the development, implementation, and results
DESCRIPTION
TRANSCRIPT
The Development, Implementation, and Results
of Tenet Healthcare’s
Commitment to Quality Initiative
The Development, Implementation, and Results
of Tenet Healthcare’s
Commitment to Quality Initiative
Jennifer Daley, MDSenior Vice President—Clinical Quality
Chief Medical OfficerTenet Healthcare Corporation
Dallas, TX469-893-2988
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
Tenet HealthCareTenet HealthCare
Created in 1996 as the merger of two for-profit hospital chains with subsequent acquisitions of over 40 hospitals
Currently 97 hospitals primarily across the southern tier states; within the year will be 70 hospitals
Typical Tenet hospital is a 150-200 bed community hospital offering secondary and tertiary services
Four academic health centers (USC, Creighton, Hahnemann, St. Louis University)
About 30% of the hospitals have some affiliated teaching programs
Created in 1996 as the merger of two for-profit hospital chains with subsequent acquisitions of over 40 hospitals
Currently 97 hospitals primarily across the southern tier states; within the year will be 70 hospitals
Typical Tenet hospital is a 150-200 bed community hospital offering secondary and tertiary services
Four academic health centers (USC, Creighton, Hahnemann, St. Louis University)
About 30% of the hospitals have some affiliated teaching programs
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
Among Tenet’s Challenges in Early 2003Among Tenet’s Challenges in Early 2003
What is the state of quality in Tenet Healthcare?
How can we improve it?
How can we improve it rapidly?
How can we incorporate quality, safety, and service into the culture of Tenet hospitals quickly?
How can we sustain improvements for the foreseeable future?
Can we afford to do it?
Can we afford not to do it?
What is the state of quality in Tenet Healthcare?
How can we improve it?
How can we improve it rapidly?
How can we incorporate quality, safety, and service into the culture of Tenet hospitals quickly?
How can we sustain improvements for the foreseeable future?
Can we afford to do it?
Can we afford not to do it?
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
What are the most critical areas to improve rapidly?
What are the most critical areas to improve rapidly?
Evidence based medicine
Patient safety
Physician excellence
Nursing excellence
Patient flow and capacity management
Clinical leadership
Clinical resource management and utilization review
Equity in access and pricing for the uninsured
Service excellence
Evidence based medicine
Patient safety
Physician excellence
Nursing excellence
Patient flow and capacity management
Clinical leadership
Clinical resource management and utilization review
Equity in access and pricing for the uninsured
Service excellence
The birth of the Commitment to Quality » “C2Q”
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
To Tenet Hospitals: CTQ can help you improve…To Tenet Hospitals: CTQ can help you improve…
“Convince me that this is really important…..”
― Subtext: “Show me that improving quality and safety brings me more revenue…”
• “Don’t impose this on us from the top down….”
― Subtext: “Corporate initiatives are DOA…”
– Subtext: “Give us some choice in what we do….”
• “How can we do this with all the other things you expect us to do?”
― Subtext: “We don’t really know how to do this. Send help!”
“Convince me that this is really important…..”
― Subtext: “Show me that improving quality and safety brings me more revenue…”
• “Don’t impose this on us from the top down….”
― Subtext: “Corporate initiatives are DOA…”
– Subtext: “Give us some choice in what we do….”
• “How can we do this with all the other things you expect us to do?”
― Subtext: “We don’t really know how to do this. Send help!”
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
C2Q Implementation Vehicle: Transformation TeamsC2Q Implementation Vehicle: Transformation Teams
In-depth (300 page) self assessment of over 200 metrics associated with each major transformation initiative (1 month)
On-site (five days a week/12 hours a day for eight weeks;) team of content experts in areas identified for improvement alongside hospital leadership and staff
10,000 mile checks to achieve ongoing improvement and sustainability
Thirty two hospitals will have completed TT (Phase I) by end of 2004; all 70 retained hospitals by the end of 2005
In-depth (300 page) self assessment of over 200 metrics associated with each major transformation initiative (1 month)
On-site (five days a week/12 hours a day for eight weeks;) team of content experts in areas identified for improvement alongside hospital leadership and staff
10,000 mile checks to achieve ongoing improvement and sustainability
Thirty two hospitals will have completed TT (Phase I) by end of 2004; all 70 retained hospitals by the end of 2005
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
C2Q Transformation Teams: EBM (2004)C2Q Transformation Teams: EBM (2004)
Goal 1: “Hardwire” 95% adherence to evidence-based guidelines in AMI, Pneumonia, CHF, Surgical Infection Prophylaxis, and isolated CABG by the end of 2004
Goal 2: Have hospitals with CABG, valve, and PCI programs to require cardiac surgeons and invasive cardiologists to assess and record the AHA/ACC appropriateness classification (I, IIa, IIb, or III) for every CABG, valve replacement, and PCI
Goal 1: “Hardwire” 95% adherence to evidence-based guidelines in AMI, Pneumonia, CHF, Surgical Infection Prophylaxis, and isolated CABG by the end of 2004
Goal 2: Have hospitals with CABG, valve, and PCI programs to require cardiac surgeons and invasive cardiologists to assess and record the AHA/ACC appropriateness classification (I, IIa, IIb, or III) for every CABG, valve replacement, and PCI
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
AMI: Beta Blocker Prescribed At DischargeAMI: Beta Blocker Prescribed At Discharge
Mean Rate: Tenet vs. JCAHO National Benchmark
85% 86%91%89% 90% 91% 92%
84%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2003 Q1 2003 Q2 2003 Q3 2003 Q4
Tenet
JCAHO
85% 86%91%89% 90% 91% 92%
84%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2003 Q1 2003 Q2 2003 Q3 2003 Q4
Tenet
JCAHO
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
Mean Rate: Tenet vs. JCAHO National Benchmark
AMI: ACEI for LVSDAMI: ACEI for LVSD
71%73%
78%77% 78% 78% 80%
65%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2003 Q1 2003 Q2 2003 Q3 2003 Q4
Tenet
JCAHO
71%73%
78%77% 78% 78% 80%
65%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2003 Q1 2003 Q2 2003 Q3 2003 Q4
Tenet
JCAHO
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
Mean Rate: Tenet vs. JCAHO National Benchmark
Pneumonia: Pneumococcal Screening and/or Vaccination
Pneumonia: Pneumococcal Screening and/or Vaccination
22%25% 27%
34%36% 37%
42%
21%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2003 Q1 2003 Q2 2003 Q3 2003 Q4
Tenet
JCAHO
22%25% 27%
34%36% 37%
42%
21%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2003 Q1 2003 Q2 2003 Q3 2003 Q4
Tenet
JCAHO
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
Mean Minutes: Tenet vs. JCAHO National Benchmark
Pneumonia: Time To First Dose of AntibioticsPneumonia: Time To First Dose of Antibiotics
254 254 251
228
256 251 253245
0
50
100
150
200
250
300
2003 Q1 2003 Q2 2003 Q3 2003 Q4
Av
era
ge
Min
ute
s
Tenet
JCAHO
254 254 251
228
256 251 253245
0
50
100
150
200
250
300
2003 Q1 2003 Q2 2003 Q3 2003 Q4
Av
era
ge
Min
ute
s
Tenet
JCAHO
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
Utilization Management and ReviewUtilization Management and Review
Interqual assessment for 100% of all adult medical/surgical admissions for appropriateness of inpatient admission, continuation of stay, and discharge
In invasive cardiology, use American Heart Association/American College of Cardiology appropriateness guidelines for CABG, valve replacement, and percutaneous coronary intervention
Use NIH guidelines for appropriateness of bariatric surgery
In the 6 months, implement the Interqual SIMS criteria for all major discretionary procedures
Interqual assessment for 100% of all adult medical/surgical admissions for appropriateness of inpatient admission, continuation of stay, and discharge
In invasive cardiology, use American Heart Association/American College of Cardiology appropriateness guidelines for CABG, valve replacement, and percutaneous coronary intervention
Use NIH guidelines for appropriateness of bariatric surgery
In the 6 months, implement the Interqual SIMS criteria for all major discretionary procedures
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
C2Q: Improvement in CABG Processand Outcome
C2Q: Improvement in CABG Processand Outcome
Comprehensive assessment of all aspects of isolated CABG surgery
Appropriateness of surgery (AHA/ACC criteria)
Processes of care demonstrated to improve mortality and morbidity
Outcomes: risk-adjusted mortality and morbidity
Comprehensive assessment of all aspects of isolated CABG surgery
Appropriateness of surgery (AHA/ACC criteria)
Processes of care demonstrated to improve mortality and morbidity
Outcomes: risk-adjusted mortality and morbidity
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
CABG Appropriateness at Tenet Hospital JCABG Appropriateness at Tenet Hospital J
Target Jan
04
Feb
04
Mar
04
Apr
04
May
04
Jun
04
July
04
Aug
04
Isolated CABG
(n)
44 39 29 48 43 32 37 25
CABG + CABG-valve
(n)
51 50 37 58 56 36 44 34
AHA/ACC Level
IIb/III
0% 0% 0% 0% 0% 0% 0% 0% 0%
AHA/ACC Guideline Adherence for Appropriateness of CABG
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
CABG Mortality in Tenet Hospitals:Observed vs. Expected Mortality
CABG Mortality in Tenet Hospitals:Observed vs. Expected Mortality
3.6%
3% 3%
3.9%4.1%
3.5%
0%
1%
2%
3%
4%
5%
CY 2001 CY 2002 CY 2003
Mo
rta
lity
Ra
te
Observed Mt% Expected Mt%
3.6%
3% 3%
3.9%4.1%
3.5%
0%
1%
2%
3%
4%
5%
CY 2001 CY 2002 CY 2003
Mo
rta
lity
Ra
te
Observed Mt% Expected Mt%
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
C2Q: Patient SafetyC2Q: Patient Safety
Implement web-based occurrence reporting system
Reduce hospital acquired infections by 50% (VAP, central line BSI, UTIs associated with catheters, surgical site infections)
Reduce high severity adverse drug events by 50%
Promote a culture of safety in each hospital
Build team training in high risk areas of hospital (ICU, ER, L&D, OR, invasive radiology)
Provide hospitals with educational material for governing boards, administrators, clinical staff, physicians, patients, and families
All Tenet hospitals are members of the National Patient Safety Foundation Stand Up program
Corporate level Patient Safety Committee monitors trends, develops patient safety policies, identifies new trends in patient safety
Implement web-based occurrence reporting system
Reduce hospital acquired infections by 50% (VAP, central line BSI, UTIs associated with catheters, surgical site infections)
Reduce high severity adverse drug events by 50%
Promote a culture of safety in each hospital
Build team training in high risk areas of hospital (ICU, ER, L&D, OR, invasive radiology)
Provide hospitals with educational material for governing boards, administrators, clinical staff, physicians, patients, and families
All Tenet hospitals are members of the National Patient Safety Foundation Stand Up program
Corporate level Patient Safety Committee monitors trends, develops patient safety policies, identifies new trends in patient safety
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
Informatics-enabled Infection Control Monitoring
Informatics-enabled Infection Control Monitoring
Sample screen shots from the CCM and IC story boards due 9/12 will go here
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
C2Q: Physician ExcellenceC2Q: Physician Excellence
Half day educational session annually for all Tenet hospital governing board members regarding their fiduciary responsibility for quality, safety, and physician credentialing
Standardization of the business processes of physician credentialing and privileging through web-based tool
Identification and remediation of physicians whose utilization/quality is substandard through peer review and established medical staff and governing boards processes
Consistent physician performance assessments using objective data and peer review
Half day educational session annually for all Tenet hospital governing board members regarding their fiduciary responsibility for quality, safety, and physician credentialing
Standardization of the business processes of physician credentialing and privileging through web-based tool
Identification and remediation of physicians whose utilization/quality is substandard through peer review and established medical staff and governing boards processes
Consistent physician performance assessments using objective data and peer review
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
CredentialingCredentialing
Echo and Echoapps screen shots
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
CredentialingCredentialing
Echo and Echoapps screen shots
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
Completing the Circle of Supporting Physician Excellence
Completing the Circle of Supporting Physician Excellence
Individual informatics-enabled projects dependent upon one another
IT integration strategy to support hospital management processes
Individual informatics-enabled projects dependent upon one another
IT integration strategy to support hospital management processes
Incident Reporting
Physician ClinicalPerformance Assessmentfor Quality
andUtilization
Peer Review
Re-Appointment
Physician Excellence
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
C2Q nursing program has improved nursing retention, quality, and patient satisfaction
C2Q nursing program has improved nursing retention, quality, and patient satisfaction
Example nursing improvements from last round of C2Q
Hospital 3 significantly decreased voluntary turnover and accelerated involuntary turnover– June RN voluntary turnover improved to 13.8% vs. 20% for the
previous year– June RN percent involuntary terms less than 90 days dropped to zero,
while voluntary terms less than 90 days rose to 22.2%
Nursing retention
Pressure ulcers/falls
Hospital 84 implemented corporate policies to reduce the incidence of pressure ulcers and patient falls
Hospital 11 developed a shared governance/nursing peer review model aimed at improving the quality of nursing care
Nursing peer review
Hospital 53 dramatically improved inpatient satisfaction with pain management scores from 61% before C2Q to 96%
Pain management
Hospital 19 demonstrated significant improvement in inpatient satisfaction scores (hospital never achieved 4 star status before but was 4 star 2 of the past 3 months) by implementing a new nurse staffing model
Inpatient satisfaction
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
C2Q: Patient Flow and Capacity Management
C2Q: Patient Flow and Capacity Management
Hypothesis 1: delays and “blocks” in high flow areas of the hospital are not the result of lack of space or staff
Hypothesis 2: delays and “blocks” in high flow areas of the hospital are the result of a failure to “connect the dots” in tightly coupled systems and a failure of synchronization
Key Areas: Emergency Room, Operating Rooms, ICUs, discharge processes (bed turnover)
Hypothesis 1: delays and “blocks” in high flow areas of the hospital are not the result of lack of space or staff
Hypothesis 2: delays and “blocks” in high flow areas of the hospital are the result of a failure to “connect the dots” in tightly coupled systems and a failure of synchronization
Key Areas: Emergency Room, Operating Rooms, ICUs, discharge processes (bed turnover)
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
24
8
0
13
43
45
48
9
100
92
C2Q operations impact has been strong
and sustained
C2Q operations impact has been strong
and sustained
Average discharge time
Average minutes DOW to DC
Average minutes exit to room clean
Asset utilization in hours
First case delay in minutes
Cancellation percentage
LOS minutes – discharged
LOS minutes – admitted
LWBS percentage
Diversion hours*
Continuum of care
Operating room
Emergency Department
Metrics
Gap closed at C2Q team departurePercent
Gap closed by September, 2004Percent
30
4
-5
23
48
57
42
45
100
75
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
Daily Tool SnapshotDaily Tool Snapshot
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
Examples of C2Q Quality Improvements From Most Recent Round
Examples of C2Q Quality Improvements From Most Recent Round
– Improved medication safetyPatient
Safety
Compliance
with EBM
–Lowered the incidence of ventilator associated pneumonia
Medical Staff Support
Hosp 1
Hosp 17
– Increased CHF patients receiving discharge education from 8% to 79%
Hosp 4
–CAP patients receiving IDSA approved antibiotics improved from 33% to 80%
–CAP pneumovax immunization rate improved from 59% to 90%
Hosp 64
–Strengthened its credentialing process by infusing better data into re-appointment processes
Hosp 35
–Reviewed criteria for sub specialist performance on medical staff
Hosp 51
–Considerable body of evidence that level of quality is improving significantly due to C2Q
–Hospitals building necessary skills and tools through C2Q to tackle next-wave quality issues in their hospitals
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
C2Q cultural impact is acceleratingC2Q cultural impact is acceleratingWays the culture is changing
New skills are being learned
Physicians are embracing the program
“I wasn't before, but now I'm a believer in C2Q. An initiative I thought would take 8 months got done in 8 weeks.”
– MD
“The training opened my eyes to new ways of approaching the same issue.”
– Director
“For the first time, I believe we can make change happen; the outside help has really opened our eyes.”
– MD
“The training gave me some really good ideas for how I’m going to tackle the one physician issue I’m struggling with.”
– Director
“For the first time in my 20 years, I finally feel that we have a mechanism to drive positive change.”
– MD
“C2Q gives us the capability to be able to tackle new issues as they arise. In the future we are going to “C2Q” new problems.”
– CEO
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
Enabling mechanisms in place to sustain impactEnabling mechanisms in place to sustain impact
Current tools
Bi-weekly performance reporting from hospitals to Program Management Office
Process to feed back action items to regional and hospital teams
Near-term (monthly) and long-term (12-24 month) targets Clinical Quality measurement index Performance evaluation and development tool for
regional team
Performance management
Best practice sharing
User-friendly best practice database in Tenet intranet Process for ongoing best practice development, codification,
and dissemination Key operations and quality expert resource contact list
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
New strategic direction to achieve service excellenceNew strategic direction to achieve service excellence
Transform Tenet’s service strategy through new value propositions for patients and physicians
Build upon the best elements of Target 100 and fill gaps to strengthen Tenet’s service culture
Integrate T100 and C2Q teams to align service, quality, and operations initiatives Build distinctive service levels in selected local markets
Strategic direction
Patient service commitment
Physician service commitment
Description
“Tenet will offer physicians operationally effective, collegial professional communities where they can be significantly more productive and have their patients treated safely and with dignity.”
“Tenet will create a physical and emotional environment that delivers positive patient-centered experiences, not just health service transactions.”
Safe, comfortable and prompt
Respectful, empathetic, and coordinated
Consistent with other ‘service- excellent’ environments
Doing the right thing, the first time, on time
Equitable governance to give physicians a sense of ‘ownership’
Economics, technological support, and improved lifestyle need to make a 15-20% difference
CONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSESCONFIDENTIAL – DO NOT DISTRIBUTE BEYOND ORIGINAL ADDRESSES
Positive Forces At WorkPositive Forces At Work
Leadership
Resources
Standardized Approach with “Local Customization”
Communication, communication, communication
Accountability
Public influence in dialogue about performance
“Quality” or “safety” or “safeguarding”?
Leadership
Resources
Standardized Approach with “Local Customization”
Communication, communication, communication
Accountability
Public influence in dialogue about performance
“Quality” or “safety” or “safeguarding”?