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Review of Article: "The Joint Commission’s Ongoing Professional Practice Evaluation Process: Costly, Ineffective, and Potential

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Review of the Article: "The Joint Commission’s Ongoing Professional Practice Evaluation Process: Costly, Ineffective, and Potentially Harmful to Safety Culture"

This article published in 2024 details some of the significant problems with the OPPE evaluation process.  It is well written and we agree with its findings.  Here is a summary of what the authors found.  From our perspective the FPPE and OPPE process end up abused and used as tools to drive out competent doctors from a practice where there are competitive pressures or to target doctors who don't fit the culture of a particular institution.  Patient safety is the mantra but self interest is how the tool is used against good doctors.

Publication Details

  • Journal: Journal of the American College of Radiology (JACR), Volume 21, Issue 1, Pages 61-69
  • Publication Date: January 2024 (online ahead of print September 2023)
  • Authors: Lane F. Donnelly (lead), Daniel J. Podberesky, Alexander J. Towbin, Ling Loh, Kathryne H. Basta, Terry S. Platchek, Michael T. Vossmeyer, Joan E. Shook
  • Affiliations: Primarily from major pediatric and academic health systems (e.g., UNC Health, Cincinnati Children’s, Stanford Children’s, Texas Children’s)
  • DOI: 10.1016/j.jacr.2023.08.031

Background and Purpose

The Joint Commission (TJC) introduced the Ongoing Professional Practice Evaluation (OPPE) requirement around 2008 as part of accreditation standards. OPPE mandates that hospitals continuously collect and review data on privileged providers' performance to identify trends impacting quality and safety. This is distinct from Focused Professional Practice Evaluation (FPPE), which is triggered for specific concerns. The goal is to ensure competent practitioners and support decisions on privilege renewal, limitation, or revocation.

The authors, drawing from their experiences in large healthcare systems, hypothesized that OPPE:

  • Imposes significant administrative costs
  • Rarely identifies true "outlier" performers leading to privilege actions
  • Harms safety culture, especially in radiology, by conflating learning-oriented peer review with punitive oversight

The study's objective was to quantify labor costs and effectiveness across multiple systems, extrapolate nationally, and review impacts on radiology safety culture.

Methods

  • Data Collection: Leaders from six large U.S. healthcare systems (covering various specialties, including radiology) provided:
    • Estimated annual labor hours for OPPE administration (data collection, analysis, reporting, review)
    • Number of providers evaluated via OPPE
    • Number of providers identified as outliers solely through OPPE metrics, resulting in privilege non-renewal, limitation, or revocation in the 2022 cycle
  • Cost Estimation: Labor costs calculated using average hourly rates (including benefits); extrapolated nationally based on estimated U.S. privileged providers (~1.56 million, derived from sources like physician workforce data).
  • Radiology-Specific Review: Literature search on the effects of using score-based peer review error rates as OPPE metrics over the past ~15 years.
  • This was not a formal systematic review but a multi-institutional retrospective analysis.

Key Findings

  • Sample Size: 12,854 providers across the six systems.
  • Effectiveness: Zero providers were identified as outliers solely via OPPE that led to privilege actions. (Any performance issues were detected through other mechanisms, like complaints or incident reports.)
  • Costs:
    • Average annual recurring labor cost per provider: $50.20
    • National extrapolation: $78.54 million per year
    • Cumulative since OPPE introduction (~15 years): Over $1 billion
  • Safety Culture in Radiology:
    • Using discrepancy/error rates from peer review (e.g., RADPEER system) as OPPE metrics has been widely perceived as punitive.
    • This mixing of improvement-focused data (for learning) with policing (for outliers) discourages open error reporting, reduces participation in peer learning, and undermines a "just culture" that prioritizes system improvements over individual blame.
    • Cited literature supports a shift toward "peer learning" models (non-punitive feedback) over traditional score-based peer review.

Conclusions and Recommendations The authors argue that OPPE, as currently implemented, represents administrative waste: high cost, zero yield in detecting actionable outliers, resource diversion from meaningful quality improvement, and potential harm to safety culture (particularly in radiology). They call for:

  • Further research on OPPE's true impact
  • Collaboration between TJC, hospitals, and professional societies (e.g., ACR) to refine or replace OPPE with more efficient, improvement-aligned mechanisms
  • Separation of data for learning vs. accountability

Strengths

  • Large, multi-institutional sample provides robust real-world data.
  • First study to empirically quantify OPPE costs and (lack of) effectiveness at scale.
  • Highlights an important tension in healthcare regulation: compliance vs. genuine improvement.
  • Radiology focus is timely, aligning with ACR's push toward peer learning.

Limitations

  • Relies on self-reported estimates from system leaders (potential variability in accuracy).
  • Extrapolation assumes uniform costs nationally (may vary by system size/specialty).
  • Radiology safety culture assessment based on literature and author experience, not new primary data.
  • Does not evaluate potential indirect benefits (e.g., general deterrence or subtle improvements).
  • Focused on large systems; results may differ in smaller hospitals.

Broader Context and Reception

  • The article sparked discussion: A letter/response in JACR (March 2024) from a TJC representative defended OPPE as essential for early detection, emphasizing flexibility in metrics.
  • Media coverage (e.g., Radiology Business) highlighted the critique, noting TJC's lack of immediate response.
  • Aligns with ongoing debates on regulatory burden in healthcare, where mandates like OPPE aim for safety but may create unfunded administrative loads.

The medical lawyers at the Horowitz physician practice can protect you if the OPPE or FPPE process is being used to marginalize or harm you.  Call us for an initial consultation at (925) 283-1863