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CRP CERTIFICATION FAQs

Introduction Questions

  1. Who manages the CRP Certification Program?   CRP Certification is a program of Washington Patient Safety Coalition (WPSC), housed at the Foundation for Health Care Quality in Seattle, Washington. The Foundation is a nonprofit organization dedicated to providing a trusted, independent, third party resource to all participants in the health care community – including patients, providers, payers, employers, government agencies, and public health professionals. The CRP program within the WPSC is a statewide, multi-stakeholder collaborative that was created in 2010 (originally under the name HealthPact) to promote transparency and communication in healthcare. By having CRP Certification at the Foundation, WPSC is better equipped to aggregate de-identified information on the response to medical injuries and disseminate it statewide so all healthcare providers can benefit from the patient safety lessons learned.

Application Questions

  1. How will applicants submit an application?  CRP Screening and Certification applications will be submitted by emailing a completed application and supporting documents to crp@qualityhealth.org.
  2. Will applications include identifying information e.g. hospital or clinician name?  Applicants will be asked to supply the names of all involved clinicians and healthcare organizations on the application. Patient names will not be requested. All names will be removed from the application before the case is brought to the CRP Review Panel for examination.
  3. When should applications be submitted for CRP Screening? Applications for CRP Screening can be submitted at any point during the CRP process. The CRP process does not need to be complete to submit an application for validation. It is recommended for organizations to submit a CRP Screening application if any challenges or barriers arise during the CRP process.
  4. When should applications be submitted for CRP Certification? Applications should be submitted once the CRP process is complete. The CRP process is complete when resolution has been met between the organization and the patient/their family.
  5. What happens once a CRP Screening or Certification Application is submitted? Submitted applications will be received by the WPSC.  The applications will be reviewed by the CRP Manager who will scan the application for completeness. The CRP Manager will then send an email to the applicant confirming receipt of the application and outlining the next steps in the review process. The CRP Screening or Certification application will be presented to members of the CRP Review Panel.  For CRP Certification, the Review Panel will decide whether to certify the event, to not certify the event, or to delay a decision until additional information can be provided by the applicant.
  6. Are there any events that are not eligible for CRP Screening or Certification?  CRP Screening and Certification is a Just Culture approach intended to facilitate the response to adverse events caused by human errors or faulty systems, processes and conditions that lead competent providers to make mistakes. CRP events will not be considered for certification if evidence suggests any involved provider poses a significant risk of harm to patients including, but not limited to: gross incompetence, recklessness, provider impairment and intentional misconduct.
  7. How do multiple parties apply for CRP Screening or Certification on the same event?  CRP participation encourages involvement from all relevant institutions, insurance carriers, and providers. Any involved entity may submit its own Screening or Certification application. All information submitted will be considered when reviewing the case.

Mandatory Reporting Questions

  1. Does CRP Certification or Screening change mandatory reporting requirements?  No. CRP Certification and Screening does not alter current requirements for mandatory reporting to the Washington Medical Commission (WMC) and other regulatory commissions. Applicants are responsible for submitting all applicable information to WMC or other agencies in addition to their CRP Certification application. Applications for CRP Certification/Screening, and information contained therein, will not be forwarded to WMC by the CRP Certification/Screening program.

CRP Review Panel Questions

  1. What’s the difference between a CRP Certification/Screening review and a regulatory  investigation?  During a traditional regulatory investigation, the regulator conducts a primary investigation of the event by speaking directly with involved parties and examining source documents. CRP Certification/Screening uses secondary accounts submitted by the applicant that includes information from the patient, provider, institution and insurer to assess whether the handling of the event met the high standards of the eight essential CRP practices.
  2. Does CRP Screening/Certification only consider the actions of individual licensed clinicians?  No. CRP Screening/Certification is granted to applicants that demonstrate a comprehensive response to adverse events. The CRP is a collaborative process that requires the involvement of multiple stakeholders and actions at both the individual and system levels to effectively meet patient, family and provider needs and close all safety gaps.  The application provides an opportunity for applicants to describe their efforts in collaborating with other partners involved in the patient safety event.
  3. What is the review process?  The CRP Certification/Screening review process begins when a institution and/or insurer involved in an adverse event chooses to submit a comprehensive description of how the eight essential CRP practices were met in response to the adverse event. The description will be submitted by downloading a CRP Screening or Certification application from this website, completing the application and attaching any necessary supporting documents, and returning the completed application and documents to crp@qualityhealth.org. Submitted applications will be reviewed by the CRP Manager for high-level completeness. Then the case will be presented to the Review Panel at regularly scheduled meetings. If the case is a Screening application, after the case is presented the Review Panel will determine if the core CRP commitments and the key CRP steps are present in the organization’s current CRP response. If the case is a Certification application, after the case has been presented the entire panel will discuss the individual components of the case and whether the eight essential CRP practices were satisfactorily met. If necessary, the panel may request more information from the applicant. After review of the information provided, the Review Panel will render a decision as to whether certification should be granted or denied. A final report will be returned to applicants of both CRP Screening and Certification.
  4. Who will be conducting the reviews?  Each review will be completed by a diverse set of experts familiar with medical harm and the essential CRP practices. The breadth of the Review Panel ensures that applications are objectively and comprehensively assessed by balancing any biases, values or priorities that a single reviewer may have. The exact makeup of the panel may vary according to the particular case – (e.g. if the event involved a radiology error, a radiologist may be recruited to be a part of that particular panel). Review Panel members will not be involved in the review process if they have a professional or financial relationship with the applicant organization, or if they have a close personal relationship with a provider being reviewed.
  5. What is the estimated time for review?  Time for review will be heavily dependent on the complexity of each application and the overall application volume. Completed CRP Screening applications will have an approximate return of 14 days. For CRP Certification applications, once a complete application has been submitted, a final Certification Report will be returned to the applicant within 30 days.
  6. What happens if a CRP Certification application does not qualify for certification?  If the Review Panel cannot grant certification because there are gaps in the information submitted or remaining opportunities for the applicant to fulfill the eight essential CRP practices, the Review Panel will contact the applicant and alert them of the gaps and/or opportunities. Applicants will then have the chance to achieve these aims and submit an addendum to their initial CRP Certification application. This iterative process will repeat until no gaps or opportunities can be identified. At this time, the Review Panel will make a final certification decision. If the application is still not considered certifiable, and the applicant has no additional information or actions to contribute, the application will be denied Certification. At this time, if the applicant believes the ruling to be erroneous, the applicant may appeal the decision on procedural grounds only to the CRP Certification Executive Director. The Executive Director will assess whether the review process was appropriately completed. If it is determined that the review process was done correctly, the denied certification will stand without opportunities for further appeal. If it is determined that the review process was faulty, the application will be re-reviewed up to one more time by a new review panel.
  7. What if an applicant only hears about an event when a claim is filed; is the application still eligible for Screening/Certification?  If the applicant was not aware of the adverse event before the claim was filed, the application can still be considered for Screening/Certification.
  8. Many performance/quality improvement activities can take months or years to reach completion; can certification be granted before the activities are complete?  In the course of assessing a CRP event it may become apparent that quality improvement measures may be necessary, but that they may take weeks or months to accomplish. Examples include physician CME, purchase of new equipment, changes in clinical care processes, or hiring of additional personnel.  If there is a plan for completing the performance/quality improvement activities, an application may receive provisional certification.
  9. Is the CRP certification application, along with the documents submitted with it, protected from discovery in a civil suit?  Yes, provided the applicant meets the conditions below. If the applicant is a hospital, RCW 70.41.200 protects information and documents created specifically for and collected and maintained by the coordinated quality improvement committee from discovery or introduction into evidence in any civil action. If the applicant is not a hospital, the applicant can receive the same protection by having the Department of Health approve its coordinated quality improvement program (CQIP) under RCW 43.70.510.Coordinated quality improvement programs may share information and documents with other approved coordinated quality improvement programs and maintain this protection.  In 2015, the Department of Health approved the Foundation’s CRP Validation/Certification process as a coordinated quality improvement program. Therefore, any information and documents an applicant submits as part of the CRP Screening/Certification process is protected from discovery. To ensure full protection, a non-hospital applicant must ensure that its Department of Health-approved CQIP specifically includes CRP activities and CRP Screening/Certification activities.  For CRP activities, the CQIP should include:
    1. Exchange of information between the risk manager and the CQIP committee; and
    2. Exchange of information between the risk manager or CQIP representative and the CQIPs of other health care organizations with CQIPs that are involved in their patients’ care.

    The CRP activities may involve the transmission of information about individual adverse event investigations, remedial actions and resolutions with patients and families.

    For CRP Screening/Certification activities, the Department of Health-approved CQIP should include

    1. Information and documents compiled for and submitted as part of the application to the CRP Screening/Certification event review board;
    2. Receiving the CRP Screening/Certification report; and
    3. Sending the Certification report and other information and documents to Department of Health licensing boards, commissions and programs.

    If the applicant’s Department of Health-approved quality improvement program does not specifically include these elements, the applicant should submit an amended quality improvement program to the Department of Health and redefine their program to include this material.

  10. Is the CRP Screening/Certification report issued by the CRP Review Panel to the applicant protected from discovery in a civil suit?  Yes, provided that the quality improvement program approved by the Department of Health specifically includes receipt of the Foundation CRP Review Panel Screening/Certification report. To maintain protection, the applicant must be sure to place the certification report into the CQIP files. If the applicant places the Screening/Certification report into the physician’s employment file, the Screening/Certification report may lose its protected status.

CRP Certification Report Questions

  1. What information will be included in the CRP Certification Report?  The Certification Report must supply enough information so that if the regulator receives the report from the applicant, the regulator can make full assessment that all patient safety concerns were addressed by the CRP process. The CRP Certification Report will only be sent to the CRP Certification applicant. It is up to the applicant to submit the Certification Report to the regulator if needed. The majority of the report will be the determinations of the review panel, but some of the original submitted material (e.g. relevant portions of the medical record that have been de-identified, verification of the individual and system-level lessons learned and remedial actions) will remain.
  2. How will the certification decision be communicated to the applicant?  The final Certification Report will be provided in PDF form via email to the applicant.

Quality Assurance Questions

  1. How do CRP Screening/Certification reviewers know if applicants are being honest?  CRP Screening/Certification is founded on a high level of trust between patient safety stakeholders. Unlike regulator investigations, applying for CRP Screening/Certification does not generally require primary source documents (e.g. interview transcripts, RCA documents); the review panel is assuming that applicants are being truthful about their processes and findings. However, in order to ensure quality, CRP Certification reviewers reserve the right to ask for source documents to substantiate statements in the application before granting CRP Screening/Certification.
  2. How will reviews be standardized across committees and cases?  All review panels will be expected to adhere to the clearly defined Screening/Certification criteria. CRP Screening/Certification will utilize standard quality assurance techniques to track how applications are reviewed across review panels and cases to ensure consistency and fairness.

Department of Health Regulatory Authorities Questions

  1. Should an applicant submit a CRP Certification report to the regulator, such as the Washington Medical Commission? If the regulator is aware of the event, an applicant should consider sending the certification report to the regulator.  Regulators may consider the certification report when deciding whether disciplinary action is necessary.  The Washington Medical Commission has signed a Statement of Understanding with the Foundation stating that the Commission will consider the certification report and accompanying documents and “use its discretion to determine whether or not to close the case with no further Commission action based on remedial action that has been completed and its judgment that patient safety issues have been fully addressed.” If the regulator is not aware of the event, there is no reason to send the report.
  2. What information should an applicant submit to a Department of Health regulator, such as the Washington Medical Commission? The regulator has a statutory obligation to review complaints, investigate complaints with merit, and take disciplinary action to protect the public from unsafe health care.  Therefore, the applicant should submit enough information for the regulator to fully assess the matter, and ensure that all patient safety concerns have been addressed by the CRP process. The applicant should consider submitting the certification report, and should consider submitting the application and all materials submitted to the CRP Event Review Board. The applicant may consider marking the documents as CQIP documents to make it clear that the applicant created the documents specifically for, and were collected and maintained by, a coordinated quality improvement program.
  3. I applied for CRP Screening and received a report validating my CRP response. Should I submit my CRP Validation report to WMC? No. The only CRP document that should be submitted to WMC (if a complaint or report concerning the event is open) is a CRP Certification report. The CRP Screening report is only for the submitting organization to incorporate feedback/learnings into their current CRP response. Only completed CRP processes (as determined by CRP Certification) should be submitted to WMC.
  4. What documents will the regulator release to the public? The Department of Health has approved the Foundation’s CRP Screening/Certification process as a coordinated quality improvement program under RCW 43.70.510. Under this statute, “Information and documents created specifically for, and collected and maintained by, a quality improvement committee are exempt from disclosure under chapter 42.56 RCW” (The Public Records Act). Therefore, the Department of Health, which handles all public records requests made to the health profession boards, commissions and programs, would not release any documents that meet this criteria. This would include the application for CRP Screening/Certification and documents submitted with the application, the Screening/Certification report issued by the Foundation CRP Review Panel, and any documents that are part of the applicant’s coordinated quality improvement program.
  5. Can a plaintiff’s attorney obtain the documents from the Department of Health or its boards, commissions and programs in discovery in a malpractice case? No.  Under RCW 43.70.510, documents “created specifically for, and collected and maintained by, a quality improvement committee” are not subject to discovery or introduction into evidence in any civil action. Therefore, any documents that were part of the applicant’s CQIP process, even if shared with the Foundation and then submitted to a regulator, are exempt from discovery in a malpractice case.
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