Looking at OHPIP through the lens of Right-Touch Regulation
CPSO’s Out-of-Hospital Premises Inspection Program (OHPIP) is being re-evaluated with the intent to modernize and align the program with our right-touch regulation approach, and to ensure the public interest is being effectively served.
“Over the last three years, we have looked at programs at CPSO through the lens of Right-Touch Regulation. It was time to look at OHPIP with that same lens and ensure the program remains fit for purpose,” said Laurie Reid, CPSO’s Director of Investigations and Accreditation.
The OHPIP was created more than 10 years ago through a regulatory amendment under the Medicine Act, 1991. The regulatory amendment was prompted by an increase in the number of procedures traditionally provided in hospitals — such as complex surgical interventions — that were moving into community settings, without the same quality and institutional oversight typically found within hospitals.
The amendment gave CPSO the authority to establish a quality and inspection regime focused on premises where procedures are being performed under general anesthesia, parenteral sedation or regional anesthesia, along with a number of more specific categories of procedures performed with local anesthetic.
With an aim to improve the effectiveness of the program as a whole, modernization efforts will include changes at the operations level, committee level, and to the Program Standards that outline the core requirements that must be met when performing specific procedures in Out of Hospital Premises (OHPs).
The Program Standards include details regarding the inspection regime, outline the different levels of premises within the program, and set out specific standards in relation to, for example, staff qualifications, post-procedure care, infection-prevention and control, and physical infrastructure. Additional specific standards are also set out for premises providing interventional pain, endoscopy and induced abortion care.
Work is underway to both redesign and revise the current approach to setting standards for OHPs. The primary intention of the redesign is to improve the clarity, readability and utility of the Program Standards to support improved understanding and uptake. This process will likely also include significant updates to the content of the standards.
And in keeping with right-touch regulation, CPSO wants to move away from prescriptive or detailed standards to more principle-based requirements, where possible, and focus on areas of greatest risk to patients.
Dr. Craig Roxborough (PhD), Director of Policy, says consultation will be the foundation of the modernization effort, with the profession being consulted on the draft standards.
The Premises Inspection Committee (PIC) — the committee supporting the program — has also been engaged and has provided feedback on the current approach to regulating OHPs, as well as its perspective on potential areas for improvement and areas of potential risk that need to be mitigated or addressed.
Feedback from OHP medical directors and physicians practising in OHPs has also been sought. A recent survey found that while there is broad support for the current regime, there were a number of constructive suggestions for improvement.
“In general, the feedback confirmed our internal analysis of the program and supported some of the changes already being undertaken or contemplated,” said Ms. Reid.
These activities have informed the key objectives of this modernization project, including:
- Aligning the broader regulatory approach with the Strategic Plan (i.e., a focus on Right-Touch Regulation), including a focus on areas of greatest risk;
- Updating the Program Standards to increase clarity, reference and align with existing external standards, and promote and allow for professional judgment;
- Coordinating and leveraging existing regulatory tools, such as existing standards, policies and clinical practice guidelines (e.g., holding individual physicians practising in OHPs accountable for compliance), the role of Medical Directors (e.g., expanding oversight and responsibility), the quality monitoring and oversight regime offered by OHPIP and PIC, and finally, the investigative process.