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Peer Review. It has been a topic of conversation for years. In the Health Resources & Services Administration (HRSA) world, peer review is talked about by Federally Qualified Health Centers (FQHCs), FQHC Look-A-Likes (LAL) and Primary Care Associations (PCAs). Peer review is talked about at state and federal conferences, during training sessions and webinars, and during HRSA Operational Site Visits (OSVs). Unfortunately, the reason peer review is talked about so frequently is because there are so many unresolved questions. What does HRSA require? How many charts must be reviewed? How frequently must charts be reviewed? And even, why are we doing this?
The standards for peer review are outlined in Chapter Five, Clinical Staffing, and Chapter Ten, Quality Improvement/Assurance of the HRSA Compliance Manual (Chapter Five, Chapter Ten). Chapter Five discusses the need to consider the results of peer review/performance improvement activities in the reappointment process for credentialing and privileging, while Chapter Ten discusses the need for the completion of quarterly QI assessments. What the Compliance does not do is provide specifics, such as:
Health centers are expected to have a process in place for conducting peer review on a “routine and regular basis,” although there is minimal guidance from HRSA on how to do this. Health centers should utilize the responses to the “Five W’s” below as guidelines to not only ensure compliance with HRSA expectations, but as a means of emulating the best practices demonstrated by high performing health centers:
The best process for implementing peer review is often organization specific. There is no “one-process fits all.” Some health centers complete peer reviews during quarterly provider meetings to ensure timely completion, while others have providers complete reviews during administrative time. Regardless of what process is used, the threshold for performance should be clearly defined and understood by the provider. Additionally, results must be shared with providers. The health center cannot expect a provider to improve if they are not aware there is a problem.