So, we went LIVE, what happens next?

Blog # 9 is the final blog in this Redesigning Quality Systems series. Refer to blog # 7 for an overview of the 5 Steps for GO-Live Strategy.

Go-Live: Step 4 – Triage Impacted Documents

The purpose of the triage step is to manage the impact of in-process system documents the day the new design goes live.  What happens to forms that were started and not yet completed?  Employees will need to know how to move forward and still be in compliance.   The easiest path on Day 1 is to use the new form(s) to begin a new record.  But what about the documents that were already started?  The ones that were initiated.  They will reflect the previous version although in effect at the time of initiation. Anticipate these questions from affected users:

  • Do we process the old form?
  • Do we start over with the new form and add the original started document with EOD notation for missing information?
  • Do we suspend and pick up with the new form?

A good example of this situation is when paper change control requests have SOP drafts attached. The Project Manager with the guidance of the Head of Quality needs to meet prior to the launch date to carve out the decision paths based on the amount of initiated documentation stages each document contains.  These decisions and individual directions are the main tenets for daily guidance from the Project Manager and/or Quality System owner during the start and end period for the transition phase.  Revisit Step 2. 

In addition, s/he or a small team needs to answer questions that are sent via emails, phone calls, drop by’s and drop-ins for direction on how to close the loop on initiated previous versioned documents. Anticipate additional 1-1 coaching through the new paperwork until the end of the transition period. 

“What happens to forms that were started and not yet completed? ”

Vivian Bringslimark, HPIS Consulting, Inc.

When Will We Be Fully Operational with The New Design?

When this design team began putting together its go-live strategy, their impact assessment (Step 1) mirrored an “End in Mind” approach.  The project manager asked, “what needs to be in place in order for us to be fully compliant with this procedure”.  The list of items was long.  The second question – “What is the best way to accomplish this” was then asked and detailed steps were captured.  The third question focused on the estimated time to complete and so on.  In essence, the team was generating an implementation plan to guide its launch decisions.  It became clear that they needed to launch in high priority clusters

However, two cluster sets were competing for first place to launch.  One focused on the business objective while the other focused on establishing foundational principles for the quality system.  In a stunning presentation, the system owner made her compelling appeal to the site leadership team and was given the approval to begin with foundational principles despite the number of tasks and time to complete those tasks. 

In order to move forward with identified tasks from the implementation plan, the team needed the high-priority procedures to be in effect in order to gain cooperation from department managers.  This created a compliance dilemma of being out of compliance immediately upon launch.  To mitigate this gap and not create unnecessary deviations, the system owner generated a change control packet that also included the implementation plan tracker.  It gave the design team the necessary authority to invoke the changes without becoming bogged down in the compliance dilemma dialogue which derails progress. 

When FDA made an unannounced visit to the site weeks later, the change control packet of documentation was not only accepted as an appropriate way to cover the obvious compliance gaps in the new procedures, but the implementation dates were moved up and execution of the plan became a site priority. 

The project manager asked, “what needs to be in place in order for us to be fully compliant with this procedure”

Vivian Bringslimark, HPIS Consulting, Inc.

Go-Live Step 5: Monitor Performance and Collect Feedback.

The project ends for the consultants when the handoff is completed, and they disengage. The handoff usually includes a formal document describing the current status of the system at the point in time including deliverables, suggestions for next steps and sustainment. 

Can the team celebrate that the project is over? Or should they wait until someone determines whether it is a successful adoption? Recall Step 2 of the Go-Live Strategy defined the end date of the transition period as well.  Did this include the expected date for being fully operational? By the way, who is responsible for declaring success or needs improvement?

Phase Three – Successful User Adoption

One more component of the overall project plan is User Adoption aka Phase 3.  In my experience, this is perhaps the most overlooked phase in redesigning quality systems.  Once training is delivered and the consultants leave, “life as normal” sort of returns with pockets of progress, “learning curve” deviations and loads of suggestions for “fixing” the new design. 

In this phase, the project plan expands Go-Live Step 5 into two main activities, initial user adoption results and sustaining the redesigned quality system through controlled continuous improvement feedback loops.

User Adoption: Did we succeed?

What kind of data/evidence will you use to confirm the success of the Redesigned Quality System?  Will you be relying on the CAPA Effectiveness Check statements to determine User Adoption success?  One word of caution here. These may be too narrowly focused on particular steps as it maps back to a single observation and does not provide enough evidence to tell a complete story just yet.  

What the System Owner really needs to know is:

  • Who is following the new process?  Who is still dragging their feet? Who is confused about how to proceed? Who needs help remembering what the changes are?
  • Do we have any early examples of how or where the new process is helping to produce positive results?
  • What is the value of those results?
  • How long do I have before I am forced to release the next set of “promised” revisions?

You Need a User Adoption Study

The purpose of the study is to get data both quantitative and qualitative to address the system owner’s questions.  This means the study needs to focus on identifying the specific changes (removed, added, and modified) and then collecting the evidence to evaluate how well those changes have been transferred into this “life as normal” stage.   Whether this means reconvening the design team or initiating a new subgroup of early adopters, user input into the tools, existing KPIs, new metrics, surveys, and who to interview is another excellent opportunity for users to be involved.

It also means keeping key stakeholders and the sponsor informed and up to date.  The “project may be over” however, the adoption has only just begun.  Feedback is essential to not only determine successful adoption but to also gather detailed information for continuous improvements that feed revisions.

“In my experience, [phase 3] is perhaps the most overlooked phase in redesigning quality systems.”

Vivian Bringslimark, HPIS Consulting, Inc.

Managing “New Normal”

Life as new normal has begun. The quality system is fully operational and Affected Users are now performing their tasks.  New normal is really about managing the new workflows and the status of the current resources to sustain the new system.  Are you able to sustain the new system or are requisitions pending for more full-time employees?

A screenshot of a cell phone

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why redesigned SOPs are more than a set of revised procedures

What existing performance metrics can you leverage? Perhaps it is only a matter a slight tweaking here or there to accommodate your redesigned quality system.  In some systems that have gone digital, brand new metrics and KPIs (key performing indicators) need to be established.  Most vendors will partner with their clients and recommend industry best practices around popular metrics in use.

Anticipate periodic revisions that come from corrective actions and from the Affected User groups.  Hold focus group meetings quarterly for the first year and then semi-annually the second year to stay on top of trends and possible performance challenges to prevent unexpected deviations.

Continuously Improve the Quality System

The redesigned quality system has to feed itself.  Identify and continuously monitor the key linkages (handoffs) between one system interface and the other.  Are they working or are they becoming the source of miscommunication between users? 

How many CAPA investigations have been initiated where the handoff may have been a contributing factor?  How many small or incremental changes has the quality system undergone in the course of a year?  When will it be time to remap the process and identify all the tweaks that have occurred? Would anyone recognize the differences?  I’m betting on savvy new hires to ring the change bell and raise our awareness.  We forget just how many changes can happen to a quality system over 1 – 2 years.

Summary

  • Any change we introduce into an organization must be aligned to fit the existing system or modify the system to accept the changes.
  • Quality Improvement Projects/ CAPA teams are no stranger to change and all that comes with changing old ways.  But managing change fatigue can wear us down and make us slow to outwardly embracing major change efforts. Include change management strategies that go beyond Awareness Training only.
  • This blog series outlined why some post-implementation issues can thwart our best designs for users and provided tips and suggestions to deploy during the project phases rather than waiting until post-launch to ensure User Adoption success. 

Here’s a recap of the series:

  • Blog # 1 – Redesigning Quality Systems: Achieving User Adoption
  • Blog # 2 – Manage Your Stakeholders and Users Expectations
  • Blog # 3 – Gap Assessments are Necessary for Redesign Projects but so is the right level of support
  • Blog # 4 – What to Expect When Processing Map with SMEs
  • Blog # 5 – Field Testing Your Final Draft of Redesigned SOPs and Forms: Helpful or Seen as unnecessary?
  • Blog # 6 – Change Management and It’s Little Cousin Training
  • Blog # 7 – Do I Really Need a GO-Live Strategy?
  • Blog # 8 – Is an Awareness Training Only Session Enough for Successful User Adoption?
  • Blog # 9 – So, We Went Live, What Happens Next?

Who is Vivian Bringslimark?

© HPIS Consulting, Inc.

Is an Awareness Training Session enough for successful User Adoption?

Note: This blog is part of an ongoing series. Blog # 7 – Go-Live Strategy introduces the 5 Steps.

Go-Live: Step 3 – Develop the Rollout Timeline and Training Schedules.

A redesign of the quality system SOPs more than likely resulted in significant changes in routine tasks.  What changed, what was removed, what was added that is truly new and what stayed the same? Simply reading the newest version in an e-document platform will not suffice as effective training.  Nor will reading the change history page or reviewing a marked-up version of SOP for the highlighted changes.  When your previously delivered change management sessions include this level of detail, then the content of your training session can focus more on the new process.  If successful user adoption is tied to the effectiveness check of your CAPAs, then the project team needs to discuss what the training rollout will look like.  

Identifying Critical Users

From the stakeholders’ analysis for Affected Users, consider who is directly affected and indirectly affected by the change in responsibilities. Which users are most critical to ensure success with adhering to the new steps and forms? I refer to them as the Primary Users who are directly affected. They are usually more functional in their responsibility rather by department titles or business units.  Another way to determine this is to review the responsibilities section of the new SOPs.  Who in your organization are these people? In this review, are there supporting and ancillary responsibilities with the steps and forms?  I call this group the Secondary Users that are indirectly affected.  Both sets of users need to be fully trained in their tasks and responsibilities in order to ensure that the new system will function per the SOPs. 

The Training Rollout

Training Roll Outs need to meet three different levels of Users needs.

The overarching question to address is whether or not everyone has to attend the training.  One awareness training session for both groups is extremely efficient but not nearly as effective if the training sessions were tailored based on the level of user need.  See figure at the right.  Within the indirectly affected group are the senior leadership team members. 

An executive briefing is more likely to be attended by these folks when it provides a summary of what they need to know only.  What does the general population need to know about these changes?   Keep this short and to the point. It’s the Primary Group of Users who need to not only be made aware of the changes but to also know how to execute the new forms.  Yes, this session is a bit longer in duration than Awareness Training and it should be.  These Users have more responsibilities for correct execution. 

Simply reading the newest version in an e-document platform will not suffice as effective training. Nor will reading the change history page or reviewing a marked-up version of SOP for the highlighted changes.

Vivian Bringslimark, HPIS Consulting, Inc.

Who is the Trainer?

Depending on the level of involvement of the Design Team members, the following minimal questions need to be addressed:

  • Should the Project Manager deliver any sessions?
  • Will we use Train the Trainer approach?
    • Where each design team member is assigned to deliver Awareness Training for their area of remit.
    • Do these members have platform skills to lead this session?
    • Will they be provided with a slide deck already prepared for them?
  • Solely the responsibility of the QA Training Department
    • Provided s/he was a member of the Design Team
  • What kind of Training schedule will we need?
    • Will we provide three different tiers to meet the needs of our Affected Users?

Did the Training Roll Out Meet the Learning Needs of Primary Users?

While the revised SOPs were in the change control queue, the design team for this client met to discuss the difference between Awareness Training and Primary Users Training. Briefly, the differences were:

Difference between Awareness Training and Primary Users Training Content

Awareness Training is more knowledge-based.  It tends to be information sharing and very passive until the Q & A session.  A knowledge check at the end is no assurance that there will not be any deviations.  Primary Users Training is intended to focus on the behavioral changes that will be needed for adoption back in the department. The session can be a workshop with real examples that are generated from the users as part of their concerns and questions. 

The design team concluded that the differences were significant enough to warrant two different classes based on the type of user.  The risk of deviations was too great and would send a negative message to the site leadership team about the new process design.  Early adopters were not at risk because they were already trained via their participation in the design team. 

The task of developing the Awareness Training and Primary Users materials was assigned to the instructional designer on the team.   Attending the Awareness Training would not be a substitute for participating in the Primary Users class.  However, attending the Primary Users class would automatically credit the Awareness Training requirement for users if they attended.

Given that condition, the Primary Users materials also included similar content from the Awareness Training and then expanded the level of detail to include the sequence of steps for executing associated new and revised forms.  The Primary Users class was designed to provide more in-depth discussion of the changes and to provide adequate time to become familiar enough with their responsibilities to minimize disruption on the day the procedures and forms go into effect. 

The system owner then scheduled all users to attend the Awareness Training.  He concluded that there would be too much confusion between which class to attend. Since Awareness Training was being delivered first due to a very short Go-Live window, it would be better that they received the same training or so he thought.  In addition, the system owner felt that all employees were actually Primary Users and would not attend the training session if it went past 60 minutes.  As a result, Primary Users were never identified, and no learner matrix was generated.   No one asked for more training until weeks after the SOPs and forms went into effect. 

A knowledge check at the end is no assurance that there will not be any deviations.

Vivian Bringslimark, HPIS Consulting, Inc.

But rather than schedule the Primary User class, Users who had questions or concerns stopped by the department for 1-1 help instead.  For weeks, the staff was interrupted from their daily tasks and was expected to conduct impromptu help sessions.  The intent of the Primary Users class was to provide a hands-on training workshop for their impacted documents and not have to stop and go find someone for help.  The slide deck for Primary Users was eventually uploaded to a shared drive.  When the department got tired of being interrupted, the system owner put out a general email with the link and redirected late adopters to the website link.  The slide deck was not designed to be a substitute manual. 

Had the design team followed through with identifying lead champions, the Primary Users training workshop would have been delivered to a small group of users who then could have fielded questions from their colleagues.  The original design team members did not agree to be change champions nor trainers for their departments.  They complained about their workload already being heavy and had no time to address implementation questions.  That was for the training department to deliver, they concluded.  And then reported back to management that their direct reports could not attend a second session on the revised procedures.

Stay tuned.  Next blog includes Steps 4 and 5 of the Go Live Strategy and wraps up this series.  Become a subscriber so you don’t miss any more blogs. 

Who is Vivian Bringslimark?

© HPIS Consulting, Inc.

Do I really need a Go-Live Strategy for Redesigned SOPs?

Develop Your Go-Live Strategy Before Opening up a Change Control Request

Don’t underestimate what Go-Live will look like the day the new SOPs go into effect.  The overall project plan may reflect one lined task – [Go-Live] and the date, but who is responsible for making it happen?  Doc Control administration hits a button and the eDoc system sends out a notification or perhaps folks find out about the revisions and effectiveness date from their LMS notification. What else needs to be done, you ask?  Actually, a lot of things and without a detailed plan of assigned tasks or a set of instructions, the first week of Go-Live could be disastrous if not managed well.  Whether it is broken down further in the project plan or contained in the communication strategy, the plan needs to drill down into specifying how tasks and activities will be managed, by whom and by when. 

5 Basic Steps for a GO-LIve Plan
Steps to take BEFORE draft SOPs are sent to Doc / Change Control

Go-Live: Step 1 – Transition Options

Most quality system redesigns include more than one SOP.  Sometimes the project includes multiple work instructions that are designed to work in tandem.  Releasing one without the other automatically creates a departure from the new SOP.  One approach design teams take is to release the package all at once.  Other teams decide to release serially, one after the other with timed intervals to manage the learning curve. Other approaches include pairs or high priority clusters similar to a wave or a phased tactic.  All have their advantages and disadvantages. 

And all need an impact assessment that examines the details about what will change, how that change will be handled and how many users will be involved.  In other words, how many tasks could be out of compliance when the procedure(s) goes into effect?  Will the release shut down the organization on Day 1?

Now vs. Later – Timing is Everything!

A few years ago, a client received a pretty involved FD-483.  One of the corrective actions was to enhance the Training Quality System.  So, a project team was deployed, process maps verbally approved, and the revised SOPs were in various stages of being ready for a field test.  The design team was concerned that SOP decisions for in-process drafts could impact the final drafted SOPs significantly. The team needed to be able to update a final draft SOP immediately without getting bogged down in their change control process.  Not to mention managing a new round of awareness training that could change a week later!

So, as part of the Go-Live strategy, a decision was made to schedule the release of the procedures all at once when the final set of SOPs were ready to go to Change Control.  It was determined (assessed), that too many little changes for the Training System would result in confusion, retention issues, and a paperwork nightmare controlling which version of the form was correct.  This is a popular option for design teams because the coordination of new changes happens on the same day and is much easier to track. Albeit the learning curve can be high as the site works on closing the size of their change gap.

During the development of the last set of SOPs, FDA conducted a follow-up visit for the FD-483.  One of the training CAPAs was not yet completed. It was waiting for the redesigned set of procedures to go into effect.  The new version would encompass this observation and essentially close it out.   Unfortunately, this incomplete CAPA created a hold for product to be released.  As a result, the priority to complete a retrospective qualification of 700(+) “trainers” derailed the Training Quality System project for close to 4 months.  Additional immediate fix CAPAs were also generated.  Ironically, these CAPAs could have been avoided if the design team chose the serial release option. 

Go-Live: Step 2 – Who Will Do What, When?

Establish roles, responsibilities, and priorities for the transition period.  This means identifying the beginning and end date for the transition from what we used to do to what we will do by what date. When do we anticipate being fully operational with the new procedures?  Is the end date automatically the day the procedures go into effect? Or is there a sequence of tasks that need to be executed before the Go-Live date? Have those tasks been assigned to individuals with clear expectations and due dates?

We’re Still Open During Our Construction Phase!

One client began their Go-Live Strategy with Step 2 to help assess the impact of the changes to her organization which dictated the decision to release each SOP serially; one at a time.  Using a worksheet, each targeted SOP was listed vertically while impact criteria were listed horizontally.  The team need to “see” associated form numbers, cross-referenced SOPs, the actual impact, mitigation steps, how to transition, other impacted documents, disposition status and dates of those other documents and of course next steps. 

With careful examination of what tasks, forms, and steps were actually changing, the Project Lead was able to realistically determine how much time it would take to mitigate the impact.  Subtasks such as final form revisions and revisions to other documents were being monitored and project tracked as well. 

This information shaped a pragmatic and timed sequence of events. Resulting in the conclusion that releasing one SOP at a time was the most effective way to transition into the future state with minimal disruption despite that the overall policy document would have to be revised multiple times during the transition period.  The project lead volunteered to be the taskmaster on those subsequent policy changes and updates for the stakeholder briefings.

What else needs to be done, you ask? Actually, a lot of things and without a detailed plan of assigned tasks or a set of instructions, the first week of Go-Live could be disastrous if not managed well.

Vivian Bringslimark, HPIS Consulting, Inc.

Included in this impact assessment were numerous immediate response CAPA corrective actions.  It was vital to ensure that future state procedures did not eliminate commitments that were made to the agency.  These CAPAs resulted in subprojects that also needed to be managed within the overall quality system redesign project.  Given the scope of these projects, completion dates were projected to be 6 – 9 months out.  Yet, the future state quality system procedures were expected to be operational way before these subprojects came to fruition. 

In essence, the day the SOPs went into effect, the site would automatically be out of compliance and numerous deviations would have to be initiated.  To manage the SOP change gap, an overarching CAPA was approved to allow the organization to meet agency milestones and move forward with the new process while working on the subprojects.   With each planned release of a future state SOP, the impact assessment worksheet was updated with feedback including future release notes.

Be sure to be notified for the next blog – Step 3 – Training Rollout. Subscribe to Theory vs. Practice in the left sidebar menu.

Catch up on the previous redesigned Quality Systems blogs here.

Who is Vivian Bringslimark?

© HPIS Consulting, Inc.  All rights reserved.

Change Management and It’s Little Cousin Training

Training can be considered a change in what the learner knows now | can do now and what s/he knows and does afterward.  Training can close these gaps when knowledge and skill are lacking.  Thus, a trainer has a dual role: trainer and change agent. While on the surface, the actions a trainer takes looks like change management, it is a sub-part of the larger change management plan.  The scope is narrower.  It is focused only on the training content.  But the expectations for successful transfer back to the job and improved organizational results remain the same. One allocated and approved session designed and delivered by the training department is supposed to shift years of a mindset, alter behaviors and change the company’s culture.  Amazing!

This expectancy or shall I say management assumption is very real and prevalent in fast-moving start-up companies whose leaders claim to have a limited budget for “training” and no time to sit in frivolous meetings planning “the people side” of change.  I’m supposed to be grateful that I get an hour session.  What happens next also amazes me.  Training on the proposed system changes is reduced to an hour-long awareness session on the SOPs that have already gone into effect and folks are told – “Go with the flow. Change is part of our everyday life around here.  Get with it or get out”.  And here’s the rub for me, errors rise, deviations spike, users are annoyed, pissed off or disenfranchised and management blames the trainer for a failed change effort. Wow! Is this the management support that was promised to folks at the town hall meetings? 

The bigger the redesigned quality system changes are, the more you need to consider beyond just training awareness on the SOPs.  Assess the size of the change gap and the impact the new design will have on the culture; “the way we normally handle changes around here”.  Training rollout sessions are already time-crunched.  There is not enough time “allowable” to manage all the other non-training change issues like feelings, job security concerns, why the need for change retorts, lack of supervisory support post-training, etc. that actually get in the way of a successful learning transfer. And later create hurdles for improvement results.

Let’s look at the HPISC 5 Step Change Management Plan and apply it to quality system redesign projects.  (See the sidebar below.)

5 necessary parts of a Change Management Plan

QS Change Management Plan Considerations

1. Why is the change needed?

  • This may be really obvious when the site receives a Warning Letter.  But an explanation of how this became a driving force for the needed changes will do wonders for your employees to feel the urgency about the change.

2. What is really changing?

  • Will the changes be incremental or a huge transformational change such as “changing the quality culture”?
  • How are these SOP changes part of the GMP culture?

3. What are the pros and cons of the change?

  • Who benefits and who loses?
  • Are customers hurt or helped?
  • What are the stakeholder’s benefits from the change?
  • What about the benefits for the primary users?

4. What does success look like?

  • What will the outcomes of the change look like?
  • How will you and others know if the change has been successful?
  • What benchmarks will help you track progress?
  • When is the day or timepoint we get to declare success?

5. What other initiatives are we competing with

  • And how will adding the new change requirements impact already heavy workloads?

Will Awareness Training be the only vehicle for announcing the new changes?

Are the answers to the change management questions sitting with the trainer/training department or with the site leadership team?  Perhaps the answers can be found within the steering committee members?  Is the trainer supposed to address all of these questions in a 60-minute awareness session that also includes the SOP changes?  If successful user adoption is paramount to your strategic action plan, warning letter remediation plan, or CRL commitment response, you need to ensure that change management messages regarding these changes are included in the overall communication plan.  Don’t just rely on the design team members to deliver these messages casually at huddle updates.  That is not a communication plan. 

“The bigger the redesigned quality system changes are, the more you need to consider beyond just training awareness on the SOPs”.

Vivian Bringslimark, HPIS Consulting, Inc.

The design team with the aid of the project manager needs to schedule special change management sessions where the Affected Users are briefed on the status of the project and the answers to the questions listed above addressed.  Some leaders do not want to “waste time” on these sessions.  They are concerned that it will become a gripe session.  Instead, they think it’s better to just present the users with the revised procedures.  There’s less time to fret and grumble over it.

There is a false belief that once the Affected Users see the changes in a QA-locked down version, they will follow them “because it’s now in the approved SOP”.  Forced acceptance is not a change management strategy despite rampant practice in our industry. If awareness training will be the first time affected users are learning about significant system changes and the “Go-Live” date, be prepared to receive A LOT OF FEEDBACK FROM UPPER MANAGEMENT regarding how awful the awareness training sessions went. 

“Change is disturbing when it is done to us, exhilarating when it is done by us”.

Rosabeth Kanter, 1984, p. 64.

Who is Vivian Bringslimark?

This is 6th in the Redesigning Quality Systems series.

Camp, RR, Blanchard, PN. & Huszczo. Toward a More Organizationally Effective Training Strategy & Practice. New Jersey: Prentice-Hall, 1986.

Kanter, RM. The Change Masters. New York: Simon and Schuster, 1984, 64.

© HPIS Consulting, Inc.  All rights reserved.

Field Testing Your Final Draft of Redesigned SOPs and Forms: Helpful or Seen as Unnecessary?

Redesigned procedures impact all personnel, temporary employees, consultants, and contractors involved in the manufacture of GMP drug products.  However, inviting all affected users to review the proposed changes is not practical; nor efficient.  Neither is skipping the advanced review while hoping that the draft SOPs will be approved quickly.  This is a surefire way to derail the project.  And just might add to the resistance for changed behavior these procedures are seeking. 

I’m amazed at all the feedback that surfaces after the procedures go into effect.  A field test is an effective vehicle to generate user feedback that is constructive, timely and can be used to evaluate concerns before the procedures go live. It can be as simple as an “Open House” with silent feedback forms to a full-fledged Pilot Program with formal feedback.

A pilot would be ideal.  What better way to gauge the impact of the desired state than to pilot it in the workflow? But, this would require two processes (the current one and the proposed one) to be executed simultaneously. What a documentation nightmare this would cause; not to mention the lack of approval for the plan.  An alternative approach is to invite impacted department heads, business unit leaders and a handful of affected SMEs to briefing meetings. 

Benefits:

  • The scope of the meeting is focused on one task.
  • The project manager (PM) controls the copies of draft SOPs and Forms.
  • The PM provides a forum for discussion by providing the updates in advance and still has development time to consider the feedback before submitting to Change Control/ Document Control.
  • Invited folks are “now in the know”.
  • Expedites change control review and approval workflow later on.

An Open House Invitation to Field Test the Process Redesign

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Invite users to walk through the design changes BEFORE it goes to change control

The goal of this Field Test was to provide targeted feedback sessions with identified internal customers before new procedures became effective.  Three feedback rounds were delivered each designed to achieve targeted stakeholder and user feedback.

  • Session # 1 – Formal Project Update and sharing of Communication Plan for the Project.  The first feedback form was developed to capture participants’ observations in general.
  • Session # 2 – Simulated Scenarios that challenged the future state process.  Scenarios included routine processes and new situations such as major changes to an SOP for example. Two feedback forms were used: one for procedural steps and a second one for the proposed forms.
  • Session # 3 – Silent Feedback where users provided their comments, questions, concerns and overall experience.  Similar to a “brown paper exercise”, the entire process was pasted on the wall showing actual steps, decision points, documentation, and interfaces with other systems. The exercise got users involved and they commented on strengths, weaknesses and further opportunities.  By enlarging the process maps to wall size, users literally walked through the process and used a feedback form specifically for this activity.
  • The rounds were scheduled in advance to allow the design team to leverage the feedback from each round and make changes before the next round of feedback began. Participation in the previous round was a prerequisite for attending the next round to minimize having to brief new participants on the project; thus, keeping the sessions short and focused.

Get caught up on the series here. 

Who is Vivian Bringslimark?

© HPIS Consulting, Inc.  All rights reserved.

What to expect when process mapping with SMEs as teammates

Process Mapping the Redesign

While there is value in mapping the current state of the quality system, teams can often get bogged down in disagreements over the level of detail and the sequence of explicit steps.  They miss the point that a future state design is our desired outcome from this stage.  The danger lies in members becoming so entrenched in the current state, that they have difficulty envisioning any other possibilities including a better future process for the named quality system.  The gap assessment interviews and report findings were the opportunity to focus on the current state of affairs.

To keep the project moving forward and team members engaged, begin the process mapping sessions with a marked-up, “proposed” future state model and have the design team members identify what needs to change, be eliminated or added using the gap assessment report.  During these discussions, another layer of discovery is often revealed.  The project manager frequently learns that recommended steps suggested forms, etc. were previously included in the SOPs only to have been removed in later change control requests with limited or no rationale provided.

Use process maps to work out the process conceptually first

Occasionally, one or two members will find themselves stuck in “the way we do it here” mindset and cannot embrace the change(s) being proposed.  This is when the project manager needs to switch roles and become a facilitator (or hire one) to put into practice the training concepts from team-building like staying open-minded, respecting different viewpoints, actively listening to each other and reaching consensus.

Change is a process.  As a project manager, I could just come in and tell the design team “this is the future state and these are the SOPs and new forms you will be following.  Now, will someone help me get this packet of documents into the change control queue? We have FDA due dates to meet”.  I don’t envision any of my team will raise their hand.  Would you?  And yet, most Quality Systems redesign projects are executed this way under the guise of the SME team.  If the design team isn’t buying the need for changes, how can I expect the rest of the users to embrace it, let alone comply with the new design?

“This Will Never Work Here!”

Another barrier to staying focused on future state mindset is succumbing to the fear that “management will never buy into any of this”. A good project manager will maintain a project issues log that becomes the agenda for weekly check-ins with the sponsor.  This is why it so crucial to keep the sponsor up to date with anticipated barriers and challenges sooner rather than later during the implementation stage.  It is also wise to reflect the tracking of these items in the written project status updates.  It is the responsibility of the project manager to track resolution and report back to the team in order to keep momentum, encouragement and continued trust within the team.

If the design team isn’t buying the need for changes, how can I expect the rest of the users to embrace it, let alone comply with the new design?

Vivian Bringslimark, HPIS Consulting, Inc.

But we’ve already got our process in place!”

Once in a while, I am presented with a range of progress on implementing a Robust Training System, where some departments are very far along with their executed tasks and some departments haven’t even begun.  It’s like a race to see who crosses the finish line first.  Being first allows the department to carve its way as the best practice and the process for the rest of the organization to follow.  AKA – they like to think they can influence the policy and/or SOPs with little regard for the nuances of other department’s unique processes. So, be mindful of resistance to adapt, adjust, or even participate in design team meetings, when one group is heavily entrenched in their departmental training practices, especially the unwritten ones.

Spend the team’s meeting time wisely and focus on the process maps first.  Get a consensus on the flow diagrams before proceeding to the SOPs.  This accomplishes a number of benefits.  Having a process flow diagram keeps the discussion centered on the process conceptually and not hung up in SOP semantics.  Wordsmithing comes after an agreement for the future state has been achieved. 

Another barrier to staying focused on future state mindset is succumbing to the fear that “management will never buy into any of this”.

Vivian Bringslimark, HPIS Consulting, Inc.

Include your sponsor and select executive stakeholders on the update.  This is the opportunity to inform them about major changes and anticipated impact on the organization. Be sure to speak about eliminated redundancies and/or any anticipated efficiencies gained from the future state.  Keep the discussion at the conceptual level for now.  But also be prepared to field specific or detailed concerns i.e. will this result in a change of headcount?  Note: If your sponsor or key executive stakeholder prefers “seeing” the process via printed SOP steps, accommodate this preference and have a good working draft prepared.

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Who is Vivian Bringslimark?

(c) HPIS Consulting, Inc.

Gap Assessments are necessary for QS redesign projects but so is the right level of support

This is the 3rd blog in the on-going Redesign Quality Systems: Achieving Successful User Adoption series. Visit Blog 1 and 2 here.

Assessments – “Truth Be Told”

Assessing the current state of the targeted quality system is analogous to collecting the “voice of the customer” input.  Discovering what is and is not working is vital to ensuring a successful redesign and ultimately user adoption. This is more than a review of the SOPs and forms; however.  Interviews are key to this phase of the project.  From the system owner to primary users, QA staff and even the LMS or the eDoc administrator are essential.  The more cross functional the input, the better the confirmation of the “data” and the “evidence”.  Which in turn, provides a truer gap assessment.

Most interviewees know the system’s weaknesses and they know how to fix it.  But they are frustrated with ignored attempts to change it.  Many simply give up trying to get it changed on their own or within their circle of responsibility.  So, when quality systems interviews are being conducted with an external consultant, some are eager to share the “dirt” on just how broken the system really is.  And some of the “fixes” are political and can only be handled when trust has been earned or when the sponsor deems it so.

We recognize Training is important but …

A small vitamin and supplements company set out to become a commercial manufacturer of pharmaceutical drug products.  Naturally, their quality systems were not robust enough to meet 21CFR 211 code of regulations. So, assessments were conducted for the major quality systems.  The Training Quality System assessment revealed several positive activities that were enabling current success and a lot of gaps that would need to be addressed to meet regulatory expectations for today’s pharmaceuticals companies. 

The sponsor explained that without top leadership support (meaning physically show up and attend this debriefing meeting), no one else would show up nor take the project seriously.

The sponsor routed the Training Gap Assessment Report to his peers and the CEO with an invitation to attend the first in-person briefing.  No one showed up except the sponsor, his direct reports and the consultant.  The meeting was rescheduled for a month later when all executives’ schedules showed availability.  One month later, the sponsor learned that key executives would be out of office during the meeting, so he postponed the briefing indefinitely.

The sponsor then arranged for a one-on-one follow-up session with the CEO and explained that without top leadership support (meaning physically show up and attend this debriefing meeting), no one else would show up nor take the project seriously. He also reiterated that in order to grow the business as intended, resources needed to be hired and the quality systems including Training needed immediate prioritization.  Or else the company would not receive approval to manufacture and could further impact its current relationship with the agency.

Three months later the meeting was scheduled.  However, the agenda took on a different focus. Particularly, the collaboration benefits of working cross-functionally with department managers and the shared ownership for the Training Quality System.  More specifically, the training project was not just a QA program, but a robust training system that impacts all employees.  This time the meeting occurred and was fully attended by all invitees.  

Change Readiness for the Design Team

With the briefing finally conducted, the sponsor explained to the consultant, that the “Design Team of SMEs” had very limited experience working cross-functionally or as a team. They knew even less about project management concepts like scope and project charters and they lacked fundamental concepts like quality systems and systems-based inspections.  And they did not know how to process map. They had been silo’d far too long.

SME Readiness Curriculum
Design Team of SMEs Readiness Curriculum

The consultant’s background included curricula building, instructional design, and quality systems redesign experience. She sketched a brief outline of the mini-curriculum for the Design Team of SMEs and the Sponsor agreed.   Over the next few weeks, they used their meeting time to work through the 4 introductory lessons.  And as a team, they used the “live” aspects of the project work to illustrate the concept and apply its principles to the progress and development of their team.   In essence, they were taught just what they needed to know at the moment the project needed it, similar to learning in the flow of work.  Four weeks later, the team was ready to begin their process mapping sessions together.

How Big is the Change Readiness Gap?

Who is Vivian Bringslimark?

(c) HPIS Consulting, Inc. All rights reserved.

Manage Your Stakeholders and Users Expectations thoughout the Entire QS Redesign Project

Engage Users from the Beginning and Throughout the Redesign Project

When Quality System redesign CAPAs are project managed using the 5 typical phases (see diagram), the progression of the project is easier to track and report status updates to stakeholders.

Involve Users throughout all phases and stages

Tapping into the different types of users for their input from the start of the project advances their engagement with the project along with the phases.

For example, during the Initiate Phase, an assessment of the current procedures, processes, and practices can include a variety of users, not necessarily the SMEs or system owners only. 

But without an organized and approved communication plan for each of these phases /stages, rumors evolve, misinformation circulates and the success of the new system being adopted is put into jeopardy.

Managing Stakeholders Expectations

A popular activity from the project management toolbox is to conduct a stakeholder analysis whereby a list of affected folks is captured.  And their role with the project team is clarified.  A handy acronym called PARIS can be followed: Participant, Accountable/Owner, Reviewer, Input Required, Sign-off required before proceeding. Also popular is a RACI matrix chart where;

  • R = Responsible
  • A = Accountable
  • C = Consulted
  • I = Informed.

So who are the stakeholders for the quality systems? In a quality system redesign, the following types of stakeholders are usually present,

  • Sponsor
  • System Owner
  • Managers
  • QA, HR, IT if it includes technology platform or upgrades
  • All affected Users.

Additionally, team members can identify their stakeholders’ relationship to the project which can be very helpful when the project hits barriers and is sent derailing off timelines.

Executive Sponsorship is a Key Success Factor

Quality systems by their nature are interdependent and frequently cross into boundaries of other departments’ workflow. Sponsorship is needed especially if the changes are significant, there are multiple quality system projects happening at the same time and other site initiatives all vying for the same resources.  Every quality system redesign project needs an executive sponsor:

  • To approve resource requests
  • To become aware of the impact of the changes being proposed
  • To be informed with the most current status

Thus, naming the sponsor holds this person accountable for the expected results. Thereby endorsing the project and becoming an advocate for the team’s work.

The Communication Strategy

Once the stakeholders have been identified and categorized, the next activity is to determine what level of involvement is necessary.  Ask them directly.  Ask them how often and in what format do they prefer. If you think one size fits all stakeholders, think again.  Many a project has derailed, missed its goal or became defunct as a result of miscommunication and misunderstandings.  Often stakeholders do not interact directly with the team.  It’s the Project Manager’s responsibility to be the interface.  One way to achieve this is to conduct briefings.

Briefings as a Communication Medium

The purpose of briefings is to provide updates on the project regarding timelines, milestones, deliverables and unresolved issues.  The expected results for a redesigned quality system are not always clearly understood because of confusing priorities and diluted focus.

Not all briefings have to be conducted in person via meeting time and conference room space.  Storyboard updates can be routed electronically.  Weekly updates, interim reports, and even significant project meeting minutes can be useful for briefing the stakeholders.  Make sure you match the type with the frequency as per your stakeholder analysis and communications strategy.  As the project progresses through its phases, stakeholders’ roles can change.  Use these briefings to continuously check-in for feedback and adjustment with frequency and format.

Routine Stakeholder Briefings: An example in practice

One client of mine decided to leverage the cadence of their standing update meetings and used the proposed system changes as the focus of the agenda.  As each procedure progressed to working-draft status, the Project Manager invited the key stakeholders and guest users to the meeting.

She diligently took notes in the drafts, captured their concerns on the parking lot flipchart and brought up issues from the design team for further exploration and discussion among the system owners. Then she invited them back to the next briefing to review the newest SOP drafts and secured a verbal approval for the draft so that the draft did not get hung up in disagreements among the approvers during formal change control. 

They used the briefings to work through their issues and concerns.  She would point to where the previous discussion was now resolved and often, she would provide an explanation as to why a concern or an issue did not get acknowledged in the procedures as discussed.  Participation in these meetings was generally good; a few key leaders were absent from time to time.  So, occasionally one-on-one meetings were scheduled for critical approvers.

In the next blog, I will walk through assessments in more detail. – VB

Feeling a bit lost with the sequence of this blog? It is second in the Redesigned Quality Systems series. Check out the kick-off blog here.

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Who is Vivian Bringslimark?

(c) HPIS Consulting, Inc. All rights reserved.

Redesigning Quality Systems: Achieving Successful User Adoption

What really happens to “change initiatives” after the CAPA due dates are met? Is the project done because the consultants leave? Or is it when the new priority has been re-directed to another pressing issue? What kind of post-implementation support is there for the leader charged with the ultimate responsibility for the improved performance of the redesigned quality system(s)?

But how did we get here?

The Compliance Situation

Whether it was a Warning Letter, a series of problematic 483 Inspections, or an OAI letter from FDA, you are now facing a compliance situation that has become your #1 priority.  If you are like most companies in this situation, Quality Improvement (QIP) Teams or CAPA groups are formed and are typically managed with an outside Compliance Consulting firm that is leading the overall compliance strategy using a popular 5 phased project plan.  See the visual example below.

Commonly used project phases for quality systems stages

Congratulations on taking action to quickly rectify your status with the agency.  In most cases, the redesign of one of more quality systems is part of the commitments made to the FDA, sometimes with very aggressive due dates.

CAPA Teams Produce Good Work

The individuals assigned to these teams collaborate on the necessary decisions to redesign current procedures and produce streamlined processes that link the inputs and outputs of key critical quality systems.  Team members trace and re-trace the process several times to challenge their thinking and include steps for non-routine situations that are known to happen occasionally.  They examine how the current forms will be used to ensure that the right information is captured and forwarded on to the next system when required.  For some system redesigns, new forms need to be created or undergo significant modifications that result in better compliance to form requirements. 

When Due Dates Are Met

Is there a collective sigh of relief?  Is the project now completed?  It might appear that way since the consultants have left and the new SOPs are in effect.  The mindset at this point may be akin to: “So long as we met the due dates and everyone has been trained, the new system redesign should run smoothly, right?”  Ideally yes, but the reality is no.  I often hear comments like these: “even though we trained everyone and sent out GO-LIVE emails, there is still a lot of confusion.” Another classic one is “the learning curve for new system changes is expected to be high initially considering how many changes we made.”

So what happened?  Was there a rush to complete the awareness training and collect knowledge checks as evidence of effective training?  It is no surprise that training on the new procedures follows the redesign.  But what is a surprise is when the Training Group is notified to make it all happen just days before the due date. 

When is the Training Group invited to the project meetings?

Often the Training Group is late to the planning conversations and sometimes very late to the rollout discussions. There’s never enough time to deliver a proper training session, so in 60 minutes or less, folks are supposed to have all their concerns addressed and get “trained” on all the changes. 

Suggestions and new ideas are captured for the “next revision” because it’s “kind of too late” to revise the procedures at this point.  And when the deviations start racking up, we sigh, shrug our shoulders and check the box for human error/learning curve.  There is a better way to manage the rollout.

This new blog series will examine why “training only roll-outs” are not enough to gain 100% participation and compliance with changes associated with Quality Improvement Plans (QIP) / Continuous Improvement Plans  / Strategic Action Plans. 

I often hear comments like these: “even though we trained everyone and sent out GO-LIVE emails, there is still a lot of confusion.”

I will include descriptions of additional project tasks/actions that need to be designed, planned for and incorporated into the overall QIP that are often left out or neglected. One such area is Affected Users

In this blog series, I will also identify several opportunities for the inclusion of Affected Users and how best to include them throughout the project phases. The series will wrap up with additional blogs on suggestions for maintaining the new changes for sustained performance improvement. 

Sign up now at the left sidebar to ensure you don’t miss an issue!  -VB

BONUS Material available

You might be interested in reading this BioPharma article about Quality Systems.

Looking for Remediation support? Check out these items in the HPISC library.

Who is Vivian Bringslimark?

(c) HPIS Consulting, Inc. All rights reserved.