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dont understand the revision, unless it is to allow doctors to set up shop and become independent practioners, such as cosmetic and dermatologist type services without inspection by the college. I would not be in favor of this.
I am not sure if that proposed Amendment how much it would impact safety for patient and public.
I would like to suggest that all investigations whether positive outcome or negative outcome be made available to the public in order to provide a balanced reporting of college activities and physician standards. Currently the emphasis is on reporting of negative outcomes only providing a skewed profile of the profession to the public. I suspect that this current process does not create public trust as there is no kudos or acknowledgement given to the physicians who are meeting the standard of care, only repercussions to those who fail the standard. A new process should include practice reviews, clinic reviews and the complaints process.
I don’t agree with your “balanced reporting”. All clinics are expected to meet the standard by default and it is not the college’s job to endorse a clinic but to root out bad apples.
As owner operator of a private endo clinic in Ontario I feel IHF should never have been excluded in the first place from the inspection process. I strongly agree especially if we are going to be come IHFs that we need inspections.
There has been significant financial burden placed on clinics, physicians with the new IHF fee policies. This will now add a layer of extra fees, and inspections for sites providing IHF and OHPIP inspections, making these facilities financially and operationally unsustainable.
I strongly object to this given the current existing burden of IHF requirements. Many clinics are small operations and these multiple layers of requirements are not feasible.
I fully agree with this physician’s statement.
An excellent example of the college extorting money from clinicians is the annual ” Out of hospital premises registration fee “, which was $ 825 in 2012 and subsequently increased to a ridiculous and dramatic $ 4175 in 2013. When I called the relevant department at the college inquiring about the rationale for such an increase, I was informed that this charge was now being levied per clinic and not per clinician ( as was previously done in
I was also informed that I could have ” complained ” or written some sort of letter to the college indicating my displeasure regarding the above situation. I should note that the $ 4175 billing invoice I received from the college was my first notification that they had chosen to increase this fee by 500 % on a per person basis.
This nicely summarizes the college’s ridiculous bureaucracy and cash grab mentality.
the college should not change this ammendment.
While this is a simple solution in principle, having additional clinics to be inspected by the CPSO will only serve to add additional cost to the OHP inspection program This additional cost will then be passed on to the clinics leading to even higher annual and inspection fees. Unless the government subsidizes some of this additional fee burden, this plan will not be sustainable
This whole programme is a nonsensical make work programme to justify the ever enlarging tentacles of the College. It is of no value and serves only briefly assuage the voracious appetite of the bureaucracy for more power.
Agree that all clinics conducting colonoscopy should be inspected under the OHPIP program in addition to any inspection under the IHF model.
I fully support this proposed change. As a public health preventive medicine consultant, I was heavily involved in assessing thousands of patients of an endoscopy clinic that failed inspection. Fortunately, no evidence of HIV, hepatitis B or hepatitis C transmission between patients was found. However, without the inspection program, future patients would have remained at risk. All endoscopy services, wherever located in Ontario, require periodic assessment for clinical competence including infection prevention and control.
Inspection a must, substance of inspection should be improved. From current OHPIP program, so that facilities don’t game quality, day of inspection. However this should not be a cash grab. IHF process costs to facilities is 25% of OHPIP costs, if endoscopy clinics become IHF’s should have similar cost structure. Further endoscopy IHF/OHP’s are different than surgical OHP’s and the requirements need to be more refined and realistic, and the assessors more transparent. The Program to date was a good first step, but now needs to evolve and improve specificity of evaluation.
either but not both. a profusion of regulatory operations leads to confusion.
Outpatient colonoscopy clinics need to be inspected. If OHPIP function to the IHF doing colonoscopy adds to the cost of the function out of a hospital environment, then these costs need to be resolved before moving such services into IHF with the needed inspection and absolute requirement for OHPIP inspection.
Such procedures are presently being done in outpatient service areas of acute hospitals which already have infrastructure that undergoes regular assessement and oversite and accreditation…..Why do we need to move them to IHF????Patient safety is paramount and should be protected at all cost. moreover if it is not broken why change it?What am I missing??
The hospital outpatient departments do not undergo any inspection currently. The standards to pass inspection for an Out of Hospital Premises are much higher than anything that was ever applied to a hospital department. The IHF, and the hospitals, should be subjected to exactly same standards of inspection. By the way, it is ‘broken’ – the hospitals are broken and need to be ‘fixed’, or at least improved to same standards as outpatient clinics.
I agree. The standards for OHP are higher than the hospitals. I refused to give deep sedation for colonoscopies at an hospital I was going to apply to because they did not have capnpgraphy available. They do not have to according to the public hospital act, but the OHP rules require them to have it available. FIX the hospitals first instead of being “holier than the pope ” with OHP.
As an owner of endoscopy clinic I believe that inspections are needed but I don’t believe that the
College is doing a good job but simple creating another
Source for excessive charges.
If become IFH the clinics inspections should move out of college inspection and only be under IFH
Current amendment is going to add another
Reason for college to increase the charge for
Unreasable inflated program costs
Wait and see
It seems sensible that all facilities be merged under one inspection process with the process being as transparent as possible so as to ensure public safety.
It’s not what name-tag you use. As an OHF owner, I don’t see value for the fees. Like “Parkinson’s Law”, work begets work, committees create sub-committees and bureaucracy increases, even if the real work decreases. (All existing clinics have been inspected and round two won’t start for a few years).
I suggest two unrelated bodies: one that creates standards and interprets medical evidence (like the judiciary) and another that ensures compliance and enforcement (like the police). The reasons for separation extend beyond preventing the feedback loops that speed Parkinson’s Law, but it also protects rights and gives greater transparency.
All facilities, whether IN or OUT of hospital should be inspected. There are clinics running outside of the IHF label that are NOT being regularly inspected…so simplify and keep it inclusive. ALL facilities should be prepared to demonstrate Best Practice and become publicly accredited. This would indicate to the public those facilities maintaining the standards required to perform the procedure. These standards should include physical, procedural and bookkeeping/billing. The facility should be required to pay for inspection. They will ultimately value from being able to display / advertise the value associated with maintaining the accreditation. It is one thing to regulate but another to police. More money needs to be spent on policing, not policy making…get seasoned HCP’s in the trenches doing inspections, making recommendations and monitoring follow through. If you have nothing to hide you hide nothing to loose to be transparent.
I feel that as the CPSO already has developed the resources and protocols for proper inspection and quality control for out-of-hospital clinics it makes more sense to extend that program to IHFs rather than remove existing ones away from it.
Inspections require resources and if there is a limit on the time, money and workforce, it is better to be placed where the horse’s mouth is and where it is most vulnerable to erosion. There are lots of checks and balances in place in the hospitals officially and otherwise which are not present in those clinics and those checks make such college inspections redundant.
I disagree. See my post on number 13 reply. Hospitals are not as overviewed as you think.
I have gone through both OHP inspection and hospital accreditation in 2012. I can tell you that our hospital’s endoscopy department was ‘inspected’ as part of a 20 second walk through. Subsequently, hospital was awarded ‘exemplary status’. My OHP, meantime, was turned upside down and inside out starting with policy manual, to staff credentials, to ventilation, to chemical storage, to every single piece of equipment, to quality assurance programs, etc. The process is certainly much more thorough in an OHP, there is no comparison with the hospital accreditation. If the hospital endoscopy unit was inspected in the same way, instead of ‘exemplary status’, they would have been awarded a long list of recommendations.
There should be same process, same standards, and same way to enforce standards irrespective of the location. This should apply equally to OHP, IHF, and hospital outpatient departments. Current process established by CPSO is a good one, however, the costs are out of control. There needs to be some major restructuring applied to the process so that it becomes sustainable. At the moment, each OHP facility medical director is billed in the area of 4500 per year. Inspection fees are extra, I paid another 1700 for the first inspection and 3500 for the second inspection. Plus there was an initial application fee. So I am not sure why this is so expensive, I think it is unreasonable, actually. Hopefully as IHFs are introduced to be part of this, the cost is not increased further.
It will be important to have one standard and one set of expectations for IHF’s and OHP’s – thus both types of facilities should be subject to the same inspection process.
Onerous inspection for a simple small ultrasound is unrealistic. You will succeed in forcing the use of uninspected (and expensive to the patient) alternatives.
It seems that this is a good idea…it keeps the CPSO on top of all the clinics..both IHF and OHPIP types…
I would support this because it keeps all the clinics up to the same standards and keeps the CPSO responsible for the inspections.
It is hard to understand this…so not surprised with the confusion..
its a good thing…and I support this recommendation.
I feel that the College’s Out-of-Hospital Premises Inspection Program is an effective and efficient approach to the inspection of these clinics. It would be more independent, professional and without alterative motive.
The proposed new definition of “Premises “ is sensible and brings into conformity with other existing Independent Health Facilities.
I just read my Dialogue. My view has always been and I do not see any reasons change it : The CPSO pays lip service to dialogue and then does what they always intended to do anyway. Treating family is an example. Most physicians objected in most cases, but what does the CPSO care. They will “guide”the profession anyway.
I believe only one inspection process is required.
If a clinic transitions to an IHF, then it should be accountable on the criteria of an IHF.
If it stays as a clinic, then the OHPIP program is reasonable.
This is for the sake of reducing: costs, redundancy and using our precious resources in the most efficient manner.
I AGREE THAT THOSE CLINICS THAT FIT THE CRITERIA FOR INSPECTION, SHOULD BE INSPECTED UNDER OHPIP/IHF FOR PATIENT SAFETY,BUT ALSO WITH VERY REASONABLE CHARGE AND CERTAIN CRITERIA FOR THE CHARGES .
It appears that many do not understand what the IHF program is or how the quality assurance is managed. Each of the 12 different kinds of IHF has its own standards document, called Clinical Practice Parameters and Facility Standards (see them at http://www.cpso.on.ca/Policies-Publications/CPGs-Other-Guidelines).These are developed and updated by task forces of the CPSO. IHFs are inspected by the CPSO to see that the standards are met. Until recently the MOHLTC paid the CPSO to perform this quality assurance function, but recently the costs have been transferred to the IHF facilities themselves, with no increase in their funding to cover this cost, which has risen already and is in the 1,000s per year per clinic.
College of Physicians and Surgeons of SaskatchewanCPSS is not sufficiently knowledgeable about the implications of the change to comment
Response in PDF format.
I DO NOT KNOW IF THIS WILL MAKE ANY DIFFERRENCE TO PATIENT SAFETY
I am not sure why it would be necessary to change the current review process and practice for IHF facilities as they are already reviewed and inspected under the IHF process which has served IHF institutions and their patients well for many years with excellent patient safety rates.
IHF’s were created to fill specific needs within our communities and they have done so for many years with good results, excellent patient safety and well managed financials and unless the entire system is overhauled (which would also need to include IHF funding to meet updated or changed standards in moving from IHF to OHPIP – which appear to be different in some settings) changing the manner in which these facilities are reviewed and inspected could create patient barriers and access issues for certain patient demographics.
For over 25 years we have managed abortion care services in an IHF setting, with appropriate medical standards for our patient demographics in ambulatory settings, created by people who were not only skilled and knowledgeable about our field and patient base but also experienced in our specific field of expertise. They were also created by individuals who not only work in hospital settings but also within facilities such as ours and by people who have worked long and hard to provide the large majority of abortion care services in this province.
It is shocking that we are being unilaterally moved in this manner and that our specific needs or circumstances / practices would not be taken into consideration but rather amalgamated with services such as colonoscopies, which does not take into consideration the sensitive nature of the differences within these service groups, let alone delivery of said services and the vulnerable nature of the abortion services patient group.
We are all in favour of better, improved or safer working standards and inspections/reviews but it needs to be reflective of our patient demographics and individual patient populations and the realities within our field or scope of practice – rather than a mass amalgamation of surgical services. However, it is incredibly baffling why new inspection systems or standards are being considered by the CPSO through the OHPIP for abortion facilities when in fact there was already a fully functioning, highly effective and established Induced Abortion CPG document and program already in place from the CPSO, which the IHF, along with the CPSO and the CNO, have been using to manage abortion care IHF facilities and clinics for over 20 years with stellar results, patient safety records and good financial management.
It seems highly disrespect to this undervalued and under appreciated group of service providers to go around the very CPG’s and inspection standards originally created by individuals selected by the CPSO to help establish guidelines for care for these kinds of facilities and for our specific patient group – a document that has helped to provide the large majority of abortion care services in Ontario, and especially those within IHF’s (and most of the other non-IHF or funded abortion clinics modeled their care from the original CPSO induced abortion document until the OHPIP program came into play and amended the practice guidelines and created a different CPG document altogether)
It is perplexing that a system that inspected and accredited 5 Ontario abortion clinics for approximately 20 years with excellent medical and safety results (the numbers do not lie) could just be altered to change the manner in which we provide service, see patients or get inspected without any consultations with the actual IHF clinics performing the bulk of these services. By scraping or disregarding the current medical protocols and systems that have been working well for many years in Ontario for patient seeking abortion care services and creating a new system that is oblivious to the service we provide, the patient group and the financial considerations that will be necessary to change the manner in which IHF’s provide service and operate in view of changed or amended OHPIP or IHF standards, could create access and service demand issues for our patient population.
The politicalizing of abortion care services in Ontario will create patient service issues and access problems and it is sad and demoralizing that after so much was invested in ensuring publicly funded abortion care access and services for the women in our country, that the services will now be bulked in with things like colonoscopies and other elective or cosmetic surgeries, which does not share similar patient safety rates as abortion care services within these settings.