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Proposal to Clarify Data Submission Reporting and Documentation Requirements (Resolution 22) Membership & Professional Standards Committee (MPSC) Jonathan Chen, MD, Chair November 12-13, 2014

Proposal to Clarify Data Submission Reporting and Documentation Requirements (Resolution 22) Membership & Professional Standards Committee (MPSC) Jonathan

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Page 1: Proposal to Clarify Data Submission Reporting and Documentation Requirements (Resolution 22) Membership & Professional Standards Committee (MPSC) Jonathan

Proposal to Clarify Data Submission Reporting and

Documentation Requirements (Resolution 22)

Membership & Professional Standards Committee (MPSC)

Jonathan Chen, MD, ChairNovember 12-13, 2014

Page 2: Proposal to Clarify Data Submission Reporting and Documentation Requirements (Resolution 22) Membership & Professional Standards Committee (MPSC) Jonathan

The current policy does not specify what has always been impliedData submitted through OPTN forms must be accurate

Members must provide documentation to verify data accuracy

Other policies explicitly state members must maintain or provide certain documentation

The Problem

Page 3: Proposal to Clarify Data Submission Reporting and Documentation Requirements (Resolution 22) Membership & Professional Standards Committee (MPSC) Jonathan

#6 – Promote the efficient management of the OPTN

• Clearly communicate with members

Strategic Plan

Page 4: Proposal to Clarify Data Submission Reporting and Documentation Requirements (Resolution 22) Membership & Professional Standards Committee (MPSC) Jonathan

Improve readability of OPTN rules and requirements

Clarify policy to alleviate confusion

Reduce resources required to obtain documentation and review potential noncompliance issues

Only applies to standardized forms required by Policy 18

Goal of the Proposal

Page 5: Proposal to Clarify Data Submission Reporting and Documentation Requirements (Resolution 22) Membership & Professional Standards Committee (MPSC) Jonathan

Clarifies member obligations to provide documentation, when requested, to verify data accuracy

How will the Proposal Achieve its Goal

Page 6: Proposal to Clarify Data Submission Reporting and Documentation Requirements (Resolution 22) Membership & Professional Standards Committee (MPSC) Jonathan

Product Bylaw Addition

Target Population Impact:

Transplant Hospitals, OPOs, & Histocompatibility Laboratories

Total IT Implementation Hours

0/10,680

Total Overall Implementation Hours

80/17,885

Overall Project Impact

0 1000 2000 3000 4000 5000

Series1

0 1000 2000 3000 4000 5000 6000

Se-ries1

Page 7: Proposal to Clarify Data Submission Reporting and Documentation Requirements (Resolution 22) Membership & Professional Standards Committee (MPSC) Jonathan

Should not have to change policies or procedures

Will not be required to provide additional documentation during routine site surveysUNOS will not change how it monitors compliance

May be asked to gather and provide relevant documentation upon request for MPSC review

What Members will Need to Do

Page 8: Proposal to Clarify Data Submission Reporting and Documentation Requirements (Resolution 22) Membership & Professional Standards Committee (MPSC) Jonathan

Non-discussion agenda at regional meetings

Generally supported in Committee and individual comments

Primary source documentation

Maintain documentation for regular audits

Public Comment

Page 9: Proposal to Clarify Data Submission Reporting and Documentation Requirements (Resolution 22) Membership & Professional Standards Committee (MPSC) Jonathan

Add “upon request” to address concerns that members must maintain all documentation in central location for routine audits

Post-Public Comment Changes

Page 10: Proposal to Clarify Data Submission Reporting and Documentation Requirements (Resolution 22) Membership & Professional Standards Committee (MPSC) Jonathan

RESOLVED, that Policy 18.1 (Data Submission Requirements) is modified as set in Resolution 22, effective February 1, 2015

Resolution 22 (page 85)