Facility services may be provided directly by facility employees or indirectly (outsourced) by an outside individual or vendor via a contract. Examples of contracted services would include anesthesiology services, staffing, housekeeping, laundry services, medical record services, equipment maintenance, radiology services, pharmacy, and sterile processing, among others.
Who is responsible for services provided via a contract? What are the facility’s responsibilities in this situation?
The accredited facility has the primary responsibility and accountability for all contract services. A facility is expected to provide the same quality of care and patient safety, regardless of whether a service is provided directly or through a contract. The facility must verify that all applicable QUAD A standards are met by the outside vendor and have a process in place to validate compliance, staff competence, etc. Contracted services are considered part of the accredited facility, and the facility’s policies and procedures apply to all services provided by the facility. If the contracting agency provides documentation that does not meet QUAD A requirements, it is the facility’s obligation to confirm that the QUAD A requirements are met.
All staff, whether directly hired by the facility or contracted, must comply with any QUAD A standard referring to “personnel, provider, or staff.” From an accreditation perspective, contracted staff, including physician and non-physician staff, are considered employees of the facility. Therefore, the facility is required to maintain a personnel file for contracted staff, containing the same required documentation as those for employees hired directly by the facility. This includes competencies, credentialing and privileging, required immunizations, ongoing training, and education, etc. The facility must also keep copies of personnel files from the outside entity. Additionally, the facility is obligated to complete primary source verification for any clinical provider working in the facility.
Contract clinicians/vendors providing services in a facility must sign the facility Health Insurance Portability and Accountability Act of 1996 (HIPAA) confidentiality form and have a Business Associates Agreement (BAA) with the facility.
The accredited facility must oversee the quality of services provided through a contractual agreement. If an outside vendor is providing services, they must be furnished in accordance with the terms of a written contract that stipulates the accredited facility retains professional and administrative responsibility, as well as control and supervision of the services. Performance measures serve as a strategy to determine the quality of contracted services, and a requirement for these measures should be included in the contract language with the vendor.
Evaluation of Contracted Services
Contract services must be incorporated into the facility’s written quality assessment and performance improvement (QAPI) program. There are various ways to evaluate contracted services, including but not limited to reviewing the contractor’s accreditation or certification, observing care, auditing medical record documentation, reviewing incident reports complaints, and adverse events, reviewing periodic reports submitted by the vendor, and assessing performance measures Reports from staff and patients can also provide valuable insights
If the contracted services do not meet the terms of the contract, facility leaders must take steps to address the identified issues to improve the care, treatment, and services provided. In some cases, it may be best to work with the contractor to make improvements, while in other cases, it may be necessary to renegotiate or terminate the contractual relationship.
Since 1980, QUAD A (a non-profit, physician-founded and led global accreditation organization) has worked with thousands of healthcare facilities to standardize and improve the quality of healthcare they provide – believing that patient safety should always come first.