Medical Director

URAC's proposed changes to Core 11, which focuses on the responsibilities of the senior clinical staff member, are worth noting.  The changes are both substantive and in terms of scoring.  The new standard would read:

A senior clinical staff person: (--)
(a) Provides guidance for all clinical aspects of program; (Wt=3)
(b) Is responsible for clinical aspects of program; and (Wt=M)
(c) Has periodic consultation with practitioners in the field. (Wt=3)
(d) Ensures that the organization has qualified clinicians accountable to the organization for decisions affecting consumers. (Wt=M)

Substantive, subsection (d) is new. URAC explains this change this way:  "Added element (d) to address the senior clinical staff person’s role. Senior clinical staff may or may not serve as a clinical decision-maker for the clinical areas covered by the organization’s services; therefore, the new standard element indicates that this individual “Ensures that the organization has qualified clinicians accountable to the organization for decisions affecting consumers."

While the change may seem subtle, the fact that it is a mandatory standard makes it less subtle.  Coupled with the other scoring change, making subsection (b) mandatory, too, shifts significantly more attention to this standard than in the current version.  Under this proposal, there would be two ways to flunk, whereas this standard could not, by itself in its current version, break a URAC applicant's heart.   

This standard addresses the qualifications of the senior clinical staff member.  URAC proposes no substantive changes to the standard, nor does it propose a meaningful change in scoring (beyond the overall scoring system change discussed elsewhere).  The only changes are a subtle attempt to clarify in the interpretive information associated with the standard. 

The new standard would read:

The organization designates at least one senior clinical staff
person who has: (---)
(a) Current, unrestricted clinical license(s) (or if the license is
restricted, the organization has a process to ensure job
functions do not violate the restrictions imposed by the state
licensure board); (Wt = M)
(b) Qualifications to perform clinical oversight of the services
provided; and (Wt = M)
(c) Post-graduate experience in direct patient care; and (Wt = M)
(d) Board certification (if the senior clinical staff person is an M.D.
or D.O.). (Wt = 3)

The interpretive changes are twofold:  First, an addition to the interpretive information makes it clear that it is the senior clinical staff person's responsibility to assure staff access to qualified clinical people.  Second, by creating a definition for the word "oversight" ("Monitoring and evaluation of the integrity of program processes and decisions affecting consumers"),  URAC intends to clarify the duties of this particularly important person.

I invite your comments as to how this will change anybody's approach to the URAC accreditation process.  URAC seldom does anything without a reason (or at least a history), but that doesn't necessarily mean that it will change your life.  Please let me know if it will.

The change in Core 11 from v. 2.0 to v. 2.1 could not be more technical -- changing the first word from "The" to "A".  It now reads:

A senior clinical staff person: (N/A)

   (a) Provides guidance for all clinical aspects of program; (Primary)

   (b) Is responsible for clinical aspects of program; and (Primary)

   (c) Has periodic consultation with practitioners in the field. (Primary)

The only possible significance that I can imagine of this change is that it takes the heat off the senior-most clinical staff member for doing the things required by the standard -- i.e., he/she can have a less senior clinician handle these tasks.  This is suggested in Core 10 (both the old and new versions), so one might argue that this change is unneeded.  I'll not be the one arguing that, though.

Documentation to support this standard is straightforward:  job description, verification of licensure, and CV are the minimum, while a program description describing the senior clinician's roles  and documentation of activities conducted in the field by this clinician are helpful, too.