780.4 Development of Review Mechanisms 730.41 PSRO Responsibility. The PSRO shall assure the active involvement of non-physician health care practitioners in all phases of the development and implementation of those review mechanisms which will be used to assess the performance of non-physician health care practitioners. 730.42 Hospital Responsibility. Any hospital which receives delegation of review activities from a PSRO is expected to involve non-physician health care practitioners in all phases of the development and implementation of those review mechanisms which will be used to assess the performance of non-physician health care practitioners. 730.5 Health Care Review 730.51 PSRO Responsibility. The PSRO is responsible for assuring that nonphysician health care practitioners are involved in the actual review of care provided by their peers. 730.52 Hospital Responsibility. Any hospital which performs review under delegation from the PSRO is responsible for assuring that, where such review involves assessment of the care of non-physician health care practitioners, nonphysician health care practitioners perform the assessment of their peers. 730.53 Where care is provided jointly by physician and non-physician health care practitioners, the assessment of such care will be performed jointly by peer physician and non-physician practitioners. 730.54 Where care is provided exclusively by one type of non-physician health care practitioners, the assessment of such care will be performed by peer nonphysician practitioners. The decisions made during such review would be reported through the mechanisms established for review decisions related to physician care. 730.55 Only physicians will be allowed to make final decisions on the care provided by physicians. 730.7 Organization Those types of non-physician health care practitioners whose care is being reviewed under the aegis of a PSRO are responsible for developing mechanisms by which the results of review are utilized in the continuing education of such practitioners. 730.7 Organization Where appropriate, the organizational structure established to provide for involvement of non-physician health care practitioners in the activities listed above should be the same structure established for the performance of these activities by physicians. For example, committee (s) should include physician and non-physician practitioners. 730.8 PSROs must show evidence over time of adherence to the guidelines listed above. STATUTE OF THE AMERICAN ACADEMY OF PEDIATRICS Public Law 92-603 (HR 1) created the Professional Standards Review Organization Program, which mandates the establishment of organizations at the local level to review professional standards of medical care in the institutional setting. The American Academy of Pediatrics has traditionally promoted standards of health care for all infants and children in the United States, Canada and Latin America through the various manuals and committee statements. Recently, it has been in a leadership role with other primary care physicians' organizations (American Medical Association, American Academy of Family Physicians, American Osteopathic Association, American Society of Internal Medicine, etc.) in a study of quality assurance of child health care in the ambulatory setting, to be completed in late 1974. The Academy's Committee on Hospital Care has been engaged in the development of criteria for assessing quality care for infants and children in hospitals, and has cooperated with the American Medical Association and norms and criteria for patient care, which can be modified to fit local situations. The American Academy of Pediatrics has supported and will continue to support the concept of peer review as a method of assuring the delivery of an acceptable quality of pediatric care. This policy and the aforementioned activities are consistent with its objective to "foster measures and conduct activities directed toward establishing and maintaining the highest possible standards of quality and acceptability in the delivery of health care to children." Professional Standards Review Organizations (PSRO) represent a method of accomplishing peer review of pediatric care. The Academy recognizes that varying opinions have been expressed regarding the acceptability of specific provisions in the law. With these in mind, however, the Academy feels that PSROS should be given every opportunity to prove their effectiveness in assuring better quality pediatric care through the cooperation of all physicians delivering child health care. As implementation of the law progresses, every effort should be made to maximize the acceptability of the PSRO system with both patients and providers through appropriate and timely changes in the system. The American Academy of Pediatrics encourages all providers of child health care to cooperate in the implementation of the PSRO law through participation at the local level. The Academy will also continue to work cooperatively with all concerned organizations in the implementation of the law and also in seeking any changes that would maximize the acceptability of the PSRO system with both patients and providers of child health care. AMERICAN ACADEMY OF PEDIATRICS. AAP ISSUES PSRO STATEMENT EVANSTON, ILL.-All providers of child health care should "cooperate in the implementation" of the federal law which establishes Professional Standards Review Organizations (PSROS), the American Academy of Pediatrics has urged in a policy statement. The statement, approved by the AAP's Executive Board at its spring meeting in Bal Harbour, Fla., said the Academy as an association will "continue to work cooperatively with all concerned organizations in the implementation of the law and also in seeking any changes that would maximize the acceptability of the PSRO system with both patients and providers of child health care." The PSRO law was passed by Congress to create local organizations to review the professional standards of medical care in the institutional setting. The PSRO law has been the subject of controversy within the medical profession. The AAP statement noted that objections to the law had been made, but said that "PSROs should be given every opportunity to prove their effectiveness in assuring better quality pediatric care through the cooperation of all physicians delivering child health care." The statement said the Academy has expressed similar interest in the quality of care through its work with the Joint Committee on Quality Assurance and the AAP's Committee on Hospital Care. The PSRO statement was drafted by the Academy's Council on Pediatric Practice and has been reviewed by its various District Committees. AMERICAN NURSES' ASSOCIATION, INC., Hon. HERMAN E. TALMADGE, DEAR SENATOR TALMADGE: The American Nurses' Association is the professional organization of registered nurses representing 200,000 registered nurses with constituent associations in fifty states and three territories of the United States. We are pleased to have this opportunity to express our support of the concept of peer review of health care services and respectfully request that this statement be made part of the official record of the current hearings to evaluate present and proposed implementation of the professional standards review legislation. The American Nurses' Association, since its inception in 1896, has consistently demonstrated its concern for the development and implementation of professional standards through: promoting state legislation to regulate the practice of nursing; developing standards for the preparation of individuals to enter the practice of nursing; establishing a code of ethical conduct for practitioners; developing Standards for Nursing Practice; standards for the organized delivery of nursing services; and stimulating research designed to enlarge the knowledge on which the practice of nursing is based. As a result of more than a decade of diligent work by hundreds of nurses, in 1973, the American Nurses' Association issued general standards of practice and specialized standards in five areas of practice, namely, Medical-Surgical nursing, Maternal and Child Health nursing, Psychiatric and Mental Health nursing, Geriatric nursing and Community Health nursing. To our knowledge nursing is the only health profession to have voluntarily so moved beyond establishing a code of ethics to specify standards of practice. Currently, a major thrust of the Association is implementation of these standards. This is being accomplished through certification for excellence in practice, the development of out-come criteria and other tools to evaluate the quality of nursing care and promoting peer review mechanisms and the use of nursing audit. The American Nurses' Association supports the basic principle of the ac countability of all health care professionals to provide care which is of a high standard and which is available and accessible to all people at a reasonable cost. Furthermore, the ANA acknowledges the right of the public to be assured that the care received is of a high quality. We believe that it is the obligation of government as representing the people to insure that health care services meet professional standards. Providing support for the development of peer review sys tems is an appropriate mechanism to insure that professional standards are met. The public would be better served if it were fully recognized that Health Care and Medical Care are not synonymous terms. Health Care Services encompass a wide range of activities designed to maintain the physical, mental and social well-being of people. Several health care disciplines must be involved in planning, providing and evaluating health care and each discipline must be ac countable for the quality of its own practice. Health care to the population to be served under Title XVIII and XIX of P.L. 92-603 can be adequately evaluated only when the professional care provided by all disciplines are evaluated by members of the disciplines. This is a critical step in the direction of interdisciplinary review of all patient care provided. Nursing is an essential component of health care. As the largest group of health professionals in the United States with 825,000 nurses actively engaged in practice, nursing as a profession has a significant role to play in any health care system. Physicians do not possess the knowledge and skills of the discipline of nursing. Peer review which incorporates the review of nursing care by physicians is, therefore, not in the best interest of the public. We urge that the legislation be amended to provide for true review of nursing care by nurses. The recently published Program Manual by the Office of Professional Standards Review-Department of Health, Education and Welfare, in chapter VII, pages 31-33, makes reference to the involvement of "non-physician health care practitioners in PSRO Review." This section of the manual appears to reflect a genuine interest in the Department of Health, Education and Welfare to involve other health professionals in the mechanisms for review of care. However, in the absence of explicit provisions within the law to include representation from nursing and other health care disciplines as full partners within the councils and committees at the national and local levels, this regulation cannot be fully implemented. The ANA urges your committee to give immediate attention to amending P.L. 92-603 to provide for the full participation of all health care disciplines in implementing a system of true peer review. While such amendments are under consideration, we urge provisions be made through appropriations to assist all health care disciplines in developing appropriate norms and criteria to evaluate the quality of care they render. The nursing profession recognizes that cost containment and reduction of over-utilization of costly services is a prime objective of the PSRO Program. If both cost containment and evaluation of quality are to receive appropriate attention, it might be well to consider two distinctive types of review: (1) utilization review, which would examine both over and under utilization, and (2) review of the quality of care provided. To be effective, utilization review must be an interdisciplinary undertaking. In conclusion ANA commends the Finance Committee for its leadership evident in this legislation. Respectfully submitted, EILEEN M. JACOBI, Ed.D., R.N., Mr. MICHAEL STERN, Staff Director, Senate Finance Committee, Dirksen Senate Office Building, Washington, D.C. DEAR MR. STERN: Following "Statements for the Record" are submitted in response to the invitation soliciting views of various individuals on the PSRO issue. At the same time this writing may be considered as follow up to a correspondence which took place nearly two years ago between Senator Wallace Bennett and myself-copies of that dialogue are attached for reference. Summarizing what has taken place since that time, I believe; (a) Intergovernment power struggle has temporarily subsided pending the implementation stage of PSRO. (b) Insurance carriers, fiscal intermediaries, etc. have also suspended their opposition in hopes of deriving even more Federal funds for their services. (c) Health Care professionals have intensified their effort in opposition to PSRO rapidly approaching a point of no return. As you may have suspected by now, I AM ALL FOR PSRO. The people need it to obtain quality health care, the government needs it to help it monitor and direct its huge spendings, the insurance carriers need it to help them provide more precise coverage and health care professionals need it to help them provide better service to the public and modify patterns of care wherever and whenever necessary. PSRO is needed to insure that administration of health care remains with the health care professionals and not government agencies. For the first time the professionals are afforded the opportunity to participate in administration of health care at the policy level. They owe it to themselves and to the public to take full advantage of this position by constructive contribution and wholehearted participation in the PSRO program. With the National Health Insurance program around the corner, now is the time to start the mold that will produce the best form. Another Title XVII or Title XIX will surely result unless everyone interested and specially the health care professionals realize their obligations and support this program. In summary I would like to state that PSRO is not perfect but it is here and it can be of great value to all of us. For any one wrong thing in the program, I can easily point out several more important benefits that we can all use, now. I wish to thank you for your time and attention. Sincerely, M. ALI PARMOON. JANUARY 24, 1973. Hon. WALLACE BENNETT, U.S. Senate, Washington, D.O. DEAR SENATOR: As a private citizen and one who is directly involved in the health care industry, I was indeed elated by the passage of Section 249F of HR-1 Act. Since that date in October, 1972, I have been expecting, exploring, and at 33-013 - 74 pt. 2 - 3 times even explaining the significant improvements that this legislation can bring about. However, it appears that passage of time is slowly but surely altering its direction away from the intended objectives. It seems apparent that unless immediate attention is given to the status of the Professional Standards Review organization effort, it may become totally neutralized and, in fact, further add to the heavy burden carried by the general public for maintenance of our existing inadequate health care delivery systems. One can easily see the tremendous benefits that can be derived from an effective implementation of this section of the HR-1 legislation. Unfortunately, powerful factions in government and private sector have labeled the PSRO effort "An Enemy." They have reached the unspoken agreement to preclude its success. Established administrations within the Federal government see PSRO as a threat to their power structure. The insurance carriers visualize PSRO as a force interferring with their payment methods. While, worst of all, the powerful orga nizations representing health care professionals predict a time under PSRO when mythical sanctions can no longer replace professionalism and expertise. Since those who stand to benefit the most from PSRO's are the general population, and since these people have little to say in the day-to-day operation of the Federal government, unless this matter receives the direct and personal attention of a person of your position, its fate will be decided by those who desire it the least. Any evaluation of our health care delivery system readily reveals the desperate need for an effective implementation of the PSRO program. You have realized this necessity for some time by first conceiving the PSRO concept and subsequently sponsoring its passage through the Congress. I hope and believe that you will bring the power and prestige of your office to insure its successful implementation as well. I would welcome the opportunity to discuss any of the above in more detail with yourself or your representatives. Very truly yours, Mr. ALI PARMOON, M. A. PARMOON. U.S. SENATE, Washington, D.C., February 5, 1973. DEAR MR. PARMOON: I want to acknowledge my receipt of your recent letter in which you express your fears about the viability and effectiveness of PSRO. I don't share your fears and at the moment there really isn't anything that needs to be done or that can be done. I am working closely with Secretary Designate Weinberger who will finally select the man to head the PSRO effort on the staff of the Department of Health, Education and Welfare, and I think that selection may be the key t othe over-all implementation of the program. At the same time, you may be sure that we, on the Finance Committee who fought so hard and so long to get this concept built into our health care system, will be giving this very careful supervision, particularly during the formative months and years. I appreciate your personal interest and if, as time goes on and the system actually gets into operation, your fears continue both the Finance Committee and I will be interested in any information you can give us. Very truly yours, WALLACE F. BENNETT. EAST RANGE CLINICS LTD., April 9, 1974. MICHAEL STERN, Staff Director, Senate Committee on Finance, Dirksen Senate Office Building, Washington, D.C. DEAR MR. STERN: As I understand it, Senator Talmadge's Senate Subcommittee on Health will be meeting to discuss implementation of PSRO legislation. Presently I practice in a 26 man clinic in Virginia, Minnesota. The Secretary of Health, Education, and Welfare has placed Northern Minnesota in a district by itself. That is, he has made three PSRO's in the State of Minnesota. Previously I had written to him giving him the reasons for my wishing and feeling that the entire State should be an entire PSRO. |