Combined OPPE/FPPE Policy and Procedure POLICY AND PROCEDURE I. SECTION PAGE 1 OF 4 DATE SUPERSEDES MANUAL Medical Staff Office APPROVED BY Governing Board SUBJECT OPPE/FPPE WRITTEN BY Medical Executive Committee PURPOSE: To define, determine, maintain, and evaluate the competency of members of the medical staff and advanced practice professionals, who are members of the allied health professional staff, to provide care, treatment, and service in accordance with the credentialing and privileging processes and requirements of the medical staff. This policy refers to the records and proceedings of the medical staff, which has the responsibility of evaluation and improvement of the quality of care rendered in the hospital. The records and proceedings of the medical staff that relate to this policy in any way are protected from discovery pursuant to [state evidence statutes]. II. POLICY: All members of the medical staff and advanced practice professionals, who are members of the allied health professional staff, will be required to meet six general competencies and will be subject to a focused professional practice evaluation and an ongoing professional practice evaluation process. III. TERMS: A. General competencies: There are six areas of general competencies. These general competencies were developed by the Accreditation Council for Graduate Medical Education (ACGME) and the American Board of Medical Specialties (ABMS) joint initiative and adopted by The Joint Commission. The areas of general competencies include: 1. Patient care Practitioners are expected to provide patient care that is compassionate, appropriate, and effective for the promotion of health, prevention of illness, treatment of disease, and care at the end of life. 2. Medical/clinical knowledge Practitioners are expected to demonstrate knowledge of established and evolving biomedical, clinical, and social sciences and the application of their knowledge to patient care and the education of others. 3. Practice-based learning environment Practitioners are expected to be able to use scientific evidence and methods to investigate, evaluate, and improve patient care practices. 4. Interpersonal and communication skills Practitioners are expected to demonstrate interpersonal communication skills that enable them to establish and maintain professional relationships with patients, families, and other members of the healthcare team. 5. Professionalism Practitioners are expected to demonstrate behaviors that reflect a commitment to continuous professional development, ethical practice, and understanding and sensitivity to diversity and a responsible attitude toward their patients, their profession, and society. 6. Systems-based practice Practitioners are expected to demonstrate both an understanding of the contexts and systems in which healthcare is provided and the ability to apply this knowledge to improve and optimize healthcare. B. FPPE: FPPE is an intensified assessment of data or events, which relate to the performance or behavior of a specific practitioner holding clinical privileges. The purpose of a focused review is to determine whether the practitioner’s performance or behavior meets the minimum standard of behavior or clinical care as is established by the medical staff. FPPE is not considered an investigation as defined in the medical staff bylaws and is not subject to rights afforded in an investigation. If an FPPE results in an action plan to recommend a formal investigation, the process outlined in the medical staff bylaws will be followed. This process may be triggered: 1. When a practitioner has the credentials to suggest competence, but additional information or a period of evaluation is needed to confirm competence in Doctors Hospital of Manteca’s setting. 2. If questions arise regarding a currently privileged practitioner’s ability to provide safe, highquality patient care as documented by reports from others. 3. Practitioners may undergo proctoring (per policy) upon the granting of initial privileges and/or when additional/new privileges are granted. C. OPPE: OPPE is the continuous evaluation of the practitioner’s professional performance in order to identify and resolve any potential problems with a practitioner’s performance. It allows the medical staff to identify professional practice trends that impact on quality of care and patient safety on an ongoing basis and provides an evaluation of an individual practitioner’s performance and includes opportunities to improve patient care based on recognized standards. OPPE uses multiple sources of information for individual evaluation, and practitioners are provided with feedback for personal improvement or confirmation of personal achievement related to the effectiveness of their professional, technical, and interpersonal skills in providing patient care. OPPE information is one of the factors considered in the decision to allow a practitioner to maintain existing privilege(s), to revise existing privilege(s), or to revoke an existing privilege prior to or at the end of the initial appointment/reappointment period. OPPE includes, but is not limited to, review of the following: 1. 2. 3. 4. 5. 6. 7. 8. Direct observation Individual case review/peer review results/incident or occurrence reports Review of aggregate data Compliance with hospital policies, medical staff bylaws and medical staff rules and regulations Clinical standards and the use of rates compared against established benchmarks or norms Results of any required monitoring/proctoring Utilization data Core measures compliance 9. IV. Other relevant indicators as determined by the medical staff PROCEDURE A. General competencies: Initial applicants for privileges and all members of the medical staff must meet the general competencies outlined in this policy at the time of initial appointment and granting of privileges at reappointment. A practitioner who is unable to satisfactorily exhibit the general competencies outlined in this policy may be subject to the focused evaluation of his or her professional practice as noted in this policy. The general competencies of the practitioner can be verified in the following ways: 1. Verification regarding each practitioner’s current California licensure, training, experience, competence, and ability to perform the requested privileges in accordance with the medical staff bylaws. 2. Information from peer references that affirmatively attest to the general competencies of the practitioner. Peer recommendations must be obtained from a practitioner preferably in the same professional discipline as the applicant with personal knowledge of the applicant’s ability to practice. 3. Information obtained from performing background checks, verification of any actions taken by any licensing board or other healthcare organization, reports to the National Practitioner Data Bank, and verification of any sanctions. 4. The recommendation of the department chair or designee and the Medical Executive Committee (MEC) that the practitioner exhibits the general competencies based on the practitioner’s relevant education, training, experience, and known information about the practitioner’s current performance. 5. Specific information that may arise out of ongoing and/or focused evaluation of a practitioner that affirmatively or adversely speaks to that practitioner’s general competencies. B. FPPE: FPPE will occur under the following circumstances: 1. Privileges requested at initial appointment or requests for additional privileges: All medical staff members granted initial privileges will undergo a period of proctoring as determined by the individual clinical department in which the practitioner is assigned. Refer to the Proctoring Policy and Specialty Specific Proctoring Guidelines for specific requirements. 2. Focused review: A focused review of a practitioner’s performance will occur if it is identified that there may be a significant practitioner-specific issue related to patient care or safety. Refer to the Peer Review Policy, located in the Departmental P.I. Plan, and medical staff bylaws. 3. Circumstances requiring evaluation from an external source: At times, there may be need for an outside evaluation to occur. Refer to the Peer Review Policy. 4. Discussion with others: Reports from other individuals involved in the care of a patient (e.g., consulting physicians, assistants at surgery, nursing or administrative personnel). 6. OPPE: Significant findings as a result of the OPPE process. C. OPPE: Every eight months, and at the time of reappointment, a summary of the following information will be made available to the department chair or designee in order to perform the OPPE process. If a trend of unsatisfactory patient care or management is identified, the department chair or designee will recommend that a focus review be conducted in accordance with medical staff bylaws. 1. Peer review process: A Practitioner Profile will be generated in order to identify if there are practitioners with a trend of unsatisfactory patient care and management. 2. Results of peer review: Utilizing indicators selected by medical staff clinical departments, cases will be forwarded for peer review. 3. Crimson reports: A Crimson report, where available, will be generated to identify practitioners with an unfavorable variance regarding the expected length of stay, expected complication rate, or the expected mortality rate. 4. Results of proctoring: The results of proctoring, if any, will be compiled and reviewed. 5. Medical staff required monitoring: Quality peer indicators, results of blood review, mortality review, operative and invasive procedure review, per departmental-specific criteria, will be reviewed in order to determine whether focus review is indicated. 6. Compliance with core measures: The organization collects data related to compliance with the Core Measures. Triggers: The two triggers that will be used to indicate a need for performance monitoring to further assess current competence are: 1. Identification of a significant single event/sentinel event. 2. Identification of a trend of performance deficiencies. A trend will be considered to be met if four or more cases for the same type of review with a rating of Q2, Q3, U2, U3, B2, or B3 are identified. Conflict of interest: A member of the medical staff who is asked to perform an FPPE may have a conflict of interest if he or she is unable to render an unbiased opinion due to either involvement in the patient’s care or a relationship with the practitioner involved, whether as a direct competitor or a partner. It is the reviewer’s obligation to disclose the potential conflict to the department chair. Department chairs are responsible for determining whether the conflict would prevent the individual from participating and the extent of that participation, if allowed. Individuals determined to have a conflict may be present during the FPPE; however, they will recuse themselves from voting on any recommendation. Confidentiality: Data, records, documents, and knowledge, including but not limited to minutes and case review materials collected for or by hospital departments, individuals, or committees assigned with the responsibility of performing the functions delineated in this policy are confidential and are not public record. The information shall be used by department chairs and designated medical staff departments and committees, including appointed ad hoc committees, only in the exercise of the assigned functions of the department or committee. Approved: Medical Executive Committee, [Date] Governing Board, [Date] Source: Doctors Hospital of Manteca, 2015. Used with permission. From The FPPE Toolbox: Field-Tested Documents for Credentialing, Competency, and Compliance, Second Edition, ©2015 HCPro