Complaints

Complaints/Inquiries Against Accredited Providers (95-06-A)

The following are procedures for handling complaints/inquiries received by the Ohio State Medical Association Continuing Medical Education office which indicate that an accredited provider may not be in compliance with the Essential Areas, Elements and Policies or may not follow established accreditation policies with regard to one or more of its activities.

1. To receive formal consideration, all complaints shall be submitted in writing and signed. Complaints which are received by phone will be accepted if the complainant provides his or her name; Staff shall produce a memorandum to file.
2. The OSMA Accreditation Screening Subcommittee and CME staff will review the complaint/inquiry to determine whether it relates to the manner in which the provider complies with the Essential Areas, Elements & Policies or follows established accreditation policies.
   1. If the complaint/inquiry is judged not to relate to compliance with the Essential Areas, Elements & Policies or to established accreditation policies, the person initiating the complaint shall be notified by the OSMA CME staff.
   2. If the complaint/inquiry is judged to be related to compliance with the Essential Areas, Elements & Policies or to established accreditation policies, the following shall be observed:
      1. The confidentiality of the complaining/inquiring party shall be protected.
      2. The OSMA CME staff shall provide the complaining/inquiring party with a copy of the OSMA letter of inquiry to the provider.
      3. The OSMA CME staff shall notify the provider by certified mail of the nature of the complaint/inquiry. Notification shall include a request for investigation by the provider and a subsequent report of the findings by the provider. The report will be due 30 days from receipt of the OSMA letter of inquiry.
      4. The OSMA CME staff may request information from the complaining/inquiring party, the provider, or other relevant sources as is warranted by its investigation.
3. Upon receipt of the provider's response, the OSMA CME staff shall determine whether additional information is necessary and may request such information from the provider. Should the staff determine that the information submitted is adequate, the following will be observed:
   1. If the provider is being considered for re-accreditation within six months of the OSMA resurvey process, the complaint/inquiry materials shall be included as part of that process and provided to the Focused Task Force on Accreditation. The provider shall be notified that the complaint/inquiry will be considered as part of the task force's re-accreditation deliberations.
   2. If the provider is not being considered for re-accreditation in the immediate future, the complaint/inquiry will be considered by the Focused Task Force on Accreditation through the following procedures:
      1. The complaint/inquiry materials shall be sent to two (2) members of the Focused Task Force on Accreditation. Those members will review the materials and communicate their recommendations separately and in writing to the OSMA CME staff.
         1. If the recommendations are compatible, the results will be communicated to the chair of the Focused Task Force on Accreditation for concurrence and then presented to the entire Focused Task Force on Accreditation for ratification.
         2. If the recommendations are in disagreement, a conference will be held among the reviewers, the Focused Task Force on Accreditation chairperson, and the OSMA CME staff. If consensus is achieved, the recommendation will be presented to the task force chair for ratification. If no consensus can be achieved, the full task force shall review the materials.
         3. The members of the review team, the chair of the Focused Task Force on Accreditation, or the full task force may request additional materials from the provider if they determine that the materials they have are insufficient to allow them to render an opinion.
      2. The review team shall make its recommendation to the Focused Task Force on Accreditation based on its determination that the materials received are adequate to make a recommendation. The task force shall make the final determination; the following are the possible results:
         1. Letter of Acceptance.
         2. Letter of Concern.
         3. Letter of Reprimand.
      3. The following are the definitions of the possible actions:
         • Letter of Acceptance
           • From the documentation submitted, the Focused Task Force on Accreditation has determined that there appears to be compliance with the Essential Areas, Elements & Policies regarding the issues presented.
           • The information will be filed and the inquiry letter and the Focused Task Force on Accreditation decision will be made available to the reviewers at the next review.
         • Letter of Concern
           • From the documentation submitted, the Focused Task Force on Accreditation is concerned regarding the extent to which there is compliance with specific Essential Areas, Elements & Policies.
           • The concern(s) will be enumerated in the decision letter to the provider, which, along with the inquiry letter and the provider=s response, will be placed in the provider's file and will be made available to the reviewers at the next review.
           • The provider will be asked to address the concern(s) either (1) in a Progress Report or (2) at the time of the next review.
         • Letter of Reprimand
           • From the documentation submitted, the Focused Task Force on Accreditation has determined that the provider is not in compliance with the Essential Areas, Elements & Policies regarding the issues presented.
           • Areas of non-compliance will be enumerated in the decision letter to the provider, which, along with the inquiry letter and the provider's response, will be placed in the provider's file and will be made available to the reviewer at the next review.
           • The provider will be asked to provide documentation of corrective action at a time determined by the Focused Task Force on Accreditation and will be notified that failure to correct the deficiencies may result in an immediate on-site resurvey which may affect the provider's accreditation status.
4. The OSMA Focused Task Force on Accreditation will intervene by affecting the accreditation status of a provider only when it identifies practices and conditions which indicate that a provider is not in compliance with the Essential Areas, Elements & Policies or with established accreditation policies.