Reimbursement Page

The Return of TPE

What to expect from the reinstated Target, Probe, and Educate program

TARGET

TPE

PROGRAM

PROBE EDUCATION

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CMS ANNOUNCED A MAJOR shift in audit strategy in August 2017: the Target, Probe, and Educate (TPE) program. TPE replaced traditional Medicare audit procedures that relied on expansive postpayment reviews, which subjected entire product categories across all providers to significant audit activity. The TPE program was very well received as it significantly reduced the overall number of Medicare audits, shifted much of the Medicare audit activity to prepayment audits, and provided increased education and communication between the provider community and the durable medical equipment Medicare administrative contractors (DME MACs).

When the COVID-19 pandemic created unprecedented and unexpected shifts in the operation of the Medicare program, CMS initially suspended most audit processes. CMS announced in August 2020 that while Medicare contractors would once again be authorized to perform claim audits, all audits would be performed on a postpayment basis using the previous process of probe review followed by widespread postpayment review. The TPE program was temporarily suspended, and more comprehensive audit processes were put back in place.

Today, the COVID-19 public health emergency (PHE) remains in place, but Medicare contractors are slowly returning to some sense of normalcy in how they process Medicare claims. CMS has authorized the contractors to reinstate many of the processes that were temporarily suspended due to the PHE. In August 2021, CMS announced that the TPE program would be reinitiated and would, once again, replace the widespread postpayment review process.

How Is TPE Different From Widespread Review?

The primary difference between the traditional probe review followed by widespread review model and the TPE program is that the TPE program is much more focused—not only in identifying a much smaller pool of claims for review, but also in providing education for providers who do not pass the audit process to improve their compliance with Medicare policy requirements and regulations.

The TPE program consists of three rounds of prepayment review. Each round involves 20-40 claims that have been identified for review through detailed statistical analysis, which identifies specific areas of risk for the DME MAC contract area. Additional documentation requests are sent for each of these claims, and a standard prepayment review is performed.

If the results of the first round of

prepayment review are deemed acceptable or compliant, the provider receives a notice from the DME MAC that they will be removed from the audit pool for a period of one year. If the results of the prepayment review are not acceptable, the provider is scheduled for a personalized education session with the DME MAC claims review department, where common errors and strategies to improve compliance are discussed. After the personalized education process is complete, a second round of prepayment review takes place, again consisting of 20-40 claims. If, after a second round of targeted review and education is complete, the prepayment review results are still not acceptable, a third round may take place. During each round of prepayment review, providers have the opportunity to be removed from the audit pool if the results are considered acceptable.

The goal of the TPE program, as stated by CMS, is not to identify claim errors and punish providers, but rather to assist providers in achieving better compliance when submitting claims to Medicare. While it is too early to measure the impact that the shift in Medicare audit philosophy will have on the overall number of claims subject to prepayment review, it appears that the TPE program will result in a smaller number of overall prepayment reviews but a higher level of scrutiny for claims selected for review through the TPE program.

What Doesn’t the TPE Program Do?

The TPE program is popular with Medicare providers, but it only replaces DME MAC-based audits. The TPE program does not impact other contractor-based audits, such as those performed by comprehensive error rate testing (CERT) contractors, recovery audit contractors, and zone program integrity contractors (ZPICs). These contractors will continue to perform the audits that they always have using their current processes.

In fact, providers who do not reach an acceptable level of compliance after three rounds of claim review and education may be referred to other audit contractors, such as the ZPIC, for additional review and/or investigation.

How Will TPE Be Reintroduced?

The CMS announcement on the resumption of TPE audits indicated that the program would be reintroduced gradually so as to not overwhelm providers, and to allow them to continue to focus on providing quality care to Medicare beneficiaries during the COVID-19 PHE.

Instead of starting with the typical 20-40 claim sample, the first rounds of TPE audits will involve 10 claim samples.

What Does the Reintroduction of TPE Mean for O&P?

The TPE program provided welcomed relief to O&P providers. In general, TPE resulted in a significant reduction in the overall number of claims that were subject to prepayment review.

AOPA members have reported that, when selected for TPE audits in the past, the opportunity to receive claimlevel education was useful and the opportunity to be temporarily exempt from future audits was a valuable incentive to ensure full compliance with Medicare policy requirements.

The reintroduction of the TPE program does not mean that compliance efforts should be reduced or ignored. The DME MACs and the Pricing, Data Analysis, and Coding contractor are constantly performing data analysis that identifies trends in utilization as well as claim error rates. CERT contractors will remain active during the TPE program and will identify areas of risk where the DME MACs should focus their targeted audit activity. If anything, proper compliance is more important now than it ever has been. The ultimate goal is to avoid TPE reviews entirely through proper claim submission and compliant documentation practices.

AOPA will continue to monitor the progress of the TPE program and will communicate feedback regarding potential improvements that will make the program more efficient for both the Medicare program and the provider community.

Joseph McTernan is director of reimbursement services at AOPA. Reach him at jmcternan@AOPAnet.org.

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NEED TO KNOW

• Recent technological innovations are changing patients’ lives for the better, and some also have the potential to transform the way O&P professionals make clinical decisions and conduct business. • One example is a prosthetic foot emulator that mimics the mechanical characteristics of commercially available passive prosthetic ankles and serves as a tool to systematically explore different clinically available prosthetic foot designs. • A team is conducting outcomes research on the emulator and “test-driving” strategies for prosthetic foot prescription with the goal of improving the process for all stakeholders. Trialing feet while assessing outcome measures can produce data to potentially justify prosthetic foot selection during prescription and reimbursement. • Another research team is testing a microcontrolled prosthetic socket system that automatically adjusts to maintain consistent prosthetic fit and limb volume during ambulation, allowing for transtibial prosthesis users to wear their device pain-free while functioning at a high level. • Preliminary research data is promising. The system has the potential to be applied to other areas of prosthetics and to reduce the historically significant amount of time prosthetists spend optimizing socket fit for patients. IN RECENT YEARS, the rate at which technological innovations have advanced O&P devices is unprecedented. For many, the benefits to patients are obvious and profound. Meanwhile, some other creations are quietly evolving with the potential to also transform the way O&P professionals make clinical decisions and conduct business.

Take, for example, the prosthetic foot emulator developed by Josh Caputo, PhD, president and CEO of Humotech. Inspired by Caputo’s doctorial work at Carnegie Mellon University several years ago, the prosthetic foot emulator is a wearable robotic system that is physically similar to a powered prosthetic ankle; however, its motors, computers, and power components are separate from the wearable portion and connected by a flexible tether. “This enables the device to be extremely lightweight, high performance, and versatile,” Caputo explains. The nature of the tethered components means the user currently cannot take the system outside of the laboratory, so it is typically used with a treadmill or stairmill. “In some new projects, we’re exploring the use of treadmills with uneven surfaces, and even a portable version of the off-board actuation, control, and power components.”

The prosthetic foot emulator in use at the DoD Center for the Intrepid study site

By mimicking the mechanical characteristics of commercially available passive prosthetic ankles, the emulator primarily serves as a tool to systematically explore different clinically available prosthetic foot designs, explains Caputo. Through the software interface, operators can select different foot brands and models, stiffness categories, and lengths to trial with prosthetic foot users. “The robotic actuator is controlled accordingly to emulate the stiffness characteristics of the programmed foot,” he says. “In this manner, people with below-knee amputations can test-drive candidate feet without having to acquire physical samples of each specific foot they are interested in. This rapidly accelerates the process of trialing feet, which we believe will help patients and clinicians work together to find the best prosthetic foot solution.”

In advance of commercialization, a multisite research team led by physiatrist David C. Morgenroth, MD, at the Department of Veterans Affairs (VA) Puget Sound Health Care System’s Seattle campus Center for Limb Loss and Mobility (CLiMB), is studying the predictive abilities of the system. The current process for prosthetic foot prescription is more of a trial-anderror approach, based on a clinician’s knowledge of the patient and his or her knowledge of and experience with certain prostheses, says Morgenroth. “A confluence of factors can limit the success of this process,” he explains: “There is limited existing evidence to effectively guide the process in a patient-specific manner; prosthetic manufacturers do not typically publish objective mechanical property data so clinicians are left to make assumptions about mechanical properties through a combination of their clinical experience and advertising claims; there are hundreds of feet to choose from; … and there is typically little to no opportunity for the prosthetic user to provide experiential input [trialing feet] as part of the process.”

Josh Caputo, PhD

Morgenroth’s research team, which includes VA, Department of Defense (DoD), and university collaborators, is conducting large-scale, rigorous, and clinically oriented outcomes research on the emulator. His team has developed a “test-drive” strategy for prosthetic foot prescription research, which involves “studying parallel strategies—one using the prosthetic foot emulator, and the other using commercial prosthetic feet,” he says. The initial project, funded by the Department of Defense Orthotics and Prosthetics Outcomes Research Program (DoD OPORP), is a multisite clinical trial focused on assessing the predictive validity of these test-drive strategies. “In this project, which we call TeD (short for “Test Drive”), study participants are given a chance to walk with different prosthetic feet under a variety of environmental terrains including slopes, stairs, and on flat ground at different speeds,” Morgenroth explains. After laboratory testing of different commercial feet and the emulated versions of those feet, participants wear each of the commercial feet for two weeks at home and in the community, and then return to the laboratory for re-evaluation. The study assesses correlations between preference for both commercial and emulated feet worn in the lab and used under different walking conditions to their foot preference and performance-based measures after the two-week takehome period with each foot. The team recently completed data collection for the TeD study and is currently analyzing the data and preparing to publish results. They also will be presenting on the study at the 2021 ISPO World Congress in November.

More recently, DoD OPORP funded the next step in the “test-drive” strategy research, called TeD Max (Test Drive Multiaxial), which focuses on correlating mechanical properties in both the sagittal and coronal planes with stability and fall-related outcomes in people with transtibial amputation. “We are assessing whether a test-drive strategy for prosthetic foot prescription using commercial feet with a variety of sagittal and coronal plane properties, and emulated versions of these feet—using a multiaxial prosthetic foot emulator—can predict stability and balance-related outcomes,” Morgenroth explains.

By enabling patients to offer experiential feedback during the prescription process, these studies have the potential to provide meaningful benefit to clinicians, as well as to lower-limb prosthesis users. “Both of these projects are examples of the benefits of multidisciplinary and multi-institution efforts,” says Morgenroth, given that the research team includes clinician-scientists, engineers, and biomechanists from VA, military health, and academia.

As these studies conclude, and the emulator moves closer to widespread use, Caputo is planning new additions and uses for this technology. “The sky’s the limit as far as what’s possible with emulation, and we’re just getting started,” he says. “We’ve started by focusing on the most common foot types, and what we think are the most important foot characteristics. As the research evolves, we are refining our approach, developing new capabilities to enable test-driving a broader variety of prosthetic foot characteristics that differentiate clinically available feet, and hopefully validating that with each advancement we are able to generate outcomes data accurately.”

For example, Caputo’s team is adjusting the design of the emulator to better understand the role of multiaxial prosthetic foot features and their impact on balance-related outcomes.

The current version uses a programmable robotic forefoot component to match the sagittalplane mechanical characteristics of passive commercial foot keels, and it uses swappable passive heel springs to match the heels of those feet. The emulator is worn without a shoe, so the characteristics of a walking shoe are incorporated into the design. “There are some size and weight limitations [26- to 29-centimeter feet and 250-pound body weight] that we are working to expand—we really want to try to accommodate the widest possible range of foot types and users.”

Now, Caputo and his team are adding multiaxial characteristics to emulate frontal plane mechanics, by adding a second degree of freedom to the robotic forefoot, and perhaps also to the heel. “We haven’t tackled transverse plane mechanics, although that’s certainly possible, too,” he says. “Emulating microprocessor or powered feet is also certainly possible, but we haven’t been focused on that simply because we’re trying to target the most commonly prescribed feet.”

The ultimate goal of the emulation approach is to “help make [the test-drive] process easier, more efficient, and more effective for all the stakeholders in the prosthetic foot prescription and rehabilitation process,” adds Caputo. “We see this as a system that enables [patients] to demonstrate their capabilities and explore their options rapidly and in a scientifically-sound manner.” Trialing feet while carefully assessing outcome measures can produce “a robust individualized dataset that, in theory, could be used to justify prosthetic foot selection during prescription and reimbursement.

David C. Morgenroth, MD

BALDWIN BELT

(shown on model)

“There’s a strong desire in this field for evidence-based methodologies,” Caputo adds, “and we believe this type of highly individualized experimentation is essential because the needs of individuals and their response to different types of technologies are so varied and unique.”

Game-Changing Sockets

At the University of Washington (UW), another project is poised not only to improve the comfort and satisfaction for people with limb loss but also to change the historically significant amount of time prosthetists spend optimizing socket fit for their patients.

Funded by a four-year, roughly $6 million contract awarded by the DoD’s Defense Health Program (DHP) Joint Warfighter Medical Research Program (JWMRP), UW researchers are testing a microcontrolled prosthetic socket system that automatically adjusts to maintain consistent prosthetic fit throughout the day. While research and development of manually adjustable sockets have grown over the past 10 years, this system is designed to automatically adjust during ambulation, allowing for transtibial prosthesis users to wear their device pain-free while functioning at a high level—and without the inconvenience of pausing their activity to reactively adjust their socket due to discomfort.

“The impetus for the project is that prosthesis users’ socket fit can change during the day and affect the comfort and quality of life of people with limb amputation,” explains Joan Sanders, PhD, professor of bioengineering and the project’s principal investigator. “Most often, these changes in fit are due to a change in limb volume.”

To begin the project, the team needed a socket that would allow them to control and monitor fluid volume and record data. They expanded upon a previously developed cabled-panel, adjustable socket system with a motor mounted beneath the socket and connected to the cable using tubes in the wall of the socket. The new system adjusts each panel individually and is more lightweight. Users manually adjust the fit using a mobile phone app and Bluetooth technology to send commands to a microcontroller. Then, “the motor moves in

Joan Sanders, PhD

UW’s auto-adjusting socket system

discrete steps (in either direction), which causes the three socket panels (anterior lateral, anterior medial, posterior midline) to displace radially,” according to the UW Prosthetic and Orthotic Science & Technology Laboratory website. Through careful observation of the panel motion, the researchers determined socket volume changes caused by the radial movement of the panels.

The new, automatically adjusting system uses a series of custom sensors developed in the UW lab that are placed within the socket at the posterior medial, posterior lateral, and anterior locations. They measure the distance to the user’s liner. “The liner has a thin layer of magnetic powder, deep in the elastomer next to the fabric backing, that serves as a target for the sensors,” Sanders explains. The microcontroller in the socket continuously samples the sensors, and when the sensed distance changes, the socket expands or contracts automatically to accommodate the increase or decrease in limb volume. While sitting, “the user can release the panels, which may increase limb volume, and that volume may be retained during subsequent walking, helping to stabilize limb volume,” she notes.

To develop the automatic system, the team conducted a number of studies. In one study, they fit 12 participants with the adjustable socket and monitored the effects of socket size change on limb fluid volume. On average, users accepted a socket size range of 2.2 percent larger than their normal socket volume to 3 percent smaller than their normal socket volume. The average optimum size was 0.7 percent smaller in volume than their normal socket.

Most recently, the researchers were in the process of quantifying socket fit data collected from clinical testing in participants’ at-home environments; however, the pandemic slowed their efforts. “Hopefully, with COVID restrictions decreasing, we will be able to test a lot more people soon,” Sanders says.

During the at-home tests, participants wear each of three socket configurations for about one week: auto-adjusting, using the microcontroller; manual-adjusting, using a mobile phone app to control socket size; and “locked” (no adjustment). “We compare socket fit measured over the course of the day for the three configurations,” says Sanders. “We also look at activities and bodily positions, and we compare socket comfort scores collected from the participant each day of testing.”

Preliminary results are promising. “The auto-adjusting socket is performing consistent with expectation,” according to Sanders. “Some users are thrilled to let the auto-adjusting socket do all the work, and they are very positive on using it. Others want to participate more, and they use the phone app to make adjustments when they want.”

In addition, Sanders says that some participants are eager for a commercial version of the autoadjusting system to become available. “We were contracted to make a system to work on any type of adjustable socket,” Sanders adds. “Our innovations are primarily the sensors and the control system algorithms. Hopefully, those will be applied to many types of adjustable sockets in the future.

“We are also enthusiastic about the effectiveness of the socket fit sensor that we developed,” Sanders continues, “because we see opportunity to apply it to other areas of prosthetics and orthotics.”

The congressionally directed JWMRP contract that provided the funding for the project came as an honor to the team. “As they hoped, we accomplished a huge amount in a short time,” Sanders concludes. “We are hopeful that our efforts will launch forward auto-adjusting socket technology in prosthetics.”

Josephine Rossi is editor of O&P Almanac. Reach her at jrossi@ contentcommunicators.com.

By CHRISTINE UMBRELL EDUCATION

Review

HAMONTREE AWARD WINNER REBECCA SNELL SHARES A STEP-BY-STEP AUDIT PROCESS FOR REVIEWING ADVERSE BUSINESS OUTCOMES—AND PREVENTING RECURRENCES

Rebecca Snell, 2021 Hamontree Award Winner, left, with AOPA President Traci Dralle, CFm

IN MEDICINE, HOSPITALS study adverse patient outcomes at morbidity and mortality conferences— traditional, recurring conferences involving the analysis of adverse outcomes in patient care through peer review. But what if we applied this model to adverse business outcomes at O&P facilities? That’s the question Rebecca Snell, director of IT and marketing at Dankmeyer Inc., posed in September at the 2021 AOPA National Assembly, during her award-winning Hamontree presentation on “Adverse Outcomes Audits: Using Simplified Six Sigma as a Loss Control Measure.”

A variety of events can be classified as an adverse business outcome, according to Snell—for example, losing a patient to a competitor, having to refund money to a payor or patient, remaking a device at your own cost, responding to a complaint to Medicare, missing an audit deadline, or even experiencing a data breach (see “Managing Cyberthreats” in the August O&P Almanac). Each undesired outcome is the result of something gone wrong in a company’s process—the series of actions taken to reach a desired outcome, according to Snell. Identifying exactly what happened during the process that caused the adverse outcome can help O&P facilities pinpoint problem areas and prevent recurrences.

Snell looked to the principles of Six Sigma—a method that provides tools to improve the capability of organizations’ business processes— and adopted a simplified Six Sigma approach to systematically review adverse outcomes. This modified approach works well for companies

Snell presented her Hamontree lecture in person during the AOPA National Assembly in September.

that have limited resources, such as many O&P facilities, because participants can “forget measuring, forget testing, forget the graphs and charts, and make it accessible,” Snell explains. “There might be a point later for you to do [a more scientific review]—but don’t let that stop you from the problem analysis.”

Defining the Process

Snell instituted the simplified method, which she calls AOR, or “Adverse Outcomes Reporting,” at Dankmeyer, with positive results. Each quarter, Dankmeyer chooses an adverse outcome event that occurred within the past year and schedules a two-hour meeting to review the case, identify what went wrong, and make changes to prevent repeat scenarios. This process involves six distinct steps, which any O&P facility could follow to reduce losses and improve satisfaction among both internal and external O&P stakeholders:

STEP 1 Make a Pre-Audit Checklist. Before each AOR meeting, Snell follows a checklist with specific tasks to prepare for the conference.

She starts by working with the leadership team to identify one negative outcome to audit. “It could be a patient service, a front-office issue, a billing error, or something else.” The audit process works well with any type of problem, according to Snell.

Next, she works with leadership to determine the audit “team.” Snell recommends finding a process “champion” to oversee the program. Then, for each quarterly meeting, identify a moderator or facilitator to serve as an impartial group leader to guide discussion and keep people on track. You also will need a scribe/ recorder to document key activities, and subject matter experts who were involved in the case you’re considering or who understand the process you’re auditing.

Then, Snell schedules the meeting, which should last approximately two hours. To develop her agenda, she adapted the Six Sigma 4W/2H/1C tool that involves discussing the “who, what, when, where, and why” of the outcome, as well as “how often and how much” it occurred, and the consequences.

Finally, she invites the team to the meeting, and asks that each participant come prepared—and ready to adhere to the agenda.

AOR Process in Action

WHEN Dankmeyer Director of IT and Marketing Rebecca Snell introduced the “Adverse Outcomes Reporting” (AOR) process at her facility, the company decided to review a recent case with a negative outcome: A complicated orthosis for a pediatric patient had to be remade at the company’s cost. Here’s how the process worked, and what the team members learned.

Who and what? The family—a return customer that had been previously extremely satisfied with the company—took delivery of the device, but when adjustments could not be completed before a move out of state, they returned the device; the payor was refunded; and the patient’s needs were not met.

When and where? During the audit, the Dankmeyer AOR team identified dates of contact with the patient’s family in chronological order and established which staff member was involved at each step. They looked at documentation from eight appointments over a three-month period and reviewed phone calls and emails between the patient’s family and employees.

Why? Although it appeared as if all employees were following correct processes, the AOR team found that the patient didn’t keep the last appointment to get delivery of the adjusted orthosis. The team examined several “why” questions. First, “Why didn’t we know earlier in the service that the patient’s family was moving and required a short turnaround time?” asks Snell. “We asked more questions and learned via the process timeline that there were several communications with the patient’s family via phone and email that were not recorded in the patient record.”

The team looked deeper, and asked more questions: “Why did we lose track of this as an active service until we got the request for a refund?” Snell asks. She notes the staff thought the service was closed after the delivery receipt was signed, and they did not reactivate the service once the additional adjustments were needed—which was not following their own process. Finally, “why did we have to refund the payor?” Snell asks. Ultimately, when the patient’s family wanted to restart the service at a new facility after their move, Dankmeyer refunded the payor as an “act of goodwill,” says Snell.

How often and how much? Looking closely at the communication breakdowns, the AOR team realized that communication outside of the patient record via phone and email happens quite often—but can lead to missed opportunities because the whole team doesn’t have access to potentially crucial information. In addition, “how often do we neglect to set appropriate expectations with patients for a service [at the time] they are experienced?” Snell asks. “When we look at outcomes, do we think about the cost of extra labor, parts, and shipping when we don’t get it right the first time?”

Consequences? When reviewing the actions that led to the adverse outcome, the Dankmeyer team realized the client expected delivery of a working device, with some adjustments required, within a very tight timeline, during the COVID-19 pandemic. With a normal timeline and setting of expectations, this would have been possible. However, in this instance, “if we had known at the beginning of the shortened timeline, we never would have started” making the device, Snell says. “While other things contributed to the loss, this was the key element to the failure in this specific case.”

Finally, the team discussed a plan to prevent future failures. “Our operations group looked at employee training and education to make sure all patient communications are recorded,” Snell explains. Plus, “we decided to investigate a warranty policy with each of our fabricators to see that we completely understand what is our cost and what is not.” Finally, Dankmeyer renewed its dedication to setting appropriate expectations with the patient every time, because time and circumstances change.

The Dankmeyer team did an outstanding job with the AOR process on their first try, conducting careful, thoughtful analysis, then coming up with an executable action plan, according to Snell. “And they were ready to use the method again, for a new case.”

STEP 2 Start the Meeting By Asking Questions. During the AOR meeting, it is the facilitator’s job to ensure participants are objectively focused on the process, without finger pointing. “The facilitator should remain neutral to guide the process,” Snell explains. “Be ready to shine an open and transparent light on some things that may be uncomfortable.”

The facilitator should ensure that each team member is prepared to answer questions in their area of expertise. “We try to analyze the information to reach any conclusion as to what part or parts of the process are broken,” Snell explains.

She recommends going through the agenda carefully, which—at Dankmeyer—focuses on five “Ws,” two “Hs,” and consequences. Each team member should share their experience in relation to the following agenda items: • Who? Who was involved, both on staff and external parties, such as patients, payors, or referral sources.

Also ask “who else” should have been involved, if applicable. • What? What happened, and what should have happened? • When? Go through the chronology of the adverse outcome, and look at what occurred at each distinct point in time. • Where? Where did each action related to the adverse outcome take place? • Why? Why did the adverse outcome occur? Why wasn’t a positive outcome possible, given the circumstances? • How often and how much? How often did the adverse outcome occur, and how much of an impact did it make? • Consequences? Dive into the consequences of the outcome—how it affected the facility, employees, patients, payors, and/or referral sources, and the bottom line.

When discussing these questions, “You don’t come in with assumptions. Anything is fair game,” says Snell. Going around the room and asking each question allows the team to analyze the information. Discussing these points empowers team members to identify specific points where breakdowns in the process occurred. Then, the team can discuss how to ensure those breakdowns won’t happen again.

STEP 3 Conclude the Meeting With Specific Action Items. At the end of the meeting, the goal is to propose a corrective plan of action, says Snell. Your team should apply creative thinking to discuss how big of a problem the adverse outcome is, what can be done to correct it, and what steps should be taken to solve it.

“By fixing those defects, we’re going to increase the bottom line somewhere, or we’re going to please a customer— whether that customer is internal, a patient, or a clinical partner. Somebody needs to come out better for this.”

If possible, Snell suggests delineating a plan to fix a single point of the process that will produce the biggest impact on reducing or eliminating the error. “Sometimes you can decide to change one thing,” then turn that task over to the staff members responsible for that area of operation to initiate the change.

However, if the problem is too big or unwieldy, “you may have to spin off a workgroup” and expend more resources to develop an action plan.

STEP 4 Task a Staff Member With Follow-Up. Even if your audit meeting goes well, your business will not reap any benefits if no one follows up. “Someone needs to be the champion who guides and keeps track of the plan of action, to ensure the action items are carried out, after the meeting,” says Snell.

That employee should check in with the individuals responsible for making the change to ensure they are on track—and make adjustments if necessary.

STEP 5 Plan the Next AOR Meeting. As Snell notes, Dankmeyer reviews one case per quarter—but that frequency can vary, based on what works best for each facility. “Be consistent,” and schedule the next meeting after one has concluded, says Snell.

Snell suggests that one month before your next audit meeting is the best time to select a new case to review, prepare the agenda, and send a reminder. And you may need to change the team—to include different stakeholders—depending on the specific case and outcome.

STEP 6 Review Your Accomplishments at a Year-End Meeting. After you have a system in place to review adverse outcomes at regularly scheduled meetings, plan a year-end wrap-up meeting to go over each adverse outcome that was studied that year.

“Talk to the people responsible for implementing the changes” on a case-by-case basis, Snell says. “What was taken care of, and what has

Don’t Wait! View the 2021 Hamontree Presentations Online Before It’s Too Late

The Sam E. Hamontree, CP(E), Business Education Award was created to recognize the best business education paper, idea, or proposal submitted for presentation. This award is a counterpart to the Thranhardt Award given each happened since? How well did our intervention work? Was the intervention successful? If not, should it be revisited? Our goal is to look at all our cases, look at our action items, and see how things played out.”

year to the best clinical abstracts. Presentations by the 2021 Hamontree Award contenders took place September 10, during the AOPA National Assembly in Boston.

Registered Assembly participants can view all three of the 2021 Hamontree presentations on the conference’s virtual platform: • “Adverse Outcomes Audits: Using

Simplified Six Sigma as a Loss Control

Measure,” Rebecca Snell, 2021

Hamontree Award winner • “Technology Readiness for Orthotists and Prosthetists,” Gerald Stark,

MSEM, PhD, CPO, LPO, FAAOP(D) • “Evidence-Based Practice: Make

It a Business Opportunity,” Andreas

Kannenberg, MD(GER), PhD. Rebecca Snell

The presentations—and all other educational sessions and additional content—on will remain available to registered Assembly participants on the virtual platform until December 18. Gerald Stark, MSEM, PhD, CPO, LPO, FAAOP(D)

Andreas Kannenberg, MD(GER), PhD Ensuring Success

Better outcomes and a healthier bottom line are among the benefits of implementing an audit process similar to AOR, according to Snell. She offers advice to facilities interested in launching similar programs.

First, ensure all team members are dedicated to the process. It’s important to have a high degree of confidence that everybody involved is invested and wants to find solutions by using the agreed-upon methodology, according to Snell.

Each facility also should designate an employee to keep a running list of adverse outcomes as they come up and to follow up after meetings. Doing so will make it easier to decide which outcome to focus on when it’s time for the next AOR meeting.

Preparation for each meeting is key—for every participant. This is especially important given everyone’s limited time constraints.

In addition, avoid blaming individual employees. “This is about analyzing the process,” Snell emphasizes. “If one person took a misstep, then there was something within the process the led to that misstep.”

Understand that any facility can do this, and that there is value to it, says Snell. For smaller facilities that may find it more challenging to devote staff time to quarterly meetings, Snell suggests “keeping it simple and accessible,” and involving fewer staff members, if necessary.

Finally, don’t be afraid to try this process. If nothing else, try it at least once, says Snell. “I think there’s a lot of value in the things that you’ll learn.”

Christine Umbrell is a contributing writer and editorial/production associate for O&P Almanac. Reach her at cumbrell@contentcommunicators.com.

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Policy Effective Date:

I. ACCOUNT INFORMATION

1. Business Name: 2. Mailing Address: 3. City: 5. Contact Name and Phone Number: State:

7. Coastal State:Yes No (If yes, distance to body of water): 9. Do you have a website? Yes No (If yes, URL): 10. Email address: Zip: 4. Phone: 6. Fax: 8. Number of locations:

II. DESCRIPTION OF OPERATIONS

1. FEDERAL TAX ID #: 2.Corporation:Yes No Individual: Yes No 3. Provide a brief description of operations including years in business:

4. If new venture, please explain your prior experience, how many years, and what position and field this experience is in:

5. Practitioner for Patient Care Certified by ABC or BOC? Yes No

6. Any business conducted other than Orthotics & Prosthetics? Yes No (If yes, please describe):

7. Current Insurance Carrier: Premium:

8. Prior Insurance Carriers and policy dates: 9. Check off if you are a member of any of the following:

AAOP Pedorthic Footwear Association AOPA Other:

Is the facility accredited? Yes No Years with carrier:

III. CLAIMS HISTORY

1. Have you had any losses in the past 3 years? Yes No (If yes, please describe below):

Description of Loss Date of Loss Amount Paid

IV. PLEASE INDICATE ESTIMATED SALES FOR EACH CATEGORY

Last Term’s Sales

Practitioner Patient Care: Includes all items fabricated for patients. Custom Products. Manufacturing: Items manufactured by you and sold to others to distribute. There is no patient care for this class Wholesale Distribution: Includes all items purchased from others that you resell to other facilities. No direct sales to patients. Retail Sales: Sales/ Revenue includes pre-fab items that you rent/sell to others. Off-the-shelf items that you do not repackage. Includes ‘prefab’ custom fit braces. Medical Equipment Repair: Sales/ Revenue of Medical Equipment that is repaired, installed (no retail sales)

Est. updated sales for current term

1. Download the O&P Program Application at:

bit.ly/cailorflemingOandP

2. Fill out the form. 3. Email the form to dfoley@cailorfleming.com Cailor Fleming Insurance will quickly provide your individual program quote.