• Σχόλιο του χρήστη 'Dr. Anna Ritsatakis' | 12 Ιουλίου 2020, 22:09

    Σχεδιο νομου του Υπουργειου Υγειας «Ρυθμίσεις για την διασφάλιση της πρόσβασης σε ποιοτικές υπηρεσίες και ίδρυση του Οργανισμού Διασφάλισης της Ποιότητας στην Υγεία Α.Ε. (ΟΔΙΠΥ Α.Ε.)» A. General comments The intention “to improve the quality of health services in Greece, to strengthen patient safety, and to rationally reorganize the country’s health services, with the aim of equal access and universal coverage of the population” is very welcome. The “Programmatikes Theseis” of the Prasinoi party in Greece, emphasise the need for patient-centered services, the broad implementation of clinical guidelines and continuous evaluation of health care using internationally recognized indicators. We also give priority to tackling inequalities in health status and in access to health care. Although I am responsible for the Health Group of the Prasinoi party, the following are personal comments, and do not necessarily represent that group. The draft law states that following the establishment of ΟΔΙΠΥ, the Organization will draw up a Κοινό Πλαίσιο Αξιολόγησης, as a manual for quality evaluation, which will analyse the indicators and tools to be used. Naturally, the proposed process for quality evaluation outlined in the present draft law, can only be properly understood when this manual is available. Finally, one might question the need for a new organization, with its presumably, considerable costs. Could the tasks outlined here, not have been completed more economically, by sharing them between existing organizations such as the universities, the School of Public Health, the National Centre for Social Research, the Centre for Planning and Economic Research, and other existing research centres.? B. Specific comments 1. International organizations dealing with this issue, for example, WHO, OECD, World Bank, all state that it is essential to develop a national quality assurance policy and implementation strategy, either as a stand-alone national document, or as part of a national health policy. As far as I am aware, the Government has not yet developed such a policy as the framework for quality assessment. 2. (Article 1) The proposed quality assessment relates to public services and those under private law supervised by the MoH, whereas quality assessment services provided by the new organization for private services would only be at the request of those services. What measures are envisioned to ensure that private health services offer high quality care? 3. (Article 2) This article, plus article 3 of the ΟΔΙΠΥ Charter, state that apart from quality assurance, the new organization will be responsible for formulating strategies for the health sector and the reorganization and improvement of health services. It is not clear how these responsibilities a) will be linked to similar responsibilities of services within the Ministry of Health, and b) how they can be fully implemented when the proposed ΟΔΙΠΥ is responsible for evaluating health services, rather than also evaluating health promotion and protection and the social determinants of health. There could be a danger of slipping back into outdated approaches where health is seen mainly in the framework of health care. 4. (Article 4) It is not clear how, and from where, people will be selected for the ”list of external experts”, on the basis of what criteria? This needs particular care, to ensure firstly that the best skills are employed, and secondly to avoid criticism of “jobs for the boys,” which unfortunately has a rather long tradition. 5. (Article 5 para 1) As presented by the draft law, it is essential that quality evaluation and assurance is carried out on a continuous basis. Such evaluation can, however, be quite time consuming and one wonders how it will be possible for regular evaluation of all public health services to be carried out every three years. There is a danger of this gradually becoming a superficial process with rather unwilling participants. This again points to the need for a Government policy and strategy to set the framework for quality assurance goals and targets. 6. (Article 5 para 2) There are many manuals for quality evaluation available abroad, and it would be very welcome if their advice could be adapted to fit the Greece situation. The use of internationally accepted indicators, would allow Greece to compare developments with those in other countries. In order to tackle inequalities in health, patients’ socio-economic characteristics must be reflected. 7. (Article 5 para 3) It appears that on the basis of proposals from the Administrative Council of ΟΔΙΠΥ, the Ministry of Health selects which hospitals or other services will be assessed. That is, if this is not my misunderstanding of the text, individual hospitals or primary care services are selected for evaluation. One of the serious problems of the system in Greece is that collaboration of the different levels of health care, patients’ progress through the system, and links with social services are frequently not coordinated. It is to be hoped, therefore, that rather than a single hospital for example, the range of services within a particular neighbourhood or area would be assessed, including collaboration or the lack of it, between levels of health care and other sectors. 8. Article 5 para 5 and 10) It is essential that quality evaluation is seen to be a continuous process, adopting new standards and ways of thinking. Implementing a two-level system, with services carrying out their own evaluation first, can be a valuable type of self-training, offering opportunities for services to question why things are done the way they are, and preparing the way for the external evaluators. However, carrying out such evaluations in all public services every three years could be costly, time-consuming and wearisome. Perhaps incentives for improved self-evaluation, (first level) would allow the second level evaluation at a later period in some cases ? 9. (Article 5 para 11) Although reports are essential and valuable, the impression is given here again, that hospitals are the number one point of interest, when worldwide it has been accepted that there should be a stronger focus on primary health care and health promotion. In addition, certain vital services such as long-term and palliative care are practically non-existent in Greece. Given the present epidemic, one would expect emergency preparedness to also be of high concern for evaluation. 10. Article 6 This article employs the six categories for evaluation frequently used in international bibliography. It will be interesting to see how these are developed in the proposed manual, with accompanying indicators and methods. 11. Article 7 Refers to rewarding those services which are evaluated as being highly successful. The rewards include increased participation in funded clinical trials, participating in EU projects, engaging additional research personnel, and obtaining innovative equipment for carrying out new methods etc. Acknowledging success is essential, and is sometimes overlooked in favour of searching for weaknesses. Care will need to be taken, however, that the creation of so-called “reference centres” does not produce a two-level health system, with highly successful, well funded and staffed units to be enjoyed by those lucky enough to live in their catchment area, (probably the large urban centres) whilst others only have access to a lower level of care. 12. Article 13 outlines the ΟΔΙΠΥ Charter. Whereas the draft law purports to support a patient-centered approach, which means that patients and their families should be included in planning and decision-making, the seven-member Administrative Council described in article 9 of the Charter, consists of the President, the General Director, 4 specialists and 1 representative of the Ministry of Health. Patients and their families are not represented on the Council. 13. Αrt. 4θ of the charter states that the organization will research, population health needs, gaps etc, and will make proposals to tackle these and to reorganize the health services. Again it is essential that this is done with the participation of the population, and that proposals are made for tackling the social determinants of health and resulting health inequalities.. Dr. Anna Ritsatakis, former Head, WHO European Centre for Health Policy