Practice Tips

Physician office practice staff is viewed by patients as an extension of the physician.

A number of medical malpractice cases have found the physician responsible for the negligent performance of both clinical and non-clinical staff members performing their regular duties when a patient injury or violation of patient privacy has occurred. Practice staff performance is a direct extension of the physician's medical practice when delegated directly by the physician, through a protocol or a job description.

Assuring staff competence in all areas of their job performance is an essential element of the physician office practice's risk management program.

Competency

Competence is the ability to do something successfully, safely, and efficiently. It is demonstrated by the ability to fulfill the responsibilities for the position the person was hired for. Skills and ability to perform variable aspects of their jobs should be assessed, validated, and documented.

Steps to Evaluate Staff Competence

The physician office practice should establish a process by which staff competence may be evaluated through ongoing and interactive verification of knowledge and skills. This can be accomplished during:

• The hiring process
• The orientation process
• Initial and annual competence assessment
• Annual performance appraisal
• Continuing education/on-site training
• Ongoing documentation/record maintenance

Hiring

The hiring process should include verification of the individual's training, education and experience, licensure and/or certifications if applicable, in addition to current pertinent reference interviews. A criminal background check and previous professional liability claim review may also be appropriate depending on the position to be filled. The practice should also obtain information from The Office of the Inspector General (OIG) List of Excluded Individuals/Entities for information on previous sanctions by Medicare and Medicaid.

Orientation

All new office staff members, including those providing care, treatment, or service under contractual arrangements, should complete a general physician office orientation program and receive an orientation specific to their job description. The length of the orientation should be determined by the practice based on the complexity of the position to be filled and the new office staff member's previous training, education, and experience. The staff member's performance and completion of the orientation process should be documented.

Initial and Annual Competence

Specific staff competencies should be assessed periodically in areas of high risk, high volume; high risk, low volume, and high visibility. Staff competencies should also be assessed whenever there is a change in job responsibilities, new equipment is put into operation, or unanticipated outcomes are trended that may relate to staff performance. The staff member's successful performance of selected competencies should be documented. Keep in mind the person validating the competency must be qualified to do so. Once completed, the competency assessment documentation becomes part of the employee's Human Resources file.

Performance Appraisal

An annual performance appraisal should be completed based on the staff member's job description and any other required criteria established for office staff members that may be outlined in another office policy.

Continuing Education

Participation in continuing education programs is another demonstration of a current or developing competence. Continuing education programs may be general knowledge, e.g., infection control or they may be specific to operating a new piece of equipment, e.g., a new tabletop sterilizer. All staff participation in continuing education should be documented.

Documentation

Documentation is the most important element in being able to establish, monitor, validate, and improve staff competence. Generally, documentation of staff competence is maintained in a section of the staff member's Human Resources file.

Resources

ECRI, Risk Analysis: Managing Risks in Physician Practices, www.ecri.org.

A Practical Guide to the Joint Commission Standards: Competency Assessment Third Edition

Hospital Accreditation Blog, CIHQ, Richard Curtis RN, MS, HACP, http://cihq-blog.org

Toolkit: Licensed Nurses, Medical Assistants and Delegation: Safe and Effective Teamwork https://www.oplc.nh.gov/sites/g/files/ehbemt441/files/inline-documents/sonh/ma-delegation.pdf