PICS
Scope:
A comprehensive program for both facilitating a professional environment and providing a system to collect and track all reports to ensure accountability and follow-through.
Purpose:
The Tulane University School of Medicine (SOM) is committed to creating and maintaining a positive and respectful environment for its faculty, learners and staff by holding accountable those who do not follow the tenets of professional workplace behavior. The SOM Guiding Principles outline our prioritized core values and link them to behavioral expectations. Each year, all members of our community will acknowledge receipt of these principles. An emphasis has been placed on recognizing those individuals with exemplary behavior and who are role models for professionalism.
The Professionalism/Environment of Learning Program (PELP) is designed to facilitate the creation and maintenance of an environment that is professional, respectful, inclusive, and intellectually stimulating. The PELP allows individuals to both recognize exemplary behavior as well as submit concerns about all aspects of the learning environment.
The program receives all concerns, which can be submitted through a variety of mechanisms, and documents and records them in a confidential database. Each report is reviewed and managed following established algorithms, approved by the PELP Advisory Board. An essential assumption is that all members of our community do not intend harm, rather may need education and awareness of the impact of their actions. Thus, early intervention is key to prevent continued or escalated unprofessional behavior.
Goals:
1. Facilitate a professional and inclusive learning/work environment based on our Guiding Principles.
2. Provide consistent educational opportunities for all members of our community.
3. Provide a clear and transparent process for reviewing and resolving all submissions.
4. Provide a fair system to ensure accountability of all members of our community.
5. Build and maintain trust by making available all relevant data and metrics to ensure the integrity of the program.
6. Ensure confidentiality and minimize fear of retaliation.
7. Provide oversight to ensure resources are provided to units with recurrent concerns.
Reporting of Exceptional Behavior: How to Report
Exemplary treatment of a learner or any member of the learning environment, either experienced or witnessed, can be reported utilizing the Kudos Form.
Exemplary behavior is essential for the growth of a more accountable, professional environment. Therefore, those who have received 10 or more exceptional reports will be recognized by the Dean and inducted into the 10 Owls Society.
For students, residents or faculty:
Perceived inappropriate treatment of a learner or any member of the learning environment, either experienced or witnessed, should be reported by one or more of the following methods:
- In writing utilizing the Professionalism Concern Form. If the incident involves perceived harassment or discrimination, the reporter should select the Tulane University Campus Reporting Form link to send the report directly to the Title IX Coordinator and/or the Office of Institutional Equity (OIE) as required by federal law. Reports submitted to the Professionalism Program that are deemed to include harassment or discrimination will be forwarded to OIE.
For students only:
In addition to the methods listed above, students have the opportunity to report perceived concerning behavior by one or more of the following methods:
- Verbally or in writing to the course or clerkship director of the learner’s course. The PELP encourages students to report concerns directly. However, after discussing concerns with students, course/clerkship directors are encouraged to submit a Professionalism Concern Form. This will allow for entering of the concern into the tracking database and initiation of the review process.
- On end‐of‐course and clerkship evaluations. All student evaluations include a link to the Professionalism Program reporting form so that students may report concerns directly to initiate the review process. Students have the option to delay review of the report to eliminate concerns regarding potential retaliation being reflected in their grade for the course or clerkship.
If requested, all reports received will be kept anonymous and confidential. Anonymous reports will be reviewed to the extent that specific information is provided. Please note that full disclosure of the persons involved and the behaviors witnessed can lead to more effective action to correct the problem. Therefore, reporting the names of all individuals involved is strongly encouraged.
The identity of learners reporting inappropriate treatment can often be protected by delaying action on the report until the learner is no longer vulnerable. Each of the reporting mechanisms described above allows the learner to request delayed action on the report. Please note, however, that time delays in addressing an incident may lessen the impact of the intervention.
The establishment of a safe environment is a quality improvement initiative and therefore, all reporting is legally non-discoverable.
The School and the University will keep confidential all records of complaints and investigations to the extent permitted by law. To reiterate, behaviors that violate Title IX of the 1972 Education Amendments to the Higher Education Act, which includes discrimination or harassment based on sex or gender, must be reported by any University official so they can be promptly acted upon in compliance with federal law.
If a report suggests discrimination, the School is required to notify the University’s Office of Institutional Equity so that an investigation may be initiated.
Behaviors that pose an immediate danger to others (e.g., violence or threats of physical violence, illegal drug use by caregivers in the clinical setting, deliberate violation of patient safety procedures) or are illegal (e.g., stealing narcotics, falsifying patient records) must also result in immediate reporting so that action can be taken.
The success of PELP in safe‐guarding the learning environment depends on the timely reporting of incidents of inappropriate treatment. In all cases, retaliation, or the encouragement of another to retaliate against the person making such a report will be considered a breach of professionalism and will be addressed accordingly.
Intentional false or malicious reports of concerning behaviors will not be tolerated and will be handled as a disciplinary matter in the learner’s program. All reports of concerning behavior will be handled confidentially, with the exceptions noted above, and in a manner that affords due process.
All reports will be reviewed by the TRIO and triaged using the established professionalism protocols for intervention. If requested by the individual reporting, the timing of a review can be adjusted or delayed to relieve fear of intimidation or retaliation. However, if the concern involves behavior that suggests a violation of Title IX or imminent danger, the report will be referred to the Office of Institutional Equity without delay. We encourage all reports to be as detailed as possible to allow for a complete review.
Processes for review and follow up will vary depending upon the situation and are summarized as follows:
1. Reports made by Student Learners* about:
2. Reports made by Resident Learners* about:
- Another resident/fellow: The TRIO will determine the level of offense and proceed by using the established professionalism protocol for intervention. The report will be sent to the Program Director of the resident’s/fellow’s program and will be addressed according to the department or program's policy. The Chair of the GMEC Professionalism Subcommittee and the DIO will also be notified of the complaint. A resolution report is expected to be returned by the Program Director to the TRIO and Program Administrator.
- Staff and/or clinical site: The TRIO will review the report and determine the best course of action, which may include notifying the hospital’s Chief Medical Officer, Human Resources office, or clinical site liaison. A resolution report from the hospital designee is expected to be returned to the TRIO and Program Administrator.
- Faculty: The TRIO will determine the level of offense and proceed by using the established professionalism remediation protocol for intervention. The TRIO will assign the report to a peer messenger. If not the first offense, the report may be escalated following the pyramid algorithm. The TRIO may also notify the appropriate Chair and, if needed, the Dean. A resolution report is expected to be returned to the TRIO and Program Administrator.
- A department: The TRIO will determine the level of offense and proceed by using the established professionalism remediation protocol for intervention. The report will be sent to the Department Chair, Chair of the GMEC Professionalism Subcommittee, and the DIO. A resolution report is expected to be returned to the TRIO and Program Administrator.
- A program, program director, and/or chair: The TRIO will determine the level of offense and proceed by using the established professionalism remediation protocol for intervention. The report will be sent to the Chair of the GMEC Professionalism Subcommittee and the DIO. A resolution report is expected to be returned to the TRIO and Program Administrator.
*All reports involving residents/fellows will be shared with the Chair of the GMEC Professionalism Subcommittee, as well as the DIO.
3. Reports made by Faculty about:
- A resident/fellow: The TRIO will determine the level of offense and proceed by using the established professionalism remediation protocol for intervention. The report will be sent to the Program Director of the resident’s/fellow’s program and will be addressed according to the department or program's policy. The Chair of the GMEC Professionalism Subcommittee and the DIO will also be notified of the complaint. A resolution report is expected to be returned by the Program Director to the TRIO and Program Administrator.
- Another faculty: The TRIO will determine the level of offense and proceed by using the established professionalism remediation protocol for intervention. The TRIO will assign the report to a peer messenger. If not the first offense, the report may be escalated following the Pyramid for Graduated Intervention, and the TRIO may also notify the appropriate Chair and, if needed, the Dean. A resolution report is expected to be returned to the TRIO and Program Administrator.
- Staff in the SOM and/or clinical site: The TRIO will review the report and determine the best course of action, which may include notifying the hospital's Chief Medical Officer, Human Resources office, or appropriate unit at that facility. A resolution report from the hospital designee is expected to be returned to the TRIO and Program Administrator.
- A department: The TRIO will determine the level of offense and proceed by using the established professionalism remediation protocol for intervention. The report will be sent to the department Chair/Dean. A resolution report is expected to be returned by the Chair to the TRIO and Program Administrator.
- A student: The Program Administrator will provide the report to the Associate Dean for Student Affairs, administrative leadership of the Office of Academic Affairs, and if requested, the Director of Student Support and Wellness. The Associate Dean of Student Affairs and/or Director of Student Support and Wellness (if requested) will conduct the review and provide intervention (if indicated), bringing in appropriate persons as needed. At the discretion of the Professionalism Committee, other department leadership may be notified as well. A resolution report is expected to be returned by the Associate Dean for Student Affairs to the TRIO and Program Administrator.
4. Reports made by BMS & PhD students* about:
- Another student: The TRIO will determine the level of offense and proceed by using the established professionalism remediation protocol for intervention. The report will be sent to the Director of BMS and the Academic and Career Advisor for BMS. A resolution report is expected to be returned to the TRIO and Program Administrator.
- A faculty: The TRIO will determine the level of offense and proceed by using the established professionalism remediation protocol for intervention. The TRIO will assign the report to a peer messenger. If not the first offense, the report may be escalated following the Pyramid for Graduated Intervention, and the TRIO may also notify the appropriate Chair and, if needed, the Dean. A resolution report is expected to be returned to the TRIO and Program Administrator.
- Staff in the SOM and/or lab site: The TRIO will determine the level of offense and proceed by using the established professionalism remediation protocol for intervention. The report will be sent to the Director of the lab. A resolution report is expected to be returned by the lab director to the TRIO and Program Administrator.
- A department: The TRIO will determine the level of offense and proceed by using the established professionalism remediation protocol for intervention. The report will be sent to the department Chair. A resolution report is expected to be returned by the Chair to the TRIO and Program Administrator.
- The Director of BMS: The Program Administrator will provide the report to the Executive Dean. A resolution report is expected to be returned by the Executive Dean to the TRIO and Program Administrator.
*All reports involving BMS & PhD students will be shared with the BMS Director and Academic & Career Advisor.
5. Reports made about a faculty member by non-trainees: The TRIO will determine the level of offense and proceed by using the established professionalism remediation protocol for intervention. If the first offense and not egregious in nature, the TRIO will assign to a peer messenger. If not the first offense, the report may be escalated following the Pyramid for Graduated Intervention and the TRIO may also notify the appropriate Chair and if needed, the Dean. A resolution report is expected to be returned to the TRIO and Program Administrator.
6. Reports made about the Dean of the School of Medicine or other senior SOM administrators: The TRIO will determine the level of offense and proceed using the established professionalism remediation protocol for intervention. The TRIO will assign professionalism concerns reported about the Dean or other senior administrators to a member(s) of the SOM Executive Faculty, the University Provost/Senior Vice President for Academic Affairs, or the President of the University. A resolution report is expected to be returned to the TRIO and Program Administrator.
7. OIE Process
In all cases, the party responsible for addressing the concern will formally notify the Professionalism Program Administrator that the intervention is complete. The person who reported the inappropriate treatment, if identified, will be notified that action has been taken on the report. Specific details of any action may not generally be revealed.
On a quarterly basis, a de-identified summary will be presented and reviewed by the Professionalism Advisory Board. An overall summary will be published quarterly for all learners and faculty on the Professionalism/Environment of Learning Program website. A timely review will allow for early intervention for those individuals with recurrent issues. The tracking will include a rolling 36-month trend.
