Critique of a Hospital’s Disclosure Policy
Below is a disclosure policy for a hospital system somewhere in the United States. Apparently this is corporate policy and local personnel are not supposed to deviate from the plan. This policy was shared with me. Not naming names, because names aren’t important in this instance. The policy words below and my critique that follows should be the focus. Hopefully the healthcare system in question as well as other systems can learn from this critique.
- If an Adverse Event occurs: hospital’s Risk Management team discloses the event (within 72 hrs.) to patient/family and
- Hospitals Risk Management undertakes RCA. Family is told that it will be “fully investigated internally”, but they cannot participate in the investigation, and,
- They cannot see any “internal reports” generated, but if they call back periodically they can be told if investigation is progressing or has concluded, and,
- As a result of the internal investigation, what if any changes will occur (but not told if hospital or caretaker were determined to be causative).
Critique: To me, this policy seems simplified and dated. Bet this policy was created in the aftermath of JCAHO’s 2001 disclosure standard, when we didn’t know much about disclosure.
Consider the following thoughts: 1) There is nothing in the policy about empathy or staying connected post-event. 2) I’d be moving a lot quicker than 72 hours….family could have already retained legal counsel by then. And we “review,” not investigate. 3) Every event is different, and the risk management team will often NOT be the best folks to do disclosure. Always consider the caregivers who have a relationship with the patient/family. 4) Patients and families should always be involved in the investigation – it’s the empathetic thing to do, adds lots of credibility to the process, and you might learn something….something really important!. We have written extensively about interviewing the patient/family this year. 5) Why should the patient/family have to call back to learn about the status of the investigation?? They should never be in the dark. We should be contacting them at least once per week, if not more, and even if we have nothing new to report. We need to keep the relationship alive. And while we may not be able to share an RCA, we certainly need to share some kind of written report that addresses the details. Again, the process must be credible and believable. 6) If we are not going to be admit our faults, have we really disclosed? We’re not going to prematurely admit fault, but if the review shows we made a mistake, we will admit fault, apologize, and compensate.
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