Book excerpt: Division Peer Review vs. Committee Peer Review

Many organizations have provided a focused approach to peer review by identifying and addressing clinical practice concerns at the division level rather than escalation to the formal peer review committee. The formal peer review committee is often only used for egregious events of significant trends that require that peer review be conducted at the committee level.

Should a concern arise regarding an individual’s practice deviating from the expected standard, the concern should first be reviewed at the division level by the division chief (in organizations that are departmentalized). The division chief should be given a specific time frame for conducting an initial evaluation of the allegations; this time frame is typically listed in the organization’s peer review policy. The division director should determine if there is any conflict of interest at the divisional level that would prevent the division from conducting the peer review, or whether there is a trend or other concern (such as egregious acts, appearance of bias, etc.) that would be more appropriately handled by a peer review committee for possible corrective action.

If the division chief determines that the peer review can occur at the division level, he or she should complete an individual practice evaluation. This includes clearly documenting review of the case, outcome of the review, and any subsequent education or other action that resulted from the review.

However, if the division chief determines that an unbiased review cannot occur at the division level, or if he or she determines that the incident was egregious or has noted a trend, he or she should refer the concern to the formal peer review committee for further evaluation. The division chief should complete his or her referral to the committee chair in writing within the time frame outlined in the organization’s peer review policy.

The policy for conducting peer review evaluations at the committee level should be clearly outlined in your peer review policy. The policy should include, among other things:

·         Composition of the committee

·         Timeframes for conducting the review

·         The circumstances under which the practitioner under review has the right to meet with or respond to the committee

·         Actions that the peer review committee can take versus actions that must be escalated to the medical executive committee (if applicable)

This week’s excerpt is from Legal Strategies for MSPs & Physician Leaders: Prevent Negligent Credentialing and Protect Peer Review by Anne Roberts, CPMSM, CPCS.