Peer Review - OverviewDEB KAZMERZAK, IOWA PCA

ACKNOWLEDGEMENT: LINDA RUBLE, PA/NP, PCA CLINICAL CONSULTANT

Have you ever tried….?

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Why do FQHCs conduct peer review?

330 rules

Program requirements 3, 8

FTCA deeming

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Section 330 Authorizing Legislation

The center will have an ongoing quality improvement system that includes clinical services and management and that maintains the confidentiality of patient records.

http://bphc.hrsa.gov/policiesregulations/legislation/index.html

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HRSA Program Requirement 3

Staffing Requirement: Health center maintains a core staff as necessary to carry out all required primary, preventive, enabling health services and additional health services as appropriate and necessary, either directly or through established arrangements and referrals. Staff must be appropriately licensed, credentialed and privileged. (PIN 2002-22)

http://bphc.hrsa.gov/policiesregulations/legislation/index.html

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PIN 2002-22D. PRIVILEGING REVISION OR RENEWAL REQUIREMENTS

1. The revision or renewal of a LIP’s privileges should occur at least every 2 years and should include primary source verification of expiring or expired credentials, a synopsis of peer review results for the 2 year period and/or any relevant performance improvement information. Similar to the initial granting of privileges, approval of subsequent privileges is vested in the governing board which may review recommendations from either the clinical director, or a joint recommendation of the medical staff (including the Clinical Director) and the Chief Executive Officer, or delegate this responsibility (via resolution or bylaws language) to be implemented according to approved policies and procedures (including methods to assess compliance with these policies and procedures).

http://bphc.hrsa.gov/policiesregulations/policies/pin200222.html

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HRSA Program Requirement 8

Quality Improvement/Assurance Plan: Must include Periodic assessment of the appropriateness of the utilization of services and the quality of services provided or proposed to be provided to individuals served by the health center; and such assessments shall. . .◦ Be conducted by physicians or by other licensed health professionals

under the supervision of physicians;◦ Be based on the systematic collection and evaluation of patient

records; and◦ Identify and document the necessity for change in the provision of

services by the health center and result in the institution of such change, where indicated.

http://bphc.hrsa.gov/policiesregulations/legislation/index.html

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Other Considerations… Federal Tort Claims Act (FTCA)

◦ Requires QI/QA plan, which requires peer review

Blinded, aggregate results should be shared with health center board

Clear policies and procedures on who can see peer review results

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Frequently Asked Questions

How often?

How many charts?

How do you conduct peer review of specialists?

What about a single clinician practice? (i.e. one dentist)

There is no solid guidance

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Chart Audit vs. Peer Review

Not the same thing!

Chart audit ◦ Assesses completeness of documentation◦ Could be administrative support staff

Peer review◦ Requires clinical judgment

May be done together, as long as the person conducting the chart audit/peer review is appropriately licensed

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How can peer review findings help?

Shows the strengths and weaknesses

Provides supervisors data on training needs

Follow up data provides information on whether the training or other efforts to improve the results paid off

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Closing Thoughts Close the loop. This is not a task to be checked off the to do list, but an opportunity for rich discussion among your clinicians and for performance improvement, both at the individual clinician level and at the health center level

This is also an opportunity to recognize outstanding performance of clinicians/health center sites

RESOURCE: www.ecri.org

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Thank you!

Deb Kazmerzak

Iowa Primary Care Association

dkazmerzak@iowapca.org

515.333.5013