“Do No Harm” Risk Mitigation in Making Licensing Decisions with Differential Monitoring Approaches

When it comes to licensing measurement and monitoring systems, risk assessment is the driving force in making licensing decisions, remembering the mantra: “Do No Harm“. There have been several posts giving examples in how one does this with risk assessment and key indicator methodologies which are the predominant approaches to differential monitoring. These methodologies are derived by two very different mathematical models, one based upon Likert scaling and weighting; the other based on predictive scaling and regulatory compliance history. However, what they have in common is a basic risk aversion.

With risk assessment rules, the selection process via a weighting methodology is critical in selecting those rules that place individuals at greatest risk of harm, and then making certain that these rules are always in regulatory compliance. With predictive rules, the selection process is through regulatory compliance history in general as well as with each individual rule. The key here is to make certain that the effect size is sufficiently large so that there are no false negatives.

The licensing decision process needs to ensure at all times that there is no regulatory non-compliance with the risk assessment rules and that there are no false negatives where general regulatory non-compliance is found with some other rule when the predictive rules are all in-compliance. In order to have an effective and efficient differential monitoring approach both these conditions must be met for the licensing system to work as it is intended with abbreviated inspection reviews. It is only by having this in place will a licensing agency feel confident that the necessary risk mitigation has been implemented in making licensing decisions.