This document provides guidance to Australian speech pathologists on establishing a basic compliance system to reduce stress and non-attendance issues. It recommends appointing a compliance officer and following 11 steps: 1) identify key issues and stakeholders, 2) establish foundations and scope, 3) identify risks, 4) understand regulations, 5) implement policies and training, 6) set escalation processes, 7) regularly update the system. It also uses a case study to discuss using compliance systems to analyze non-attendance data, communicate policies, and monitor clients. The overall goal is to provide a organized, evidence-based approach to reduce chaos and firefighting.

1. Australian speech pathologists
in private practice:
reduce stress by building a
simple compliance system

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HELLO!
David Kinnane
SLP and lawyer

3. Goals
1. Extol the
benefits of having
a compliance
system.
2. Show you how to
implement a basic
compliance
system.
3. Give you free
resources to make
it easier to do it.
4. With your help,
workshop how to
use a compliance
system to reduce
FTAs.
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4. What?
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5. Chaos!
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6. System: a set of principles or procedures according to which
something is done; an organized scheme or method.
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7. Why?
On why many SLPs struggle with
compliance issues
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8. Why don’t all SLPs have a compliance system?
▸ Lack of training
▸ Lack of time
▸ Lack of money
▸ Doesn’t seem related to clients (untrue!)
▸ Doesn’t seem to affect bottom line
(untrue!)
▸ Boring and stressful!
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9. What do many SLPs do instead?
▸ Buy a manual of policies and procedures
(but never read it)
▸ Act like an Ostrich…
▸ Fire-fight
▸ Cobble, cobble, cobble
▸ “I’ll have what she/he’s having”
▸ Freak out!
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10. Why should SLPs have a compliance system?
▸ Not a huge job if you break it down and start out small
▸ Ignorance of law is no excuse
▸ Reduces stress – less fear of unknown
▸ Systems save time and money over time
▸ Less fire-fighting, panics
▸ Provides framework to build a compliance culture in your
team, track changes, deal with problems, improve client care
▸ Bigger picture issues:
▸ competitive advantage
▸ reputation of the profession.
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11. How?
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12. “
“Set a goal, and in small, consistent
steps, work to reach it.” Seth Godin

13. Theory
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14. Practice: How to establish a compliance system in 11 Steps
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15. Step 1: Appoint a Compliance Officer
Tip: Make it someone senior,
with authority to enforce
decisions internally and to
bind the practice to public
statements.
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16. Step 2: build the right foundations – keep the big picture in view
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17. Step 2: build the right foundations – keep the big picture in
view
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18. Step 2: build the right foundations – keep the big picture in
view
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19. Step 2: build the right foundations – keep the big picture in
view
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20. Steps 3 and 5: Identify key issues and scope of system
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21. Steps 3 and 5: Identify key issues and scope of system
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22. Steps 3 and 5: Identify key issues and scope of system
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23. Steps 3 and 5: Identify key issues and scope of system
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24. Step 4: identify key stakeholders
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25. Step 6: Establish a simple Compliance Policy
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26. Step 7: identify key compliance risks for your practice
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27. Step 8: Understand how Australian SLPs are regulated
(free resources)
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To get up to speed on the basics
quickly, check out these free links:
Law for Australian Speech
Pathologists: Episode 5 - Regulation of
SLPs
https://youtu.be/z0Hd7RVDb7o
Cheat Sheet:
https://www.speechiesinbusiness.com/
wp-content/uploads/2018/03/Episode-5-
Cheat-Sheet-Self-Regulation-of-SLPs-
in-Australia.pdf

28. Step 9: Implement policies and procedures – don’t forget
training!
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29. Step 9: Implement policies and procedures – don’t forget
training!
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How I do it in practice:
• Induction Training – highlight written policies, including Staff Code of Conduct
• Intranet (for staff only) - all staff policies and training videos – latest version of all
policies in one place.
• On Website, link key consumer policies, e.g. Privacy Policy, Terms of
Use/Bookings, Ethics, EBP, Statutory Code of Conduct, Code of Ethics – see,
e.g. https://www.banterspeech.com.au/our-approach/
• Client Welcome Pack – key client policies, including Privacy and Health Records,
Feedback Policy (complaints), Attendance.
• Performance Appraisals.
• Staff training and team meetings.
• Incident reports.
• Testing (e.g. spot file audits).
• Annual management reviews.

30. Step 10: establish escalation/reporting lines – test the system
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31. Step 10: establish escalation/reporting lines – test the system
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Testing includes reviewing:
1.Complaints Register;
2.Escalations and Incident Reports;
3. Random client & staff files for compliance; and
4.Physical equipment checks.
Updates include:
1.professional association news;
2.regulator, government and university alerts;
3.advice from professional advisors; and
4.input from mentors and networks.

32. Step 11: Update your system regularly
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For big, urgent or regulatory changes, you’ll need to
take action immediately.
The Compliance Officer should also undertake regular
e.g. quarterly reviews of obligations, and policies &
procedures.
Again, associations can help you with this with their
regular news updates.

33. Case study: Using a compliance system to reduce FTAs
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Goal: to reduce cost of failures to attend.
No magic bullet. Let’s brainstorm.
1. Measure baselines – management system – make
structural adjustments:
• Overall.
• Seasonal (e.g. early/late terms, week 2 of holidays).
• Weekly (e.g. Friday afternoons).
• By clinician (e.g. new grad, junior, senior, director).
• By service type (e.g. late Stage 1 Lidcombe, literacy)
• By client group (e.g. adults v preschoolers)
• Others?
• Think about what this means for your service mix.

34. Case study: Using a compliance system to reduce FTAs
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Goal: to reduce cost of failures to attend.
2. Think critically about evidence-based dosage levels, e.g. with school-age
language v CAS, see: https://bit.ly/2Mqel9i - communicate this information to
clients upfront , e.g. in Ax reports, including risks of insufficient dosage.
3. Map coverage/capacity/marketing plans, e.g. holiday timing. Mitigate effect
of FTAs: time income producing projects, advocacy, business systems and
compliance work, performance reviews, training for these periods.
4. Experiment with different models, and measure outcomes:
• Package services, e.g. LSVT, preschooler groups, Hanen, Telehealth
Lidcombe/Westmead.
• Upfront term payments, e.g. for school-age clients.
• “Jujitsu” models, e.g. early language drop in sessions.
• Are there any others you’ve tried? I’m all ears!

35. Case study: Using a compliance system to reduce FTAs
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Goal: to reduce cost of failures to attend.
5. Remind clients multiple times about attendance policy:
• At intake, flag Attendance Policy
• Questionnaires
• Website Booking Policy
• Client Welcome Pack
• Post assessment/therapy chats with admin on booking.
• SMSes (experimenting)
6. Establish value of attending:
• Highlight scarcity (e.g. through waitlists)
• Show the effort that goes into preparing each session

36. Case study: Using a compliance system to reduce FTAs
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Goal: to reduce costs of failures to attend.
7. Make someone senior responsible for monitoring FTAs:
• If possible, not the treating clinician.
• Compliance Officer or Clinic Director – call after second
FTA, explaining, e.g.: (1) other people are waitlisted for the
spot; and (2) non-attendance affecting client’s progress,
other clients, clinician, and practice.
• Document discussions.
8. Onboard slowly, discharge non-attenders efficiently:
• Explain discharge by reference to attendance policy.
• Stay client focused and ethical. Be compassionate. Offer
other options, if available. No shame or ‘punishment’.
• .

37. Practice: How to establish a compliance system in 11 Steps
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THANKS!
Any questions?
You can find me on LinkedIn, at @speechbloke
(Twitter) & via hello@banterspeech.com.au

39. Credits
▸ Presentation template by SlidesCarnival
▸ Photographs by Startupstockphotos
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