Several organizations were asked to provide feedback on the concept paper describing PLACIS, a Physician Learning and Continuous Improvement System, developed by a taskforce of individuals participating in the Physician Accountability for Physician Competence summits.

The following feedback was provided by the AMA Council on Medical Education.

COMMENTS OF THE

AMERICAN MEDICAL ASSOCIATION COUNCIL ON MEDICAL EDUCATION

ON THE PLACIS

The American Medical Association Council on Medical Education has reviewed the proposal for a “Physician Learning and Continuous Improvement System” (PLACIS) and offers the following comments for consideration.

A system to assemble and organize data about physician performance for specific purposes, as exemplified by PLACIS, could be an extremely useful tool for physicians. There are, however, several issues that need to be addressed in order to assure that the PLACIS serves its stated purpose of supporting “lifelong learning, self-assessment, reflection, and continuous improvement.

  • Absolute physician control over information dissemination. Ease of access to data about physician performance would prompt many interested groups (payers, regulators) to request information for purposes outside of, and even contrary to, the stated purposes of PLACIS. The system must assure that only the physician has absolute control about what data are released and under what circumstances. This would mean either that: (1) each request is approved by the physician or (2) clearly-defined blanket permission for the release of certain classes of data is given. In the later case, the conditions would need to be specified in detail.
  • Security/confidentiality of information. There is a need to assure that information brought into the Trusted Agent Applications from the data repositories are handled securely. Information for the physician’s own use, such as self-reflection, must be especially protected as it is meant for strictly formative purposes.
  • Data accuracy. PLACIS should only use data from data repositories that regularly check data for accuracy. Physicians should have the right to challenge the accuracy of data in databases and also in what is distributed through the Trusted Agent, and should be able to provide corrections.
  • Appropriate validation of physician performance data. The proposal describes the National Alliance for Physician Competence as being the body that, along with “broad input,” develops standards for data. It is critical that the mechanisms for data validation be widely vetted, broadly accepted, and widely disseminated.
  • Longitudinal data access/Appropriate mechanisms to access data from organizations serving as data repositories. The “predetermined business rules” by which the Trusted Agent gains access to data from the organizations that serve as data repositories must be clearly defined and be transparent. A process must be created to determine which organizations will supply data. The mechanisms by which these organizations will be compensated for the provision of data must be defined.
    Also, some data may be available on a time limited basis (eg, medical school performance/grades) or be under the physician’s personal control (self-reflection). These latter considerations add complexity to building a platform to assemble information that tracks the physician’s lifelong development. It seems likely that the PLACIS system might work best within a given phase of a physician’s career (medical school/residency/practice).
  • Linking with systems to store physician personal information (for example, physician self-reflection) or practice data. It appears technically complex to link the broad array of individual or organizational data, which may be stored in personal or organizational computer systems, into the Trusted Agent network. Linking also could make physician personal data accessible to external groups. There may be types of data that should be excluded from access (and, therefore, from PLACIS) as a matter of principle. Linking into individual practice sites/networks for patient-based data also seems to present similar complexities.
  • Costs for use of the system. Costs for access to the data should not be borne solely by the physician. Those that request data should be responsible for any fees to access the system.

In summary, the PLACIS approach could have considerable benefits but also presents considerable challenges. Major issues are assuring: (1) confidentiality and physician control of data; (2) data validation and accuracy; (3) technology that supports acquisition of the broad array of data that would be useful for physician performance assessment; and (4) oversight of PLACIS by appropriate physician organizations to assure the appropriate collection, protection, and use of physician data.

The Council on Medical Education appreciates the opportunity to provide feedback on this proposal.