The American Osteopathic Association and the American Osteopathic Healthcare Association

This statement is presented on behalf of the American Osteopathic Association (AOA) and the American Osteopathic Healthcare Association (AOHA). The AOA represents the 44,000 osteopathic physicians throughout the United States who practice medicine and are committed to ensuring the highest standards of patient care. The AOA is the national professional organization for osteopathic physicians, and is the recognized accrediting authority for colleges of osteopathic medicine, osteopathic postdoctoral training programs and osteopathic continuing medical education. The AOHA represents the nation's hospitals and health systems that deliver osteopathic healthcare or osteopathic graduate medical education.

Osteopathic medicine is one of two distinct branches of medical practice in the United States. While allopathic physicians (MDs) comprise the majority of the nation's physician workforce, osteopathic physicians (DOs) comprise more than five percent of the physicians who practice in the United States. Significantly, D.O.s represent more than 15 percent of the physicians practicing in communities of less than 10,000 and 18 percent of physicians serving communities of 2,500 or less.

The AOA and the AOHA are deeply concerned about the frequency of so-called "adverse events" or "preventable adverse events" cited by the Institute of Medicine in its recent study, "To Err is Human." The Institute reported that between 44,000 and 98,000 patients died or were injured in 1984 and 1992 as a result of these "adverse events."

The members of the osteopathic medical profession have long supported efforts to improve patient care by drastically reducing medical errors. In 1945, the AOA's Healthcare Facilities Accreditation Program (HFAP) was established. The HFAP is authorized by the Health Care Financing Administration (HCFA) to accredit osteopathic and allopathic hospitals and healthcare systems for Medicare purposes. The HFAP also assists hospitals and their staffs in reducing or eliminating medical errors by developing Quality Monitoring and Improvement programs that monitor patient safety.

The AOA and AOHA generally support the IOM's recommendations to bolster nationwide efforts to improve patient safety. We support forums that explore ways in which healthcare organizations can participate in the effort to reduce medical errors. The healthcare community can, and should, expand current activities to identify and address system failures that lead to medical errors. The osteopathic medical community fully intends to strengthen existing quality improvement efforts at every level, including education and training of medical professionals and administrative personnel. We do not believe that the way to improve healthcare is to increase federal mandates, regulation, and administrative burdens.

The AOA and the AOHA agree with the IOM that it is important to have reliable information about "adverse events" that healthcare professionals can use to assess, analyze and correct systemic and other failures that lead to such events. There is potential for such information to enhance the understanding of medical errors, while preventing future errors. However, there is scant proof among the approximately 20 states currently reporting such data that the healthcare systems are any safer in those states than in states that do not have such reporting.

Having said that, we do believe that state medical error reporting programs already in place may offer models for a federal effort to compile similar data. These should be closely reviewed and considered before federal action is taken. For instance, the data now being collected should be analyzed to determine whether or not the data used in the IOM study is reflective of the current state of affairs. Additionally, consideration ought to be given to the development of pilot projects designed to collect adverse event data. Finally, federal agencies should use the data compiled by states with mandatory reporting programs to determine whether their data is comparable with the IOM's data, which may be outdated.

Outdated data may have distorted the IOM's conclusions about the alleged epidemic of medical errors. Accurate data could help federal agencies determine which areas of healthcare result in the most errors and are most in need of reform. Accordingly, the AOA and AOHA would recommend a revised study using more current data than 1984 or 1992 as reported by the IOM.

Mandatory reporting of adverse events presents a number of serious problems. Healthcare facilities may be reluctant to cooperate with mandatory (or even voluntary) data reporting if they perceive that they will be disciplined. It will be difficult to learn from errors and to improve systems if facilities and individuals fear that the information will be used against them. Only after the IOM study and its supporting data have been fully analyzed and pilot projects established, should policymakers consider the establishment of a national database, with either voluntary or mandatory reporting. It is important to remember the rationale for such a database - the improvement of outcomes for patients.

As a national effort to gather and analyze adverse event data goes forward, the information should not be solely available to federal healthcare agencies. It also must be available to healthcare facilities, researchers, accreditation organizations, and other healthcare entities that, in turn, could use the data to benchmark and monitor changes in the occurrence of medical errors. In this way, the database would serve as a tool to promote higher standards of patient care.

Identifiable data should not be available to the public. Healthcare professionals continuously work to correct medical errors. The AOA and the AOHA believe that the American healthcare system operates well on the whole. Public confidence in that system should not be undermined while healthcare providers seek to increase patient safety.

The AOA and the AOHA recommend that data confidentiality be guaranteed by stripping the data of all possible identifiers. Healthcare facilities and providers who report and assess medical errors can attempt to rectify particular problems by monitoring their data and by comparing it with federal, state and local trends. Identifiable data is not necessary for this function to be met.

Another reason that the AOA and the AOHA recommend national data remain confidential and secure is that such data could be used as background information for litigation. Any national data that is gathered should be considered information only for peer review. Since peer review protections vary greatly from state to state, at a minimum, any federal data gathering initiative must provide protection from discoverability and use in malpractice litigation. The data must be used only for the purpose of improving the safety standards of American healthcare.

The AOA and the AOHA applaud the Agency for Healthcare Research and Quality and the Quality Interagency Coordination Task Force for convening the National Summit on Medical Errors and Patient Safety Research. We appreciate your willingness to listen to our concerns and those of other members of the medical community. No one denies that additional, reliable information is needed before constructive action can be taken in the area of medical errors.

In conducting such research, we believe it is important to have physicians of the appropriate specialties and licenses, as well as osteopathic and allopathic hospital risk managers, analyze the research instrument and the data it produces. Such examination should help ensure the accuracy and utility of the data collected. In analyzing this information, it is also necessary to address errors that occur in a variety of contexts and healthcare settings to identify recurring problems and to develop ways to correct them as quickly as possible.

Questions the AOA and AOHA would raise about the research process include:

1. How will up-to-date data be collected?
2. How and to whom will it be made available?
3. What will be the role of healthcare providers in the data collection process?
4. What role would the data play in improving patient care?

The AOA and the AOHA stand ready to support the Agency for Healthcare Research and Quality and the Quality Interagency Coordination Task Force in conducting the research necessary to help the medical community raise the already high standard of healthcare in the United States. Thus, we welcome the opportunity to work with you and others dedicated to patient safety. We are available to assist in the development of research projects and the necessary analysis of the data collected with the end goal being the continued improvement of the American healthcare system.

We thank you for the opportunity to submit this statement. We look forward to participating in future meetings on the important issue of medical errors.

Current as of September 2000

Internet Citation:

The American Osteopathic Association and the American Osteopathic Healthcare Association. Additional Statement. National Summit on Medical Errors and Patient Safety Research. September 2000. http://www.quic.gov/summit/aaoa.htm

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