Review of Risk Management Systems: Supplemental Information and ECRI Institute Resources

HRSA Clinical Risk Management Resources Homepage

Before You Fill Out the Application… Have the following items with you: Policy on diagnostic test tracking Policy on tracking hospitalizations Policy on tracking referrals HRSA Program Assistance Letter (PAL) 2012-02: Calendar Year 2013 Requirements for Federal Tort Claims Act (FTCA) Medical Malpractice Coverage for Health Centers (access at http://www.bphc.hrsa.gov/policiesregulations/policies/pal201202.html)

Components of Application 1. Conduct periodic assessments to monitor malpractice risk. 2. Describe policies/procedures on supervision of clinical and non-clinical staff. 3A. Have medical records policies that address HIPAA/privacy, completeness of documents, and archiving procedures. 3B. Periodically review medical records for completeness, quality, and legibility. 4. Have policies/procedures that address triage, walk-in patients, telephone triage, and no-show appointments.

Components of Application (cont.) 5. Develop clinical protocols that define appropriate treatment and diagnostic procedures for selected medical conditions. 6. Have tracking systems for: Referral tracking Hospitalization tracking Diagnostic tracking IMPORTANT: Attach policies for referral tracking, hospitalization tracking, and diagnostic tracking to the application.

1. Periodic Assessments of Malpractice Risk Safety culture surveys Employee safety attitudes questionnaire Patient questionnaires Patient complaints Event report reviews Near-miss report reviews Claims reviews Root cause analysis Failure mode effects analysis

2. Supervision of Clinical and Non-Clinical Staff Laboratory technicians Social workers Licensed practical nurses Registered nurses Dental hygienists Dieticians Physicians’ assistants Medical residents

Clinical Risk Management Resources Self-Assessment Questionnaire: Physician Practice Risk Management: https://members2.ecri.org/Components/HRSA/Pages/SAQ2.aspx. Sample Policies and Tools: Event Reporting Toolkit: https://members2.ecri.org/Components/HRSA/Pages/EventReportToolkit.aspx. Patient Satisfaction Questionnaire: https://members2.ecri.org/Components/HRSA/Pages/PSRMPol2.aspx. Safety Attitudes Questionnaire: https://members2.ecri.org/Components/HRSA/Pages/PSRMPol1.aspx. Guidance Article: Identifying Risks and Assessing Patient Safety in Ambulatory Care: https://members2.ecri.org/Components/HRSA/Pages/PSRM1.aspx.

3A. Medical Records Policies Must Address: HIPAA. Providers must maintain the privacy, confidentiality, integrity, and security of protected health information. Completeness of documents. Policies should define what information is included in medical records (see next slide). Archiving procedures. Check state statutes, administrative codes, or state medical boards. See the guidance articles “Regulations and Standards” at https://members2.ecri.org/Components/HRSA/Pages/RS1.aspx#medical and “Electronic Health Records” at https://members2.ecri.org/Components/HRSA/Pages/EHR1.aspx.

Medical Record: Completeness of Document Date and time of entries History/physical exam Clinical questionnaires Patient complaints/symptoms Allergies/adverse reactions Prescriptions Test results Advance directives Patient education Informed consent/refusal Referrals Discharge instructions Missed appointments Patient correspondence Others in room during appointment

4. Have Policies and Procedures that Address: Triage Walk-in patients Telephone triage No-show appointments

5. Clinical Protocols for Selected Conditions Asthma Diabetes Influenza Pneumonia Strep throat Coronary heart disease For more information, see the American Academy of Family Physicians’ Family Practice Management Toolbox at http://www.aafp.org/online/en/home/publications/journals/fpm/fpmtoolbox.html.

6. Tracking Systems: Diagnostic Tracking Track all ordered tests and document returned results using a computer application or test tracking log. Designate a staff member responsible for monitoring test tracking logs and following up on delayed results. Designate a staff member responsible for ensuring providers review the results of the tests they order. Inform patients of all test results (including normal results). Document patient notification. Document patient decisions not to undergo recommended tests and that patients have been informed of the risks.

Considerations for Electronic Health Records Develop a download policy and accountability for who will review and how often. Make sure that no labs go to a provider who isn’t in the center for review. Make sure any action that comes to the front desk/clinical staff is handled or forwarded if the staff goes home.

Test Tracking and Follow-Up Toolkit

Tracking Systems: Hospitalization Tracking Educate patients to notify the health center of hospital visits. Inform frontline staff what to do when notified of a patient hospitalization (special considerations for weekends, evenings, off-hours). Consider setting up a voicemail box for notifications. Keep a log of patient hospital/emergency room visits. Communicate with primary hospitals/facilities in the community.

Hospitalization Tracking Resources Sample Policy Guide: Tracking Hospital and Emergency Room Visits Hospital Admission and Emergency Visit Log

Tracking Systems: Referral Tracking Communicate to patients the importance of keeping referral appointments and the risks of not keeping them. Ask specialists to contact the health center if a patient misses a referral appointment. Follow-up with patients who miss appointments. DOCUMENT referrals, all communication with patients (including that patient was informed of risks), patient follow-up.

Risk Management Systems FAQs Q: What is required to provide sufficient response to question 2 under the Risk Management section of the FTCA application: “Identify policies/procedures implemented regarding appropriate supervision of clinical and non-clinical staff”? A: The health center should provide a brief summary of the policies that it has in place that delineates how it provides supervision to clinical support staff (e.g., RNs, LPNs, MAs). The health center should also describe what it has in place for supervision of mid-level providers (e.g., collaborative agreements, supervisory agreements).

Risk Management Systems FAQs Q: What is a hospitalization tracking policy? A: A hospitalization tracking policy should include procedures for tracking patients who have been hospitalized (once the health center discovers they have been hospitalized) and ensuring that the patient is brought back in to the health center for follow up care.

Clinical Risk Management Website http://www. ecri Go to: http://www.ecri.org/clinical_rm_program Enter username and password under “Member Login” Don’t have a username and password? Contact us: Clinical_rm_program@ecri.org (610) 825-6000 x5200

Questions on Deeming/Application Process? Contact BPHC helpline at 1-877-974-BPHC (877-974-2742) or BPHChelpline@hrsa.gov 9:00AM to 5:30PM (ET) FTCA website: http://www.bphc.hrsa.gov/ftca For EHB technical support (e.g., registration, username and password), contact HRSA Call Center at 1-877-464-4772 or CallCenter@hrsa.gov. Monday-Friday (except federal holidays) 9:00AM to 5:30PM (ET)