Focused Professional Performance Evaluation of a Radiologist—A Centers for Medicare and Medicaid Services and Joint Commission Requirement
Section snippets
What is a Focused Professional Performance Evaluation?
Although most practicing radiologists are unaware of the term, it is highly likely that they have been the subject of a focused professional performance evaluation (FPPE), even if they did not realize that it was taking place. FPPE is a process mandated by the Centers for Medicare and Medicaid Services and the Joint Commission (as its accrediting body) to evaluate the competency of radiologists and other physicians. All newly appointed radiologists on any hospital medical staff must undergo an
Differences Between FPPE and OPPE
OPPE is a screening tool to evaluate all practitioners who have been granted privileges. Its purpose is to identify those clinicians who might be delivering an unacceptable quality of care. It is important to remember that OPPE is not designed to identify clinicians who are delivering good or excellent care, only those who deviate from providing good care. It does not take much to realize how vague these definitions might be for diagnostic or even interventional radiologists. Therefore, the
FPPE Relating to Professional Practice or Performance
The primary goal of an FPPE is to assess the performance of a radiologist relative to his or her similarly trained and experienced colleagues, as well as to established benchmarks and hospital policies. After intensive review and evaluation of the radiologist’s clinical practice or professional conduct by his or her peers, recommendations for performance improvement of an individual radiologist should be made. As the outcome of a performance-induced FPPE is so important, the review, decision,
Steps For Initiating an FPPE
An ad hoc FPPE Committee should be convened by a Department Chief when data derived from Medical Staff or Medical Center committees or processes indicate that the performance of a specific radiologist may be deviating from established standards of care or professional conduct and may need improvement. Implementation of an FPPE may also be instigated through a designated practice group or physician organization, as well as through complaints from customers, including referring physicians and, in
Steps in the FPPE process
An FPPE should be conducted in a flexible manner designed to foster a review process that is consistent, timely, balanced, and fair. As a basis for assessment, evidence-based and benchmarked standards of care and practice should be used whenever available. The radiologist whose performance is under review should be provided with written notice of initiation of an FPPE by the Department Chair. This notice should include information regarding committee composition, the proposed timeline of the
Tools to Facilitate the Evaluation process
When evaluating an adverse outcome from any diagnostic or procedure-related event, 3 common tests can be applied to assess a radiologist’s performance:
Accountability test: Is the radiologist accountable in any way for what went wrong? Initial determination of the accountability of an individual radiologist, when a serious adverse event occurs and human error is implicated, can be assessed by an algorithm (Fig 2) based on a model developed by James Reason.2
Substitution test: Would a similarly
Record Keeping
The findings and conclusions of the ad hoc committee should be summarized in a written report, which should be maintained within the Department Chief’s peer review file for the specific radiologist. This report should be submitted to the Chief of the Department in cases where the chair of the committee is other than the Chief. The final report of an FPPE is usually maintained in the hospital or practice credentials file. All data supporting the FPPE competency assessment must be available for
Disclosure
A critical legal question is whether FPPE evaluations are discoverable in the case of a lawsuit relating to the initiating or even future adverse or sentinel event. To be purposefully provocative, we question whether any current remedial action, or even the very fact that an FPPE was required, has to be disclosed to a patient as part of the informed consent process for a future invasive procedure related to the FPPE. If not disclosed and something goes wrong, the patient could always argue that
Possible Outcomes of an FPPE Process
The Chief of the Department should make final recommendations and communicate them in a timely manner to the radiologist under review. Where applicable, the recommendations should be immediately implemented by the Chief of the Department, or delegated to the radiologist’s Division Chief. The radiologist may engage in voluntary corrective action that is consistent with the Chief’s recommendation.
Where appropriate, the Chief of the Department may take disciplinary action, the nature of which
Managing the Outlier Radiologist
How should a radiologist and the entire process be managed when the FPPE results raise more serious concerns? On a personal note, we are strongly opposed to terminating the contract or privileges of the radiologist, as this does not facilitate any improvement and may simply allow the radiologist to move elsewhere and provide the same concerning level of patient care. In certain circumstances, especially when matters of professionalism are concerned, it may indeed be necessary to remove
Summary
The FPPE process is a mandated mechanism designed to serve as a competency evaluation of a physician. When data from ongoing screening evaluations require that such a focused evaluation take place, the radiologist deserves the right to be thoroughly evaluated by his or her peers in a fair, thorough, discrete, and constructive manner, with the goals of identifying and implementing improvement practices.
References (4)
- 〈http://www.jointcommission.org/jc_physician_blog/oppe_fppe_tools_privileging_decisions/〉 (accessed on June 1,...
Managing the risks of organizational accidents
(2003)