QUESTION:
Should we be using specialty-specific triggers as a part of our professional practice evaluation/peer review process?

ANSWER FROM HORTYSPRINGER ATTORNEY CHARLES CHULACK:
Yes.  Specialty-specific triggers give a measure of predictability and transparency to the professional practice evaluation/peer review process (“peer review process”).  These triggers are pre-determined events, organized by specialty or department, that identify a case for review through your peer review process.  Moreover, accreditation entities require the inclusion of these triggers as a part of the review process.  By way of example, The Joint Commission, in MS.08.01.01, instructs that the Medical Staff must “define the circumstances requiring monitoring and evaluation of a physician’s or other licensed practitioner’s professional performance” and requires that “[t]he triggers that indicate the need for performance monitoring are clearly defined.”  The DNV standards have similar language and define, in MS.8, “areas required to be measured [as a part of the peer review process],” including “[s]pecific department indicators that have been defined by the medical staff.”  The triggers should be communicated to members of the specialty or department so that they understand that if a certain event occurs, it is ripe for review, and they will most likely be notified about the case.

Often, the department chairs take the lead in identifying the specialty-specific triggers and the peer review committee is responsible for approving and periodically reviewing them.   For surgery, the triggers could include events such as an unplanned injury or removal of an organ, a retained foreign body, a wrong-site surgery, and a laceration or puncture of a body part.  For medicine, the triggers could include an unplanned transfer to a special care unit, an adverse outcome that is unrelated to the natural course of an illness, the death of a patient in a low mortality DRG, or a critical/abnormal lab result that is unaddressed or misinterpreted.

In addition to specialty-specific triggers, there are numerous other ways that clinical issues may be entered into the peer review process, including through reported concerns, patient complaints, referrals from the serious safety event process, OPPE data that reflects a concerning practice pattern or concern, and utilization issues.  These should also be defined in your peer review policy and will establish a broad net to catch issues for review.

If you have a quick question about this, e-mail Charlie Chulack at cchulack@hortyspringer.com.