DISCUSSION: Draft By-Law Amendment – Posting of Quality Assurance Committee SCERPs (Consultation Closed)
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What is the benefit of being so transparent?
Is it to create more work for your 265 staff members or to smear doctors who were randomly targeted by one of your staff members to justify her salary as the college has 3 times more employees than comparable bodies in USA???
Quality assurance committees are meant for educational purposes and not to feel reprimanded.It is supposed to have a positive impact on the practice.I do not feel it needs to posted.
Since the QAC acts only to suggests remedial action as a result of say peer review or other non-complaint issues, it should not be able to make public the remediation procedure. If a complaint had been lodged and the physician found guilty that is a different matter.
If you publish SCERPs imposed by the Quality Assurance Committee it may unduly punish some good and conscientious physicians. A physician could be selected randomly to for a peer assessment and be reviewed by a peer physician who is overly critical. The QAC may invite the physician in for an interview and the physician might be perceived poorly by the committee, perhaps because of his or her anxiety. The committee might ask the physician to attend a course the improve his or her charting.
If the physician attends the course and his or her charting is shown to be improved a year later then the “educational” mandate of the quality assurance process would have been served. But if the SCERP is published, a local newspaper might report it and this good and conscientious physician might be embarrassed and ashamed. This punishment does not fit the crime.
If the physician did not improve after a year and was interviewed again by the committee it would be reasonable to publish any SCERP the committee decides to impose.
I therefore strongly oppose any publication of SCERPs by the college for physicians that are randomly selected for assessment. If the college proceeds with their plan to make SCERPs public then they should establish an appeal process in which a physician could request another assessment prior to the imposition of the SCERP to ensure that the first assessor was not overly critical.
I object to SCERPs arising from the QA Committee being placed on the Public Register. This does nothing to guide the profession or protect the public and can be devastating to the physician undergoing remediation.
This would be inconsistent with QA and QI. Airline industry is leading in this area and they have complete anonimity to ensure full and active cooperation. Any punitive implication will be completely counterproductive to QA and QI program.
There is much talk about education and improving quality of care in a non-punitive manner however this seems to be a step in the opposite direction.
Not sure if the balance between benefit to the public from a QA committee finding and the stigmatization of having a finding listed beside a doctor’s name is fair. It could invite vindictive or vexatious complaints; would there be a sunset clause to this? Up for a certain period of time? And given the recent publication in the Toronto Star of a list of OB/Gyns with college findings that seemed to tarnish by association an entire specialty, are you sure this is in the public interest, and far outweighs the potential reputational damage done? I’m not sure it does; I don’t feel they need to be posted.
I must agree with all the previous comments. Publishing SCERPs serves no benefit to anyone. Indeed it may foster an unnecessary feeling of resentment and embarrassment for the physician. I think that any well meaning physician would be embarrassed enough, and hopefully grateful enough, simply having deficiencies pointed out by the assessor. I think that once the physician is aware of needed changes to his practice, he/she should be allowed to make those remedial changes. If the changes/improvements are made to the satisfaction of the QAC, then the purpose of the QAC has been fulfilled. If the remediation, in whatever form, has not occurred and the problems persist, then publication of the SECR would not be unreasonable. Thus, there might be an incentive for the physician to make the required changes, knowing that if he or she does not comply, the physician’s name will be published. I strongly agree with all replies below, and reply #4 nutshells my thoughts exactly.
The reality is that the CPSO is progressively viewing physicians as piranhas. The attack on methadone physicians, and the patient bill of rights are just a few examples. SCERPs were intended to be educational for a physicians. I, and an increasing number of physicians here in Ontario, believe we need to move away from CPSO self-regulation and to more a a US based model, which would be fair.
The proposed change to include SCERP recommendation by the QA Committee to be published on the registry of physicians goes against the non-punitive nature of QA undertakings.
It will encourage physicians to take an adversarial position ( therefore legal stance ) when investigated by the QA Committee. The truth may suffer and it will not promote honest assessment of the issues in question. It is a regressive step in the name of bigger transparency.
I feel that SCERPS are an important part of quality assurance. However, if a low risk physician is required to undergo an educational program and this is made public it would have a number of potential adverse consequences. This may unduly shame him/her, affect his/her ability to gain employment opportunities or even adversely affect their ability to garner patient trust. I believe the point of this program should be education, remediation and public safety – not physician humiliation!
Making the possible outcome of an assessment punitive would interfere with the objectivity of the assessment as well as deterring from the educational value and mission.
I object to SCERPs arising from the QA Committee being placed on the Public Register. For physicians wrestling with mental health issues, a negative finding could result in the suicide of one of our colleagues. I do not want this on my conscience.
The QAC was developed for educational purposes and any public disclosure of physicians who comply with their recommendations has no benefit to the public.
This group of public consultations is certainly interesting.
On one hand you have the CPSO asking we pay a dinner at Moxie’s each for their operations.
On the other hand we have policies that are drafted to embarrass and shame physicians rather than work with them to improve the care they provide. This is along with specialized stylish Fincher-esque photography used on the intro page for this policy, with fun corporate words like “Accountability” drawn up on a window and a faceless tie-wearing guy blurred out in the background. All of this seems like a terrible waste of money for the CPSO in light of recent austerity measures.
I am concerned that this goes against QA’s educational nature which is it’s strength.
QA Committee supposedly helps physician to improve and provide better service to the patients, To make SCERPs public serves No educational purpose. It just creates more work for the college staffs, is it a means that the college want to hire more staff? Or to justify its huge number of staff ? As suggested by Physician 1 response.
I agree with the previous posts, and strongly oppose any publication of SCERPs by the college for physicians that are randomly selected for assessment. It would do nothing to protect the public – and only provide the public with another avenue for doctor bashing. It is clear to me that the CPSO has, in recent years, developed a severe case of “political correctness’”, that representing and supporting doctors is no longer part of its duties, and that we – the members – are on our own.
I don’t see this kind of transparency amongst other professionals, like teachers,pharmacists, dentists,etc.
I think this will add more stress to the assessment and the college might have a difficult time find assessors.
It adds a lot of pressure on their role as educators.
I object to SCERPS arising from QA. The Arline industry has it right by providing anonymity. Comments posted online will not protect the public but will devastate careers. The public knows about the CPSO – my disgruntled neighbour threatened to go to the CPSO with a false complaint to get even me. The CPSO can protect the public without posting SCERPS from QA for the whole world to see
The CPSO has stated that it is moving to education as opposed to penalty for physicians who may a deficiency. By making SCERPS public, you are publicly shaming physicians, akin to a discipline committee. I see no need for this if education is the trajectory of the CPSO. Certainly is the CPSO finds multiple deficiencies over time and recommends 3 or more SCERPS, then this should be referred to discipline or higher penalty. However, a SCERP recommendation as a result of a Quality review being public totally defeats the purpose of education for physician, and publicly shames them for no gain to the public.
While the college proceeds with QA transpareny as a benefit to the profession and public it has had negative consequences in the past as the published comments allude to. Hopefully they won’t be dismissed as relatively unimportant.
There is well deserved criticism of the process and inter-reviewer variability needs to be fully addressed in all QA processes before proceeding. It is not enough to review this after the fact in a committee. It is not enough to provide training for reviewers or structure for the interview review process.
The reviewers need to be validated.
The stats about any reviewer need to be published.
In the past peers brought real life experience to the review; in the present environment structure will be perceived as more rigid and unrealistic.
The evidence base needs to be established and shared widely within the profession specifically for the type of QA and QA transparency based on diagnosis, procedure,and specialty showing higher adverse outcomes, highlighting patient harm from misdiagnosis.
I agree with previous posts that the QA is to be educational not punitive. I have also been involved in a performance review which initially required remedial work for a physician but when the case was reviewed by the CPSO the physician received a full apology. Mistakes are made in reviews. This is not a program that was built to be transparent for the public.
Re QAC SCERP’s
I would heartily agree with previous comments re educational and remedial nature of this process.
Putting the results on the public register strikes me as a punitive measure.
I would also like to comment on the process of QAC. A colleague has recently undergone the ‘new’ process which seems overly complicated and almost impossible. It appears that a number of other health care professionals or administrative staff need to be responding to the process and examples given are not realistic ie radiologist, lab personnel. If one is a practitioner in solo or small group practice you may not have enough interaction on a detailed medical level with allied health care professionals or colleagues for these folks to know your skill set to fill out an evaluation. It appears the process may be punitive to docs in small group settings and there are still people in small communities in small groups.
The process seems appropriate for cities and large groups only. Has anyone else felt the same way?
To whom it may concern
I disagree with including these results in the public register.
From discussions with other health care professionals it does appear that different assessors may come to very different conclusions regarding the same individual. There seems to be some deficiency is quality assurance in house between assessors.
For example why would a physician who practices in California be used as a ‘peer’ for an Ontarian doctor as happened to a colleague? How could someone practising in such a different health care system be a valid person to ‘judge’ a physician in Ontario. This makes no sense. Unless it is crystal clear that all assessors are interchangeable it would be one person’s opinion becoming public record for a physician in contrast to most other public records decisions being made by committee.
Absolutely not to a fee increase. Fees are a huge bone of contention already. Doctors are already disheartened by the lack of respect from government. Don’t compound it.
If you really need the money, then go for a decent fee increase. $25 is the equivalent of a slap in the face.
Am also opposed to posting of QAC SCERPs. I have been a peer assessor for almost 20 years.
Transparency, you say? Humiliation, more likely. Thought this was supposed to be an educational experience. Are we now heading more towards punishment? A number of doctors get into trouble in their later years as their skills diminish or their judgment falters. 40 years of good service to the profession should be worth something. Let them improve with dignity. If they can’t , then, it’s time to retire.
Having sat on the board (council) of one of Ontario’s Regulatory Colleges my objection to publishing SCERPS stems from that excellent and enlightening experience.
So many of ‘we’ the public neither know what a Regulatory College is,nor understand the public protection mandate.
A SCERP – taken out of context – would do a disservice to both College and physician.
Is this just another policy to pander to the physician-hating public, in an effort so the College maintains its “self-regulated” status?
I have licenses in the other jurisdictions and none subject their members to random audits, much less to publish the results on the internet as now you want.
All you are doing is scaring good doctors out of Ontario.
Every year you come out with more policies to keep pandering, which require more money to administer. But unlike a gov-run licensing body, you see an endless pot of cash, which is why you keep raising the fees unilaterally. What is the end point? what will it be like in 5-10 years? A camera in every doctor’s office? Every complaint put on the internet? And an annual fee of $5000? At the rate you keep churning out policies, these things are not really unrealistic. As physicians, we have no unions and OMA does nothing to fight back against anything, the only we can do is leave Ont or leave the profession, which many are doing or considering in these toxic times.
This profession is doomed.
Audits are not much more than an exercise in record keeping. Physicians nowadays spend 1/2 their time documenting and the other 1/2 actually treating patients. With these policies the College wants to change that into 2/3 record keeping and 1/3 treating patients.
All this while the ministry keeps cutting our fees. So basically the College, like a proxy of the gov, intimidates doctors into increasing the standard while the gov itself cuts our fees. It’s like a pressure crunch from both sides.
I discourage my kids and everyone else from entering this god-forsaken profession, in this province that views doctors as slaves with no union or other employment rights.
I do not agree – it is of no value except increasing the staff of the lovely CPSO that will lead to another CPSO fee increase.
public humiliation,before finding guilt. how is this possible in a democratic country?
One word, NO.
In case I did not make myself clear, NO.
as in NO, NO, NO.
Anyone have difficulty understanding that?
The response to the proposal should be NO, NO, NO.
Professional Association of Residents of Ontario (PARO)
Response in PDF format.
Dear Staff at CPSO,
I do wholeheartedly approve of your idea to the proposed by law amendment which would allow the CPSO to add QAC SCERPS results from moderate to high risk situations be added to the doctor’s profile on the Public Register.
I hope that this happens very soon.
FAIR (Fair Association of Victims of Accident Insurance Reform)
Response in PDF format.
College of Audiologists and Speech-Language Pathologists of Ontario
The College of Audiologists and Speech-Language Pathologists (CASLPO) applauds the College of Physicians and Surgeons’ (CPSO) commitment to transparency. However, we have some reservations about making public a Specified Continuing Education or Remediation Program (SCERPs) issued by the Quality Assurance Committee. Our reasons are twofold. First, one of the most effective means to protect the public is to promote a robust and supportive Quality Assurance process. Truly effective Quality Assurance requires member commitment to all facets of the process. If members consider the process potentially punitive, compliance might become an issue adversely affecting quality. Second, if the Quality Assurance committee is seriously concerned about the member’s practice, it has the ability to refer that member to the Inquiries, Complaints and Reports Committee (ICRC) with allegations of professional misconduct as per Schedule 2 of the Regulated Health Professions Act, 1991, Section 51(1) (b.0.1).
CASLPO is in full support of making public SCERPs issued by the ICR Committee.
Response in PDF format.
Ontario Trail Lawyers Association
Response submitted as PDF.