Regulatory Updates for Non-Hospital Quality Programs

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The Washington Department of Health (DOH) has amended WAC 246-50, the rules applicable to coordinated quality improvement programs (CQIPs) for non-hospital organizations.  The amendments go into effect on May 21, 2021.  While the new rules do not change CQIP components, the rule requires all current CQIPs to submit applications to DOH for the renewal of the CQIP by December 31, 2021.  Failure to do so results in the loss of the CQIP confidentiality and immunity protections. 

Background: Washington law (RCW 43.70.510) authorizes certain medical provider groups, non-hospital health care institutions and medical facilities licensed by DOH, professional societies or organizations, health care service contractors, health maintenance organizations, certain health carriers and others to maintain a CQIP.  The purpose of a CQIP is to improve the quality of health care services. An approved CQIP provides confidentiality protections for certain CQIP information and documents and immunity from civil liability for CQIP participants (See RCW 43.70.510(5), RCW 70.41.200, and RCW 4.24.250). Since inception of the program, over four-hundred (400) such organizations have successfully applied for status as an approved CQIP program.

Revised Rule: The updated rule implements the proposed rule and:

  • Clarifies that DOH has the authority to consider and approve modifications to CQIP mandated components that reflect the structural organization of the applicant;
  • Requires regular renewal of CQIPs every five years and establishes a process for renewal applications that is nearly identical to the original application process;
  • Requires all current CQIPs to submit renewal applications by December 31, 2021;
  • Extends the requirement that CQIPs submit an application for approval of modifications to include modifications mandated by changes to program requirements adopted by DOH or the legislature;
  • Mandates notice to DOH of a change in a CQIP’s authorized representative within 30 days;
  • Clarifies that applicants whose CQIP is rejected by DOH may resubmit or request a “brief adjudicative proceeding,” as defined by RCW 34.05.482;
  • Revokes immunity and confidentiality protections for CQIPs who fail to timely file a renewal application; and
  • Streamlines the regulatory language including definitions applicable to eligible entities.

Recommended Action Items:

If you are a currently approved program, engage in the mandatory renewal process by December 31, 2021 and note the 5 year renewal mandate.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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