As part of its ongoing efforts to better serve those who trust the university with their medical care, Michigan State University recently signed an agreement with the U.S. Department of Health and Human Services that outlines further improvements.
The recommendations from the DHHS’ Office of Civil Rights enhance the many protection and policy improvements the university has made since Larry Nassar’s arrest in September 2016.
“As an M.D., I’m well aware of the sacred trust that must exist between a medical professional and a patient. Breaking that trust is simply unacceptable – anytime, anywhere,” said MSU President Samuel L. Stanley Jr., M.D.
In April 2017, the university established a chaperone policy which requires chaperones for sensitive treatments and when minors are involved. Based on the recommendations from DHHS, the scope of the policy and age of patients impacted were further refined. For the past few years, MSU HealthTeam clinics also have employed a standardized consent to treat form that acknowledges the chaperone policy as well as other permissions. Principles on informed consent are reviewed with patients as well as parents or guardians several times during the registration and treatment process.
In addition, based on recommendations from an independent review conducted by Willis Towers Watson, the MSU HealthTeam expanded the role of the risk manager position. New committees were also established including the Steering Performance Committee; Wellness and Patient Experience Committee; Quality and Patient Safety Committee; and Credentialing Certification Committee.
A large focus of the DHHS review centered on efforts to respond, investigate and resolve patient-related complaints and grievances. In May 2018, health clinics implemented a triage protocol to review all reported allegations or concerns of inappropriate interactions between providers and patients or students. As part of this process, a multidisciplinary team reviews allegations to determine if there is a risk to patients, students or staff. If there is any concern, the provider is immediately removed from the care setting pending further investigation. This protocol is in addition to the required review by the Office of Institutional Equity and MSU Police Department.
MSU plans to implement recommendations from DHHS that will build upon this protocol. A new civil rights specialist will be assigned to all the buildings containing health clinics. The specialist will serve as a first point of contact for complaints, as well as a monitor of policy compliance. This person will also assist in implementing civil rights training programs.
In OIE, a position will be created solely focused on health care-related investigations. The dedicated investigator will review and resolve all Title IX grievances and complaints from the MSU HealthTeam and four health colleges.
“We want to break new ground in patient care and safety – go beyond implementing basic protection and protocols to find ways to best ensure privacy with complete transparency and accountability,” Stanley added. “I appreciate the thoughtful feedback on our efforts from our federal partners.”
The DHHS’ Office of Civil Rights notified the university in August 2018 of its plans to review MSU’s compliance with Title IX and Section 1557 of the Affordable Care Act. The mutually agreed upon recommendations set in August 2019 end the federal investigation.