overall safety program, not primarily focused on chemicals)
We can look through the documents during the evaluation and can ask member to submit documents within a week after the visit. But after 14 days after visit, the answer will remain no in the RMPE.
The answer on the RMPE will be no, if they will not share the document evidence of compliance.
Up to the member and the consultant based on services provided but if the member feels strongly about a certain section, it is ok to agree with the member.
No, this pertains to employees that are found to be in possession of illegal controlled substances at work and should be confiscated by police.
Certain questions within certain sections only apply if the member owns the building.
We recommend you review the blank RMPE document and associated guide that Rick sent out to the members, to prepare for your visit.
Offer breaks to your client, use two monitors, make sure you’re prepared and comfortable sharing your screen with the member, thank them for their work compiling reports and preparing for the visit.
Completely up to the consultant. It’s a little faster to do it live on Pulpstream during the evaluation but if you’re more comfortable with pen/paper, can use a printout RMPE.
Maybe 1 to 2 weeks prior to visit, send a reminder to reiterate if they send you the documents ahead of time the visit will go much quicker and be less painful.
Chargebacks aren't done to the employee they are done to the department or the division. It is perfectly legal. Reasonable to charge the internal division or department or location for the accident performance that they have. It is NOT done for the employee.
Great question. We will reach out to the Captive attorney and get back to you with his response.
This is referring to the ELA loss reports and whether they are reviewing it and coming up with action plans to prevent reoccurrence.
No, the captive does not offer reimbursements any longer.
Does the captive pay for the DOL out of that 1% ?
none of the other 20 captives that we do business with pay the Department Of Labor for anything as far as we know.
Redacting is fine
This pertains to employees that are found to be in possession of illegal controlled substances at work and should be confiscated by police.
Client's address
Correct.
The follow question states "Industry average total recordable case rate" which refers to the TRR/TRCR from Curtis sheet.
Correct.
The word 'rate' is the determining factor? Is that consistent throughout?
Yes
It does warrant a yes, only workers comp works with PC 365.
Sorry for the confusion here - this isn’t to say that a member that has open claims would be receiving a No answers on these 3 questions necessarily , rather that if a member doesn’t have open claims, they would be receiving a Yes for these questions, because the positive data (zero open claims) is indicative that they are on top of the claims handling process. There are *very* good reasons for a member to have open claims - the existence of open claims isn’t indicative of them doing anything wrong. However it does allow us to ask question about their claims management processes - Does the member Claims Coordinator evaluate all open claims? (A clear No would be “Oh, we don’t look at claims until someone tells us to”, or something along those lines). Does the member Claims Coordinator have an on going dialog and good relationship with the adjusters? (A clear No would be “I don’t know who the GB Claims adjusters are, I don’t even know where the GB branch is located”). Do the member schedule and participate in Claim reviews? (A clear No would be “I don’t know if this is done, it’s not my responsibility, and I’ve never heard about this” <- especially No because if they don’t know….. they should have found out, since you gave them fair notice of the visit and what would be reviewed, and RG made the original announcement about the RMPE and the Guide To Prepare for it on 12/16/22))
I appreciate you sending some of the information over, but I'm pretty confident there's some misinformation in here that you may want to correct, As I'm pretty sure it would be impossible for 800 employees to work 615 hours in a year. Further, your 2021 log shows zero injuries, however our claims data shows that to not be the case. While not all accidents are recordable, I have a feeling plenty of your claims were, and it may be worthwhile to revisit your OSHA logs. Typically OSHA has no problem with revising logs to reflect more accurate information, and this would be a perfect opportunity to do so.
However, I am more specifically concerned about the lack of documentation for the RMPE process. You should have received an email from Rick Grobart, our team lead, on December 16th that included the guide to prepare for the RMPE. In that guide there were 19 specific items that a member might need to prepare, reflected on page 3 as well as the final page. I'm including that document here as well for your convenience as well, and I have to have this report turned in next week as we met for this purpose on January 23.
Please know that I'm not allowed to give points for unsupported answers, and a lack of documentation means your score is going to come out very low if you can't get the support information to me. Please understand I'm doing my best to work with you as your consultant, but I am bound also by the requirements of catalyst and focus, and I believe those requirements are outlined in the attached guide on page 2 under "Member Preparation for RMPE. Specifically "If documentation doesn't exist to support the answer, the question is marked no. Please understand this is an important component of the audit, as all members are held to the same standard and subjectivity is eliminated".
Totally okay to check that box yes. If you're comfortable with what they have in place, and it sounds like you are, we're not taking any points away from them because they aren't using a GB product. We are good partners, but we are not commercials for GB (or anyone else besides the captive).
Per OSHA supporting text below, you DO need an OSHA 300A log for each establishment/location.
1904.30(a)
Basic requirement. You must keep a separate OSHA 300 Log for each establishment that is expected to be in operation for one year or longer.
1904.30(b)(2)
May I keep the records for all of my establishments at my headquarters location or at some other central location? Yes, you may keep the records for an establishment at your headquarters or other central location if you can:
You can use the spreadsheet that Curtis created that helps to compile multiple locations' OSHA 300 data.
I would not include this one in the recommendations, because there is nothing you can “recommend” for them. This would be the one exception where a “no” answer doesn’t generate a recommendation.
This is incorrect. There's nothing wrong with them having open claims, in fact in a weird way, it's good for business. But the questions for 48 through 50 speak to the relationship with the Claims Coordinator and participation in Claims calls. There are some members, especially the very large ones, who know exactly who the claims adjuster is for their company and is routinely in contact with them, which of course has better results for Catalyst as well as the injured employee, and that's kind of what these questions are probing. Small members who don't have claims very often likely have no idea who their claims adjuster is, and sometimes even how to properly file claims - frequently leading to longer lag times and pissed off claimants. So questions 48 through 50 are more or less trying to gauge whether or not the company makes a point of facilitating the relationship with Gallagher Bassett with routine calls (known as Claims Reviews - these take place without Focus involvement at all, it's GB, the member, and CRI Claims Manager - to review open claims, and if they (the member) are keeping an eye on all open claims. If the answer to these are Yes And you believe them, feel free to give them a yes …. even if there are open claims.
Absolutely! If they use someone besides GB for a nurse triage service, it's perfectly okay and I would give them a Yes. In fact, about 6 years ago I was at a Board meeting for another captive and one of the members specifically made a point of standing up and saying "I just want to make sure everybody understands they don't have to go with PC365. There are benefits, because it's hardwired into the GB system that we all have to use because of GB claims on our program, but there are more cost effective nurse triage programs out there that have higher quality and responsiveness". Yes, it was awkward hearing that, especially since I worked for GB at the time (but had no responsibility for PC365), but I'm sharing this because I think it might reinforce the point here too.
I would just use the data they gave you for 2020 and 2021, even if it was only for one site, and then use the 3 forms for 2022. It sounds like they may have had some issues in the past with their recordkeeping practices and this is not an important enough issue on our end to further stir the pot. Sometimes it's better to strengthen the "partner" relationship with the client and let something like this go unmentioned.
No, but it is mandated that Focus provide this training to your organization. We speak in sessions but the attendance requirements, how many, which employees , etc. is left to the client.
We can offer the training virtually.
It is live streaming.
We will need to adapt to whatever platform they use and may need them to coordinate the invite, etc.
Maybe look up a news report and reverse engineer it for a non EMS member? Maybe look up distracted driving stories?
Unfortunately, no. Our agreement with the vendor is that a consultant will be present each time the video is played.
You can record everything but the video because it is not our intellectual property and we can’t record it.
You should write down the answers as the participants say their answers to you. We’re not using the Zoom Chat to collect their responses because their name will be attached to their responses.
Will do the training for however many participants attend but we will make a note of the member’s participation. However, if there is only one person, let them know you need to reach out to Rick and I to discuss this and get back to them about it.
The short answer is that the 8 hours includes consecutive field time on site they could block you off for. Drive time and office time would be on top of that, no problem at all. So if the member that's 2.25 hours away wanted you to do a training from 8:00 to 9:00 a.m., and then from 4:00 to 5:00 p.m., you could say yes to that and bill us for the whole time, in addition to the 4.5 hours of travel time and your office time on top of that. I'm hopeful that if they wanted you at 8:00 a.m. and 4:00 p.m., they might also want some training in between. But even if they don't, I'm cognizant that you have taken time away from work and other things to do this, and I don't want you feeling like it's donated on your part.
Ask for one of the attendee’s email address and send them the attendance link to share with all participants.
Every organization will likely be different as to who joins the training so this is a difficult spot. If management is present, we can’t really ask management to step out so we’ll just have to be sensitive to the fact that responses may be a bit guarded if management is present at the training.
You can start reaching out now as long as your member has completed their RMPE, maybe giving them a week or two of lead time when offering dates.
We would like to have at least one of the sessions completed by the end of April. The Catalyst contract ends at the end of May so we won’t be able to schedule any of these training sessions for after 5/31/23.
In a situation like that, I recommend you do it virtually to get more bang for your buck. You can say something like, “my goal is to do a training for 25 people or less during one session. You can populate those sessions with 25 people however you see fit, for up to three possible separate virtual sessions.
No, the membership hasn’t seen any training like this in years.
One, we explain that as a Catalyst member, they are expected to participate in loss control services. Second, this training will provide the benefit of potentially reduced accidents. We will listinen to employees to where accidents will happen and then we share it with the management.
As a consultant, we offer as much flexibility as we can, as is possible. Sometimes third shifts are overlooked so we try to accommodate if possible.
Yes, each person will log in to the zoom.
We can encourage camera on, but it is not a true requirement that we can/should mandate.
We don’t care, as long as they are respectful of your schedule and the available time frames you’ve offered.
We don’t get involved in the compensation for the employees to participate in the training. That is wholly up to their employer.
We suggest Rick send an email with the following verbiage,
CONSULTANT pinged me about this knowing the Situational Awareness Training was going to require a creative solution. I'll break down the problem, the proposed short-term corrective solution, and a longer term for Q1 if I might.
Extending the training into June presents a problem because the new Catalyst contract starts June 1st. So either we get the work done before then for this visit, or technically we can't check that box for you or for Catalyst for this third visit (and of the 3, I think it's the most interest and informative of the lot). It's a weird timing issue, and something we're going to leave even more of a pillow for in the next contract year for servicing.
Can I suggest that CONSULTANT run the training virtually for you and a handful of folks you would consider safety leaders - in May - and then it'd be completed in June at a time that works with you and Mindi for your wider team? There wouldn't be anything additional in the way of dollars for the June training, since we will take the credit with the May occurrence. But this way you get the box checked for completion in the expiring contract, you also get to taste the program a little bit, and then can broaden the attendees as you see fit.
Would that work for you? If so, please let us know and CONSULTANT will work with you on coordinating something virtually for your safety sensitive key personnel (even if it's only a small group of two or three, it will be helpful for envisioning how and where to apply to the wider group). Thanks so much and have a great day!
Rick suggested we add this note to create a third paragraph in the letter,
Please note, this training is designed for the wider group of employees, as they are the ones who typically incur the losses as a result of workplace accidents. I absolutely appreciate the opportunity to deliver this to one employee, but please know that I'm available to do so for more employees in the next contract year if you see fit. I believe the larger group was the spirit of what Catalyst was hoping for from us for our member engagement, however I understand the logistical difficulties sometimes encountered with larger group assemblies. You will find that in our first visit for the next year I'll be asking about employee training during the course of the contract, and perhaps we can include this into your larger employee training planning session.
Unfortunately, we do not have a video of this training for a couple of reasons:
- Because there is a level of anonymity involved in fostering discussions with the participants during training, any recording would likely lessen the honesty and abundance of attendee feedback.
- Recording the session would also be in violation of our licensing agreement with the video we use for this training." We cannot give them access to it. But what you can do is tell them where they can purchase it, which would be here. (And of course that legally we aren't allowed to share it outside of our team for licensing reasons,)
We previously thought we were going to be left with a plethora of unused service visits which might carry into the new year, and I think/hope I teed it up a little conditionally. However, since then the initial numbers show that it looks like we're going to get 100% of our service visits completed for the first year, thus no rollover credits to be used. Sounds like a problem, right? I've got a creative solution....
If the consultant/client is okay with it, let them know that you can do those same sessions on the same day you do the loss review /first visit of the contract year, at no extra charge. And as long as that training is done in the same day as the loss review, they’re golden and you can just integrate the feedback from the training into your ELA letter (it'll take some massaging but I think you can freeform it).
However if they’re wanting training over multiple days, we are going to have to work up some numbers for that.
Response from Shawn Brend, Claims Services Manager - This information would be on the Catalyst member portal https://columbus1.captiveresources.com/catalyst . It is in the library under the heading Group Purchasing Program. If they need a username for the member portal, please advise them to create an account with their member number.
Response from Rick Grobart - Attached (in Catalyst Google folder) is the Captive Resources Group Purchasing Program and you'll find Samsara listed on page 68. We (Focus Management Associates) don't have the relationship with that company, though I've heard nothing but great things about their product. I'm including Jeremy Bonino on this email in case there's questions that speak to needs related to the Group Purchasing Program.
Inspira wants to be excepted from the safety culture survey because they use something like this in a house and they've said it's overkill. We asked Greg (their broker) to get a copy of it and send it our way so I can get a look at it. we told him they would likely be the only member on the list who did not participate and I'd have to reference that to the board, but if the safety culture survey they went through is pretty close to what we have, it seems a pretty reasonable thing to be accepted on.
It's premature for me to say, because there are companies out there that specialize in 'quick surveys' of 3-5 questions, that are more focused on being able to say a survey was completed then actually deriving value from the process. That's not to say that's the circumstance for Inspira, but it's what I have to hedge against since I haven't yet seen what their product and process looked like. It's also possible what they went through was more robust than ours, I really don't know until I see it.
If you're able to get your hands on it and send it over to me I'll try to turn around some feedback pretty quickly. I think we've asked Jen once or twice and she launched a request with the firm that did it, but I haven't yet seen the output.
Thanks for getting back to me, Mike. If it helps, the link can be sent via text message and done using a smartphone.
Let me know if you think I can help in any way.
From RG -
I absolutely understand your concern about the discoverability of documents like this. One thing I can suggest is that perhaps your counsel can take a look at the questions attached to the original and see if there's any hot button issues in there that they think might overexpose your organization in particular. And if so, given these particular dynamics, perhaps we can make some tweaks to make the process more appetizing from their perspective.
Does that sound feasible? And if it does, we can hit a reset button and defer it until next month.
I've been in this dynamic for a long time and the prevailing thought process that I've encountered has been that it's better to ask the questions and mark improvement for the challenged areas, than not ask questions at all. The latter makes it hard to measure (or identify) improvement, and in this case would make the employees voice representation in the process much harder to acknowledge.
Please share your thoughts when you get a chance.
Per Mike -
That sounds feasible.
Per RG -
You bet Mike, happy to make adjustments to make it more legal friendly for your counsel.
Would it be okay to please ask them to have feedback to us by 12/20? This can give us some time to consider it and then hopefully launch an adjusted version for Jan-Care in January.
From GMT -
I have sent this out to most all our staff, its disappointing to have only gotten 9 responses back.
If we do a reset, does it keep the 9 or does the reset start them all over again?
If it doesn't mess with the 9 responses we have already received then yes, please reset allowing more to respond.
Thank you,
From Callie -
Hello,
Thanks so much for getting back to me so quickly. We will go ahead and include you in the final wave. Please note that you will receive all the emails you previously received again, but the survey link will not change and the initial responses will not be changed and will be included in the final results.
RG email to broker-
I hope this email finds you well and all good in your houses for the holidays.
I'm reaching out because we've got another issue with PRIDEStar not wanting to participate in loss control. This is a safety culture survey that all 102 members are going through... and it sounds like PRIDEStar is seeing it as voluntary. I can't speak for the captive, but I thought I'd reach to you before formally escalating it, as I know the Catalyst Board Of Directors is expecting me to present the results at the April BOD meeting, as this is a pretty high profile project. We're about to start the final wave of these, and so far none of the membership has gone down the road of suggesting they don't want to participate.
I'm hopeful you might be able to leverage your relationship with them to allow our team to collaborate with them so I don't have to formally escalate it to the captive level. It's my hope that we can get it resolved smoothly and hit the reset button to move ahead with it.
Your previous intervention spared them from appearing on the Non-Responsive Non-Cooperative list, and I'm hoping you might be able to work your magic with them again.
Please let me know your thoughts when you get a chance.
RG follow up email after meeting with broker-
Okay folks, just an update on this member.....
I just had a 30 minute conversation with the broker, Elena, who was pretty awesome. The summary is that the member was reluctant to participate because they didn't fully understand what was to be done, nor the consequences of not participating. I explained to her the methodology of how we got to this point, that it was reviewed at the past two BOD meetings and the RCW, how we assemble the team of our healthcare consultants to work with Slaven on the question designs to make sure they were health care specific, and then how we ran it past a volunteer panel of members for any final touches. She was impressed, she appreciated the time, and she said she would go back to the member to see if she can get them to participate. I volunteered that I'd be more than happy to jump into a call with her and them if it was needed, but I'm in standby mode for now.
I also told her about the final wave in January and that we could move them to that if they wanted to, but that would be the final opportunity. She said she would let me know.
That's the update, let's hope for good things from her.
RG email/call with Paramedic Services of IL that don’t want to complete survey either:
Thanks for taking my call a little while ago, I appreciate it very much.
When you get a moment please review the string below and let me know how I can help. As I suggested on the call, it might be a good idea for you or Tony to reach ro let the member know that you can arrange to get them into a survey with us next month, January 15th through 25th, but that's the final window. Anyone who hasn't completed it by then is going to be on the list for me to review at the Catalyst Board Of Directors meeting in Grand Cayman in April, and at this point they are the only one of 102 that will be on that list. We've got over half of the members completed and the rest are pretty much in motion and scheduled to finish shortly.
We just want to hit the reset button and get them on track, and if you can help we would very much appreciate it. And also, as mentioned it on the call, it's 100% my fault for not catching Jenny's December 7th email indicating they didn't want to participate otherwise I would have made today's call to you on December 7th. We've been a bit swamped with the project and that one slipped through the cracks and I'm sorry about it.
Final note, you've got editorial privilege to massage my email however you see fit to help get things on track. I know we all want let's smoothest for the member and for the captive.
Have a great week and a great holiday ma'am, it was nice talking with you today!
RG email response -
“The questions have been vetted by our panel of healthcare professionals (each with a minimum of five years of full time healthcare experience, and most in excess of fifteen years) and then a panel of members who asked tooffer feedback before they went live.
It's been a few months since we were in that spot, but I believe the thought process at that time was that if there was a pattern of employees scoring toward Strongly Agree on the Likert scale, the member is less likely to have a strong safety culture than those skewing toward Strongly Disagree. Strong safety cultures wouldn't see lower-level employees as expendable, but challenged ones would be more likely to.
I hope that helps, and if you have other questions, please let me know”.
Pia Email response,
“Thanks, Rick, for getting back to me. I suspect that this question was to gauge employee trust levels. This poll is about safety culture, then might the question have been asked in that context? In other words, could there have been a better way of phrasing the question?
I’m not an expert survey writer. Could FCM ask the 10-panel survey advisors why and how they chose to this question as they way it was written for a safety culture survey?”
RG email response,
“Hi Pia,
Unfortunately the panel was dissolved long ago, as this project has been in development for quite some time and launched months ago. We have over 50 member surveys completed at this point, and I think you're the first to express this concern on this question (or any question for that matter). I'm not an expert survey writer either, by the way, but I know there was at least one PhD involved with this project who does specialize in survey writing. And unfortunately I can't tell you where anyone's mind was way back then, but I do trust the folks that shared their input before we proceeded.
That said, I will absolutely log your concern and raise it if there seem to be issues significantly arising as a result of this particular question.
And I appreciate your feedback ma'am, as always!”
RG email response,
“With respect to the phrasing of the question and the expectations for action based on responses, I have a few thoughts....
First, please know that Dr Slaven has a background in putting these instruments together, and he's done it for our clients for several years with pretty positive results. I absolutely understand the apprehension but know that you're in good hands. Also, when the initial questions were developed they were first run by several consultants on our team, all of whom have at least 10 years of full-time health care experience. From there some suggestions were made for revisions to make sure the questions were health care appropriate. Next, they were put before a voluntary panel of Catalyst members, including the Catalyst Risk Control Chair for final review. From that the 46 question survey was compiled and so far we haven't had any negative comments from any members who've completed it. I hope that provides some comfort.
Second, with respect to what to do with the results, you won't find us following up asking that question. Your company and cultural decisions are yours to make, and I know there's already enough regulatory oversight in the health care industry. Adding one more layer for follow-up compliance on a survey like this isn't something we aim to do. As with any patient though, you don't know what you're up against until you have completed a baseline, and this instrument was developed specifically for that purpose. We are also careful not to obligate the company to take action on anything in particular as part of the survey, as it relates to employee completion.
Dr. Slaven will be in touch shortly, but if you need anything else that I can help with, please don't hesitate to reach out.”
RG email response,
“I have to be careful not to overstep my boundaries, because our job is just to deliver services. I believe participation in loss control is required by the captive, but I can't speak to any specific ramifications for not participating in this activity.
I believe this is the first time Catalyst has done a captive-wide Safety Culture Survey. Our job as the vendor is just to make sure we are offering it to all of the members with as much diligence as possible, completing it along the way and delivering a final report to the Catalyst Board of Directors in Grand Cayman in April. I have no idea or influence what happens after that, I'm sorry.
For what it's worth, most of the members who have completed it already have had good things to say about it, and several have asked for a timeline for it to be done for them again so they can measure improvements where gaps have been found.”
It's premature for me to say, because there are companies out there that specialize in 'quick surveys' of 3-5 questions, that are more focused on being able to say a survey was completed then actually deriving value from the process. That's not to say that's the circumstance for Inspira, but it's what I have to hedge against since I haven't yet seen what their product and process looked like. It's also possible what they went through was more robust than ours, I really don't know until I see it.
If you're able to get your hands on it and send it over to me I'll try to turn around some feedback pretty quickly. I think we've asked Jen once or twice and she launched a request with the firm that did it, but I haven't yet seen the output.
There is no perfect answer. I would still bring this topic up at meetings and suggest the company can connect virtually to ask employee questions, post incidents or suggest mobile phone photos to share, etc.. Can still discuss lag time and ways to decrease it.
I would suggest you stay out tf the way of any active police investigation but can take mobile photos from afar, interview employees post incident, etc. But follow the posice lead.
First, thank you so much for your great attention to details and for catching this. Second, please feel free to add two lines for those two years with 0 lag time to the table in your presentation. You can always make any changes as you see fit. This is certainly a change that makes sense and should be reflected in the presentation!