Get ready for FPPE

Dear medical staff leader:

Focused professional practice evaluation (FPPE), a requirement introduced by The Joint Commission's 2007 medical staff standards, creates significant challenges for everyone tasked with privileging duties. FPPE requirements raise the bar for medical staffs and medical staff professionals by specifically requiring that these evaluations are "privilege-specific."

To comply with this requirement, which takes effect January 1, 2008, the medical staff must confirm the competence of a practitioner new to the organization by evaluating the care he or she provides to the hospital's patients rather than relying on competency evaluations completed by organizations at which he or she formerly practiced. Keep in mind that as of January 1, 2007, FPPE must also be used when competency questions arise regarding practitioners who are not new to the organization.

In addition to allowing the medical staff to obtain information regarding a practitioner's competence from individuals involved in the care of each patient (e.g., consulting physicians, assistants at surgery, and nursing or administrative personnel), The Joint Commission standards include additional "tools" that medical staff can use to implement FPPE. These tools include some that medical staffs commonly employ as part of the peer review process, such as chart review, monitoring clinical practice patterns, and external peer review. However, the standards also introduce tools that may be new to many medical staff organizations, including simulation and proctoring.

Because designing and implementing a simulation program requires a lot of time and resources, many medical staffs are reacting to the concept of FPPE by instituting proctoring as part of the "provisional period" that traditionally applied to newly appointed and privileged practitioners. (Remember, the 2007 Joint Commission standards make no mention of "provisional" status). These medical staffs are implementing proctoring because

• chart review and monitoring clinical practice patterns are already part of peer review
• most medical staffs understand the idea of proctoring
• some medical staffs currently require proctoring
• proctoring can be described in a policy and procedure and quickly implemented

Keeping in mind that the standards do not mandate proctoring, let's examine the use of proctoring as a tool to carry out FPPEs. There are numerous issues related to proctoring, and it is not my intention to describe all the pros and cons of proctoring in this letter. However, there are some basic questions you should answer when considering proctoring as a tool to assess competency, such as:

• What should be proctored?
• How many proctoring reports will suffice to confirm competency?

As stated earlier, FPPE is privilege-specific. Imagine that a practitioner requests all privileges included on the privileging laundry list-not an unusual situation. You must decide what should be proctored, what should be chart reviewed, what is subject to monitoring clinical practice patterns, and what is subject to discussions with individuals involved in the care of the patient.

The time to determine the answer to these questions is now. Don't wait until the end of this year and then scramble to ensure compliance. Design and implementation of a FPPE process for new applicants will require thoughtful consideration of how to confirm competency in your organization. Compliance will also require consideration of how to deal with practitioners who have privileges in your organization but rarely (or never) exercise those privileges. Pay this new requirement the time and attention necessary to implement a meaningful process that ensures patients at your hospital receive excellent care.

Until next week,
Vicki L. Searcy, CPMSM
Practice Director, Credentialing & Privileging
The Greeley Company
vsearcy@greeley.com
www.greeley.com