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Stakeholder Engagement Program in Oklahoma

Stakeholder Engagement Program in Oklahoma

Oklahoma's promising practice
Applicability to other States


Early engagement with all individuals and organizations that may be affected by the implementation of the National Background Check Program is critical to program success. States such as Oklahoma that work with key stakeholders from the time the State begins to consider submitting a grant application are likely to experience less resistance to enabling legislation and to benefit from stakeholder suggestions for sustaining the program after the grant period.


In this context, “stakeholder” is defined as any individual, group, or organization that may be affected by or have an interest in an initiative or its outcome, either directly or indirectly. States have both internal stakeholders (other State agencies that will be involved in implementation, such as law enforcement) and external stakeholders (including the long term care providers/facilities, industry groups, and advocates for long term care recipients and their families).

Stakeholder engagement in the NBCP process is so critical to success that grant applications are reviewed for evidence of:

  • Involvement of consumer and provider/facility interest groups in the design and implementation of the State’s program;
  • Partnerships with public and private organizations that possess expertise in workforce issues pertaining to direct access employees in long term care settings; and
  • State partnerships with public and private organizations that represent people of any age who receive long term care services.

Grantee agencies must try to identify any stakeholder group, internal or external, on which the program may have an impact and understand the group’s expectations, the most effective way to communicate with them, and how to gain their active support for the program. Such engagement increases the likelihood of support for change and minimize unanticipated resistance.

States that have actively sought participation from stakeholders early in their process—as early as the grant application phase—are generally more successful in getting legislation passed in the first year of the grant. They are also more likely to develop background check processes that are enthusiastically welcomed by facilities/providers when those groups have been involved in developing the functionality of the system.

Oklahoma's promising practice

Stakeholder support is particularly critical to program success when legislation needs to be introduced to meet NBCP requirements. This was the case when Oklahoma was awarded its grant in April 2011. The Oklahoma State Department of Health had a long-standing and supportive relationship with many of the State’s long term care provider/facility groups—both not-for-profit and for-profit—as well as with long term care industry associations.

Even before the NBCP grant was awarded, OSDH met with these groups individually to explain its plans to apply for the grant and ensure that they understood NBCP’s goals. OSDH also used these meetings to get an initial sense of each organization’s perspective on the program and to identify program elements that caused concern. Most groups expressed support for the goals, but many indicated they would not support any increase in costs that implementation might require.

Soon after Oklahoma was awarded the grant, OSDH expanded its outreach to stakeholders to include all of the following groups:

  • Nursing homes, assisted living facilities, and home health, hospice, and residential care associations;
  • Personal care service providers;
  • Other internal stakeholders, such as the State’s Department of Human Services, Health Care Authority, and Bureau of Investigation; and
  • Vulnerable population advocates, such as AARP and the Oklahoma Aging Partnership.

OSDH asked each of these organizations to appoint a representative to a newly formed NBCP Advisory Board. The representatives worked with OSDH to refine the proposed background check system process, clearly delineate program scope, identify and select funding options, and assist in drafting NBCP-enabling legislation.

The involvement of these key internal and external stakeholders allowed Oklahoma to develop a program that both met NBCP requirements and was tailored to the unique needs of the State and its long term care community—including the service providers, law enforcement, and patient advocates. The Advisory Board members also shared information with their member organizations about the program and kept them informed about proposed legislation and its potential impact. Their participation strengthened support for the program and increased acceptance of enabling legislation by key constituents.

In spite of all the work that OSDH did to communicate with stakeholders, some lawmakers did not understand the bill, and others were resistant, when it was introduced in the 2012 legislative session. It was at this point that Advisory Board members and the wider stakeholder population expressed their support of the initiative to the legislature. They demonstrated to the legislature that the benefits of the proposed bill outweighed potential drawbacks identified by the bill’s detractors. The State Long Term Care Ombudsman, the Oklahoma Aging Partnership, and others solicited and received support from the AARP and worked closely with the OSDH legislative ombudsman to show public support for the bill. Oklahoma House Bill 2582 was passed by the legislature and signed into law by the governor on its initial introduction in June 2012.

In the end, OSDH faced substantial opposition from only one industry—providers of home and community-based waivered services under Medicaid. Eventually OSDH did negotiate this group’s exemption from mandatory participation in NBCP (making participation voluntary for this provider type).

OSDH continues to meet regularly with key stakeholders on the NBCP Advisory Board as the program is implemented. Their support and insights are crucial to the successful development and acceptance of the program. The board has worked closely with the OSDH team to respond to questions about the program from providers and to demonstrate industry support for the initiative. Members of the board were also among the first to volunteer to test a pilot version of the NBCP background check system, OK-SCREEN.

Applicability to other States

All States should identify and engage their key stakeholders in developing a NBCP program, from its inception through implementation. All State agencies have experience working with the providers/facilities, associations, and advocacy groups concerned with long term care. Each State agency has a unique relationship with these groups, but all will benefit from engaging the groups in working toward the common goal of protecting vulnerable recipients of long term care. A key to program success is the ability to work with stakeholders to come up with solutions that address their concerns without significantly compromising the program.

It is better to have done this before legislation is introduced in legislative session. States that have not worked closely with stakeholders early in the grant implementation need to understand and be prepared to address any concerns raised once legislation is proposed. States that failed to research and identify all stakeholders were surprised at who had objections to the legislation and were not adequately prepared to address the opposition. In most of these cases, legislation was not passed in either the first or the second grant years. Only after legislation failed to pass did those State agencies invite both supporters and opponents of the bill to collaborate to address the concerns and redraft the bill.

There are many methods and tools for developing effective stakeholder management and communication plans. Such tools help States develop a plan to engage stakeholders, including the type and frequency of communications with them. The fundamental elements in effectively assessing and managing stakeholder engagement are:

  • Identify all individuals and organizations that have an interest—emotional, financial, political—in the outcome of the grant program;
  • Interview or otherwise contact stakeholders to gain a better understanding of their interests and concerns;
  • Learn how the grant program is perceived to have an impact on them; develop ways to communicate with them about how to mitigate any negative impact;
  • Identify areas of mutual interest and concern that may be benefited by the grant program; and
  • Invite key stakeholders to participate in an advisory capacity to ensure that their issues are addressed and they have an opportunity to provide guidance on grant implementation policies and procedures.