Clinical Practice Guidelines and the Utilization Quality Nexus
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AHLA Seminar Materials Clinical Practice Guidelines and the Utilization Quality Nexus I. Clinical Practice Guidelines: Historical Development A. Length of Stay Norms 1. Mandated with PSRO program 2. Commercial vendors B. PSROs: Norms, criteria and standards 1. Norms a. “principal points of evaluation and review” b. “professionally developed” c. “based on typical patterns of practice” 2. National Professional Standards Review Council to provide for preparation and distribution to each PSRO appropriate materials indicated “regional norms to be utilized” 3. Definitions: a. norms: numerical or statistical measures of usual observed performance b. criteria : predetermined elements against which aspects of the quality of medical services may be compared c. standards: professionally developed expressions of the range of acceptable variation from a norm or criterion 4. National Council to provide sample sets 5. PSROs permitted to adopt or adapt or develop their own subject to National Council approval -- resulting in local norms, criteria and standards 6. To be used in four types of review and profiling a. preadmission review b. continued stay review c. concurrent admission certification d. retrospective review 7. Incentives to mandate conformity a. Denied payment b. Sanctions c. Malpractice exemption no physician and no provider “shall be civilly liable to any person ... on account of any action taken by him in compliance with or reliance upon professionally developed norms of care and treatment applied by a PSRO (§ 1167(c) of the Social Security Act, 1972) 8. Applied to HMOs
AHLA Seminar Materials “potentially the most effective anticompetitive device yet put in the hands of the medical profession” Testimony of Clark C. Havighurst, before Subcommittee on Antitrust and Monopoly, U.S., Sen., May 17, 1974 See, Gosfield, PSROs: The Law and the Health Consumer , Ballinger Publishing Co., Cambridge, 1975, 265pp C. PROs 1. Basic determinations a. Medical necessity and reasonableness b. In most economic setting c. In accordance with professional recognized standards of care 2. Applying “professionally developed norms of care, diagnosis and treatment based upon typical patterns of practice within the geographic area, ...taking into consideration national norms.” (§ 1154(a)(6)(A)) 3. ...[A] PRO must use national, or where appropriate, regional norms in conducting review (42 CFR §466.100(a)) 4. A PRO must establish written criteria based upon typical patterns of practice in the PRO area, or use national criteria where appropriate; and establish written criteria and standards to be used in conducting quality review ( 42 CFR §466.100(b)) 5. A PRO may establish specific criteria and standards to be applied to certain locations and facilities in the PRO area if the PRO determines that the patterns of practice in those locations and facilities are substantially different from patterns in the remainder of the PRO area; and there is a reasonable basis for the difference which makes the variation appropriate. ( 42 CFR §466.100(c)) 6. HMO Review: a PRO must determine whether the quality of services (including both inpatient and outpatient services) provided by an HMO or CMP meets professionally recognized standards of health care including whether appropriate health care services have not been provided or have been provided in inappropriate settings. ( 42 CFR §466.72(a)(1)) See also, Gosfield “Utilization Management, Quality Assurance, and Practice Guidelines,” (Vol III, Payment Issues, Chapter I), NHLA Health Law Practice Guide , Clark Boardman Callaghan, 1993 II. Agency for Health Care Policy and Research §6103 OF OBRA ‘89 creating a new Title IX of the Public Health Service Act A. Relationship to Part B Reimbursement B. Major Functions 1. Conduct and support research, demonstration projects, evaluations, training, guideline development, and the dissemination of information, on health care services and on systems for the delivery of such services, including activities with respect to a. the effectiveness, efficiency and quality of health care services and procedures b. the outcomes of health care services and procedures c. clinical practice, including primary care and practice-oriented research
AHLA Seminar Materials d. health care technologies, facilities and equipment, e. health care costs, productivity and market forces f. health promotion and disease prevention g. health statistics and epidemiology h. medical liability 2. Health technology assessment 3. Establishment of Advisory Council for Health Care Policy, Research and Evaluation C. Office of the Forum for Quality and Effectiveness 1. Arrange for the development, periodic review and updating of a. clinically relevant guidelines that may be used by physicians, educators and health care practitioners to assist in determining how diseases, disorders and other health conditions can be most effectively and appropriately be prevented, diagnosed, treatment and managed clinically; and, b. standards of quality, performance measures, and medical review criteria through which health care providers and other appropriate entities may assess or review the provision of health care and assure the quality of such care ( 42 USC §299b-1(a)) 2. Guidelines, standards, performance measure and review criteria shall a. be based on the “best available research and professional judgment...” b. be presented in formats appropriate for use by physicians, health care practitioners, providers, medical educators, and medical review organizations and in formats appropriate for use by consumers of health care; and c. include treatment-specific or condition-specific practice guidelines for clinical treatments and conditions in forms appropriate for use in clinical practice, for use in educational programs, and for use in reviewing quality and appropriateness of medical care (§299b-1(b)) 3. Priorities based on needs of Medicare a. high cost items b. items with substantial variation nationally or controversial 4. Initial topics selected a. Post operative pain management b. Urinary incontinence in adults c. Prediction and prevention of bedsores d. Benign prostatic hyperplasia e. Sickle cell anemia: screening, diagnosis, management and counseling new newborns and infants f. Low back pain problems g. Treatment of depression by primary care physicians in the outpatient setting h. Evaluation and management of early HIV infection
AHLA Seminar Materials i.Management of cancer related pain j.Treatment of pressure ulcers in adults k.Quality determinants of mammography l.Otitis media with effusion in children m.Heart failure: evaluation and care of patients with left ventricular systolic dysfunction n. Post stroke rehabilitation o. Screening for Alzheimer's and related dementias p. Cardiac rehabilitation q. Diagnosis and management of unstable angina r. Smoking prevention and cessation s. Diagnosis and treatment of anxiety and panic disorder in the primary care setting D. Guidance to the Agency: See, Institute of Medicine, “Clinical Practice Guidelines: Directions for a New Program,” National Academy Press, 1990 1. Definitions a. practice guidelines : systematically developed statements to assist practitioner and patient decisions about appropriate health care for specific clinical circumstances b. medical review criteria: systematically developed statements that can be used to assess the appropriateness of specific health care decisions, services and outcomes c. standards of quality are authoritative statements of (1) minimum levels of acceptable performance or results, (2) excellent levels of performance or results or (3) the range of acceptable performance or results d. performance measures (Provisional): are methods or instruments to estimate or monitor the extent to which the actions of a health are practitioner or provider conform to practice guidelines, medical review criteria or standards of quality 2. Attributes of good guidelines a. Validity: when followed, they produce expected outcomes b. Reliability/reproducibility: another group of experts would produce the same set, guidelines are interpreted and applied consistently in given circumstances c. Clinical applicability: appropriate definition of patient populations to which they pertain d. Clinical flexibility: identify known or generally expected exceptions e. Clarity: unambiguous language, logical to follow f. Multidisciplinary process: developed by diverse group g. Scheduled review h. Documentation available and meticulously described as to participants, evidence assumptions and rationales
AHLA Seminar Materials III. Guideline Differences A. Sponsorship 1. Specialty societies 2. Different practitioner groups: e.g., nurses, PTs, etc 3. Payors: coverage and technology exclusions B. Local Variation 1. How much should be permitted? 2. Why is it done? a. ownership b. understanding C. Types 1. Randomized clinical trials based 2. Literature search 3. Consensus based 4. Consumer participatory D. Controversies 1. Cost driven P.L. 102–410 AHCPR reauthorization requires “information on costs...where cost information is available and reliable” (§5(a)(5)) 2. How to include patient choice 3. Minimal or optimal 4. What about socio-economic factors E. Evidentiary value of each See, Institute of Medicine, Guidelines for Clinical Practice: From Development to Use , National Academy Press, 1992 IV. Applications A. Coverage 1. Benefits Design 2. Case Management 3. Coverage and Technology Exclusions B. Selective Contracting 1. Selection 2. Profiling practitioners 3. Corrective action C. Risk management and lower premiums COPIC mandated performance D. Fraud and Abuse Failing to provide medically necessary items and services to Medicare beneficiaries:§1128(b)(6) of the Social Security Act E. PRO Review
AHLA Seminar Materials F. Malpractice 1. Whose guidelines are evidence? 2. What value are they given? See, Brennan, “Report to Physician Payment Review Commission: Practice Guidelines and Malpractice Litigation,” January 25, 1994 3. State experiments: Maine, Minnesota, Florida, Maryland 4. PRO statute G. Will they apply in actions based on consent? H. Guidelines and Tort Reform I. Translating Guidelines into Medical Review Criteria, Standards of Quality and Performance Measures 1. What methodology? 2. New forms of producer liability 3. Bona fides of selecting guidelines V. The Law of Utilization Management A. Federal Fraud and Abuse Laws as surrogates: The need for UM 1. Anti-referral legislation 2. HMO Liabilities a. Civil money penalties of up to $2,000 per claim to be imposed upon any HMO which makes a payment directly or indirectly to a physician as an incentive for the reduction or limiting of services provided to a Medicare or Medicaid beneficiary -- effective April 1, 1991, extended from April 1, 1990, but not eliminated in face of proposals that more study was necessary (§4204 OBRA '90: Establishes criteria for incentive plans effective January 1, 1992 (§1876(i)(8)(A). b. HMOs which fail substantially to provide medically necessary services required under law or contract, where the failure to provide them either adversely affects or has a substantial likelihood of adversely affecting a Medicare or Medicaid patient are subject to a civil money penalty of up to $25,000 (§1876(i)(6)(A)) B. RBRVS and VPS 1. Utilization assumptions 2. Based on what? C. “Anti-managed care” laws which run contrary to these premises 1. Mandated benefits 2. Unlimited provider selection 3. Mandated coverage and approaches to provider networks and benefits 4. Restricted financial incentives 5. Utilization review Issues, (Examples) a. Immunity for individual physicians conducting review b. Requirement for adequate numbers of physicians c. Requirement for a physician
AHLA Seminar Materials d. Review by physician on appeal D. ERISA 1. Preemption 2. Who has discretion in the plan: Firestone Tire and Rubber Co. v. Bruch , 489 US —, 109 S. Ct. 948, 103 L. Ed. 2d 80 (1989) 3. Difference in review by court a. Arbitrary and capricious b. De novo c. but see, Brown v. Blue Cross and Blue Shield of Alabama , 898 F.2d 1556 (11th Cir., 1990)where conflict of interest in plan exercise of fiduciary responsibility can overcome standard of review 4. Cases in which utilization management was at issue under ERISA a. Elsesser v. Hospital of PCOM , (D. Ct., E.D. Pa., Civ. Action 92-3045, September 300, 1992) Patient has holter monitor removed after one day because HMO wouldn't pay; ERISA does not preempt malpractice claim but does preempt on instructions to physician that it would not pay, misrepresentation claim and breach of contract. b. Corcoran v. United Healthcare Inc. , 965 F. 2d 1321 (5th Cir, 1992) Baby dies after mother discharged on recommendation of UR company and insurer; ERISA preempts as a medical decision incident to a benefit decision. No remedy. c. Kuhl v. Lincoln National Health Plan , Nos. 92-2604/92-2607 (D.C. W.D. Mo., July 7, 1993) ERISA preempts where requirement for precertification denies access to highly specialized cardiac surgery since precert had not been obtained; patient died awaiting heart transplant after delay. d. Damare v. Occidental Petroleum Corporation Medical Care Plan , (D.C. E.D. La., Civ Action 92-1779, March 24, 1993) ERISA preempts on denial of payment for non-emergency hysterectomy for failure to obtain precertification and failure to perform appropriate diagnostic tests where Aetna handles determinations on ASO contract. e. Dearmas v. Av-Med, Inc. , 1993 WL 51541 (S.D. Fla.) Patient transferred among four hospitals in three days following auto accident within ERISA definitions of benefit determination, but violation of anti-dumping statute does not state and ERISA claim and cannot be used against an HMO; see also Bangert v. Christian Health Services , (No. 92- 613 WLB, D.C. So.D. Ill., December 17, 1992) f. Nazay v. Miller and Bethlehem Steel , 949 F. 2d 1323 (3d Cir., 1991) Retired employee, hospital admission agreed necessary, but failure to obtain prior approval by the plan, 30% financial penalty imposed. Retiree had an outdated card which did not state pre-cert requirement, so hospital did not check with Blue Cross either. Amount at issue $2,231.51. 1. Trial court: imposition of 30% penalty for failure to obtain prior authorization was arbitrary and capricious
AHLA Seminar Materials 2. Ct. of Appeals: “Bethlehem as an employer is free to develop an employee benefit plan as it wishes because the creation of a benefit plan is a corporate management decision unrestricted by ERISA's fiduciary duties.” VI. Non-ERISA based Liability of the reviewing entity A. Wickline. v. California , 228 Cal Rptr 661, 231 Cal Rptr 560, 727 P 2d 753 (1986) Everybody into the pool: Liability to all who deny care with resulting patient harm where standard is not proper, appeals are ignored, arbitrary decision-making B. Sarchett v. Blue Shield of Ca , 729 P 2d 276 (1984), Sup Ct of Ca., LA 31988 (Jan 2, 1987) Must allow appeals, but notice must be sufficient to permit the appeal right to be exercised; not enough to put it in the contract C. Hughes v. Blue Cross of Northern California burden on the insurer to investigate; must use community standard of care; must provide enough information for subscriber to pursue appeal rights (245 Cal. Rptr 273, 199 Cal. App. 3d 958 (1988); 215 Cal App 3d 832 (1989) D. Wilson v. Blue Cross of Southern Ca , 1990 Cal Lexis 4574 Denial of motion for summary judgment where reviewing entity sought to avoid liability on the grounds that Wicklin imposes it only on physicians. Suit proceeded to trial with verdict for defendants -- no bad faith; but a reported settlement with the utilization review company after insurer and utilization review company, counterclaimed against the attending physicians and hospital after their motion for summary judgment was denied E. Stout v. Board of Pensions , Super Ct. No. 601876, 4 App. Dist Cao., January 29, 1993) Long term psychiatric patient care reviewed by Preferred Health Inc., decision to discharge made by all treating physicians and utilization review physicians, at a point when patient had exhausted all of $2000 cap on outpatient mental health benefits. Patient told he cannot continue in outpatient therapy if he does not pay. He runs away and lives in his car. Eventually he is readmitted to the hospital. Plaintiff appeals granting of summary judgment for plan. Court of appeals affirms distinguishing Wilson because all physicians agreed he needed outpatient care, and alternative arrangements had been made. Court finds for plan. VII. Practical Guidance on Avoiding Review Liability A. What does the contract say about medical necessity? 1. Definition of medical necessity in the contract terms will be important, even where courts have held that the right to deny payment based on utilization review exists, it is not inherent: Schroeder v. Blue Cross and Blue Shield of Wisconsin, Ct. of Appeals , Wisconsin, Nov. 1, 1989, No. 89-00150 2. Se also, Patterson v. HMO Nebraska Inc. , Lancaster County, Nebraska, 422, Jan. 25, 1988where primary physician certification dispositive of issue of coverage of twenty-four hour nursing in the home, since if no nursing rehospitalization would be required and if rehospitalized, 24 hour nursing would be provided
AHLA Seminar Materials B. What type of process did you use? 1. Staff Builders v. Armstrong , 37 Ohio St 3d 298 (1988), $25,095.01 at issue for in-home nursing. Issues involved the level of investigation by the insurer and the nature of the notices sent to the patient and assigned-to nurse agency, indicating nothing more needed to be done; claims subsequently denied. Damages: $35,000 compensatory damages; $50,000 for bad faith, $125,000 punitives 2. ERISA does establish what kind of review must take place: see, Reed v. Lincoln National Corporation , U.S. D.Ct., Civil No. F 88-20, Nov. 22, 1989, where plan tried to use out of contract case management to lower benefit pay- out; court found that plaintiff did not receive a “full and fair review” of his claims -- denied access to report, report not specific, no evidence Committee reviewing made its own determination 3. Bellanger v. Health Plan of Nevada , CV-92-020-PMP D.C. Nev., Dec. 22, 1992) Prior authorization for surgery required, PCP did not approve, patient went out of network, patient sued for cost of surgery alleging that ERISA requires that notice of denial state requirements for perfecting appeal along with specific reason for denial which had stated denied as “out of area services” but real reason was second opinion required. Court found in favor of plaintiff. C. Prior authorization 1. Psychiatric pilot program Two psychiatrist sue Blue Cross and Blue Shield of Michigan challenging prior authorization and concurrent review; challenge based on requirement to deal with unlicensed personnel and intrusion on physician-patient relationship. Varol v. Blue Cross Blue Shield of Michigan , No. 88-40095, E.D. Michigan, March 2, 1989 a. ERISA preempts b. Unlicensed personnel could approve only; but a psychiatrist had to deny c. Like Wickline , physician retains the right and ethical and legal obligation to decide whether and how to treat 2. But beware of Bush v. Dake , Boyd v Einstein type cases where patient does not receive necessary care 3. Newell v. Prudential Insurance . (904 F 2d 644 (11th Cir., 1990)where conflict of interest in plan administrator functioning as insurer as well, burden is on fiduciary under ERISA to prove its interpretation of plan is appropriate -- upheld preadmission and continued stay review, upheld determination of need for further hospitalization for substance abuse, but abused its discretion in failure to follow notification procedures for concurrent review and failure to notify that claim would be subjected to retrospective review D. Guidelines as a bolster in UM VI. Scorecards A. Intarplan 1. US Healthcare 2. United Healthcare Corporation
AHLA Seminar Materials 3. Kaiser 4. Ethix B. NCQA Based upon HEDIS measures C. AHCPR report card (project announced September 19, 1994) D. See GAO Report, “Report Cards” Are Useful but Significant Issues Need to Be Addressed,” September 1994 E. Guidelines as a basis 1. Some performance measures are not clinical 2. Good guidelines project outcomes from their application 3. Deciding what to measure 4. Severity adjustments F. Controversies 1. Common data collection 2. Implications from formatting 3. Advertising issues related to guarantees 4. Consumer fraud and RICO? Attachments: Physicians Reference Guide to AHCPR Guidelines on Post Operative Pain Management Gosfield “Clinical Practice Guidelines and The Law: Applications and Implications” Attention ____ This Quick Reference Guide contains excerpts from the Clinical Practice Guideline for Acute Pain Management: Operative or Medical Procedures and Trauma , which was developed by an interdisciplinary non-Federal panel made up of health care practitioners, an ethicist, and a consumer. Panel members were: Daniel B. Carr, MD, (co-chair); Ada K. Jacox, RN, PhD, FAAN (co- chair); C. Richard Chapman, PhD; Betty Ferrell, RN, PhD, FAAN; Howard L. Fields, MD, PhD; George Heidrich III, RN, MA; Nancy O. Hester, RN, PhD; C. Stratton Hill, MD; Arthur G. Lipman, PharmD; Charles L. McGarvey, MS; Christine Miaskowski, RN, PhD; David Stevenson Mulder, MD; Richard Payne, MD; Neil Schechter, MD; Barbara S. Shapiro, MD; Robert Smith, PhL; Carole V. Tsou, MD; and Loretta Vecchiarelli. For a description of the guideline development process and information about the sponsoring agency (Agency for Health Care Policy and Research), see: Acute Pain Management Guideline Panel. Acute Pain Management: Operative or Medical Procedures and Trauma, Clinical Practice Guideline. AHCPR Pub. No. 92-0032. Rockville, MD: Agency for Health Care Policy and Research, Public Health Service, U.S. Department of Health and Human Services. Feb. 1992. A second guide presents excerpts from the Clinical Practice Guideline on acute pain management in pediatric patients; see: Acute Pain Management Guideline Panel. Acute Pain Management in Infants, Children, and Adolescents: Operative and Medical Procedures: Quick Reference Guide for Clinicians . AHCPR Pub. No. 92-0020. Rockville, MD: Agency for Health Care Policy and
AHLA Seminar Materials Research Public Health Service, U.S. Department of Health and Human Services. Users should not rely on these excerpts alone but should refer to the complete Clinical Practice Guideline for more detailed analysis and discussion of available research, critical evaluation of the assumptions and knowledge of the field, considerations for patients with special needs (e.g., intercurrent illness or substance abuse), and references. As stated in the Clinical Practice Guideline, decisions to adopt any particular recommendation must be made by the practitioner in light of available resources and circumstances presented by individual patients. For further information or to receive additional copies of guideline documents, call: 1-800-358-9295 or 301-495-3453; or you may write to the: Center for Research Dissemination and Liaison AHCPR Publications Clearinghouse P.O. Box 8547 Silver Spring, MD 20907 This document is in the public domain and may be used and reprinted without special permission, except for those copyrighted materials noted for which further reproduction is prohibited without the specific permission of copyright holders. AHCPR will appreciate citation as to source, and the suggested format is provided below: Acute Pain Management Guideline Panel. Acute Pain Management in Adults: Operative Procedures. Quick Reference Guide for Clinicians. AHCPR Pub. No. 92-0019. Rockville, MD: Agency for Health Care Policy and Research, Public Health Service, U.S. Department of Health and Human Services. Acute Pain Management in Adults: Operative Procedures Introduction The obligation to manage pain and relieve a patient's suffering is an important part of a health professional's commitment. The importance of pain management is further increased when benefits for the patient are realized- earlier mobilization, shortened hospital stay and reduced costs. Yet clinical surveys continue to show that routine orders for intramuscular injections of opioid “as needed” result in unrelieved pain due to ineffective treatment in roughly half of postoperative patients. Recognition of the inadequacy of traditional pain management has prompted recent corrective efforts from a variety of health care disciplines including surgery, anesthesiology, nursing, and pain management groups. The challenge for clinicians is to balance pain control with concern for patient safety and side effects of pain treatments. This Quick Reference Guide is intended to assist clinicians with these deviations. Patients vary greatly in their medical conditions and responses to surgery, responses to pain and interventions, and personal preferences. Therefore, rigid prescriptions for the management of postoperative pain are inappropriate. Several alternative approaches, appropriately and attentively implemented, prevent or relieve pain. This Quick Reference Guide contains excerpts from the Clinical Practice Guideline for Acute Pain Management: Operative or Medical Procedures and Trauma and addresses the assessment and management of postoperative pain in adults. The excerpts contained in this Quick Reference Guide provide clinicians with a practical and flexible approach to acute pain assessment and management. However, users should not rely on these excerpts
AHLA Seminar Materials alone but should refer to the complete Clinical Practice Guideline for a more detailed analysis and discussion of the available research, critical evaluation of the assumptions and knowledge of the field, considerations for patients with special needs (e.g. intercurrent medical illness or substance abuse), and reference. The flow chart, which follows, shows the sequence of activities related to pain assessment and management. This Quick Reference Guide provides information about the events listed in the flow chart. Postoperative Pain Management: A Brief Flow Chart Effective Management of Postoperative Pain Requirements • Pain intensity and relief must be assessed and reassessed at regular intervals. • Patient preference must be respected when determining methods to be used for pain management. • Each institution must develop an organized program to evaluate the effectiveness of pain assessment and management. Without such a program, staff efforts to treat pain may become sporadic and ineffectual. Principles • Successful assessment and control of pain depends in part on establishing a positive relationship between health care professionals and patients. Patients should be informed that pain relief is an important part of their health care, that information about options to control pain is available to them, and that they are welcome to discuss their concerns and preferences with the health care team. • Unrelieved pain has negative physical and psychological consequences. Aggressive pain prevention and control that occurs before, during, and after surgery can yield both short- and long-term benefits. • It is not practical or desirable to eliminate all postoperative pain, but techniques now available make pain reduction to acceptable levels a realistic goal. • Prevention is better than treatment. Pain that is established and severe is difficult to control. Pain Assessment and Reassessment Principles • Patients who may have difficulty communicating their pain require particular attention. This includes patients who are cognitively impaired, psychotic or severely emotionally disturbed, children and the elderly, patients who do not speak English, and patients whose level of education or cultural background differs significantly from that of their health care team. • Unexpected intense pain, particularly if sudden or associated with altered vital signs such as hypertension, tachycardia, or fever, should be
AHLA Seminar Materials immediately evaluated, and new diagnoses such as wound dehiscence, infection, or deep venous thrombosis considered. • Family members should be involved when appropriate. Pain Assessment Tools • The single most reliable indicator of the existence and intensity of pain—and any resultant distress—is the patient's self-report. • Self-report measurements scales include numerical or adjective ratings and visual analog scales (see Table 1 for examples). • Tools should be reliable, valid, and easy for the patient and the nurse or doctor to use. These tools may be used by showing a diagram to the patient and asking the patient to indicate the appropriate rating. The tools may also be used by simply asking the patient for a verbal response (e.g. “On a scale of 0 to 10 with 0 as no pain and 10 as the worst pain possible, how would you rate your pain?”). • Tools must be appropriate for the patient's developmental, physical, emotional, and cognitive status. Preoperative Preparation • Discuss the patient's previous experiences with pain and beliefs about and preferences for pain assessment and management. • Give the patient information about pain management therapies that are available and the rationale underlying their use. • Develop with the patient a plan for pain assessment and management. • Select a pain assessment tool, and teach the patient to use it. Determine the level of pain above which adjustment of analgesia or other interventions will be considered. • Provide the patient with education and information about pain control, including training in nonpharmacologic options such as relaxation (see Table 2 for a sample relaxation exercise.) • Inform patients that it is easier to prevent pain than to chase and reduce it once it has become established and that communication of unrelieved pain is essential to its relief. Emphasize the importance of a factual report of pain, avoiding stoicism or exaggeration. Postoperative Assessment • Assess the patient's perceptions, along with behavioral and physiologic responses. Remember that observations of behavior and vital signs should not be used instead of a self-report unless the patient is unable to communicate. • Assess and reassess pain frequently during the immediate postoperative period. Determine the frequency of assessment based on the operation performed and the severity of the pain. For example, pain should be assessed every 2 hours during the first postoperative day after major surgery. • Increase the frequency of assessment and reassessment if the pain is poorly controlled or if interventions are changing. • Record the pain intensity and response to intervention in an easily visible and accessible place, such as a bedside flow sheet.
AHLA Seminar Materials • Revise the management plan if the plain is poorly controlled. • Review with the patient before discharge the interventions used and their efficacy and provide specific discharge instructions regarding pain and its management. Management Options One or more of these approaches may be used: • Cognitive-behavioral interventions such as relaxation, distraction, and imagery. These methods may reduce pain and anxiety and control mild pain, but they do not substitute for pharmacologic management of moderate to severe pain. • Systematic administration of opioids and/or nonsteroidal anti- inflammatory drugs (NSAIDs), including acetaminophen. • Patient-controlled analgesia (PCA) usually denotes self-medication with intravenous opioids, but may include oral or other routes of administration. PCA offers patients a sense of control over their pain and is preferred by most patients to intermittent injections. • Spinal analgesia, usually with an epidural opioid and/or local anesthetic injected intermittently or infused continuously. • Intermittent or continuous local neural blockade, such as intercostal nerve blockade or infusion of local anesthetic through an interpleural catheter. • Physical agents such as massage or application of heat or cold. • Transcutaneous electrical nerve stimulation (TENS). • Note: The use of spinal analgesia or neural blockade or the infusion of local anesthetic through interpleural catheters require special expertise and well-defined institutional protocols and procedures for accountability. The administration of regional analgesia is best limited to specially trained and knowledgeable staff, typically under the direction of an acute or postoperative pain treatment service. Pharmacologic Management • Pharmacologic management of mild to moderate postoperative pain should begin, unless there is a contraindication, with an NSAID. However, moderately severe to severe pain should normally be treated initially with an opioid analgesic, with or without an NSAID. NSAIDs • Even when insufficient alone to control pain, NSAIDs, including acetaminophen, have significant opioid dose-sparing effects on postoperative pain and hence can be useful in reducing opioid side effects (see Table 4 for information on prescribing NSAIDs). • If the patient cannot tolerate oral medication, alternative routes such as rectal administration can be used. At present, one NSAID (ketorolac) is approved by the Food and Drug Administration for parenteral use. • NSAIDs must be used with care in patients with thrombocytopenia or coagulopathies and in patients who are at risk for bleeding or gastric ulceration. However, acetaminophen does not affect platelet function, and some evidence
AHLA Seminar Materials exists that two salicylates (salsalate and choline magnesium trisalicylate) do not profoundly affect platelet aggregation. Opioid Analgesics • Opioid analgesics are the cornerstone for management of moderate to severe acute pain. Effective use of these agents facilitates postoperative activities such as coughing, deep breathing exercises, ambulation, and physical therapy. • When pain cannot be adequately controlled despite increasing the opioid dose, a prompt search for residual operative pathology is indicated, and other diagnoses such as neuropathic pain should be considered. • Opioid tolerance and physiologic dependence are unusual in short-term postoperative use in opioid-naive patients. Likewise, psychologic dependence and addition are extremely unlikely to develop after the use of opioids for acute pain. Choice of Opioid Agent • Morphine is the standard agent for opioid therapy. If morphine cannot be used because of an unusual reaction or allergy, another opioid such as hydromorphone can be substituted. • Meperidine should be reserved for very brief courses in patients who have demonstrated allergy or intolerance to other opioids such as morphine and hydromorphone. Meperidine is contraindicated in patients with impaired renal function or those receiving antidepressants that are monoamine oxidase (MAO) inhibitors, Normeperidine is a toxic metabolite of meperidine, and is excreted through the kidney. Normeperidine is a cerebral irritant, and accumulation can cause effects ranging from dysphoria and irritable mood to seizures. Dosage of Opioid Analgesics • Patients vary greatly in their analgesic dose requirements and responses to opioid analgesics. The recommended starting doses presented in Table 5 may be inadequate. Subsequent opioid doses must be titrated to increase the amount of analgesia and reduce side effects. • Relative potency estimates provide a rational basis for selecting the appropriate starting dose, for changing the route of administration (e.g., from parenteral to oral), or for changing from one opioid to another. Equianalgesic doses for opioids are listed in Table 5. • Patients who have been receiving opioid analgesics before surgery may require higher starting and maintenance doses postoperatively. Dosage Schedule • Opioid administration relying on patients' or families' demands for analgesic prn, or “as needed,” produces delays in administration and intervals of inadequate pain control. • Analgesics should be administered initially on a regular time schedule. For example, if the patient is likely to have pain requiring opioid analgesics for 48 hours after surgery, morphine might be ordered every 4 hours around-the- clock (not prn) for 36 hours. Opioid administration is contraindicated when respiratory depression is present (less than 10 breaths per minute).
AHLA Seminar Materials • Once the duration of analgesic action is determined, the dosage frequency should be adjusted to prevent pain from recurring. • Orders may be written so that a patient may refuse an analgesic if not in pain or forego it if asleep. However, since a steady-state blood level is required for the drug to be continuously effective, interruption of an around- the-clock dosage schedule (e.g., during sleep) may cause a resurgence of pain as blood levels of the analgesic decline. • Late in the postoperative course, it may be acceptable to give opioid analgesics prn. Switching to prn dosing later in the postoperative course provides pain relief while reducing the risk of adverse effects as the patient's analgesic dose requirement diminishes. • Clinicians should assess patients at regular intervals to determine the efficacy of the intervention, the presence of side effects, the need for adjustments of dosage and/or interval, or the need for supplemental doses for breakthrough pain. Route • Intravenous administration is the parenteral route of choice after major surgery. This route is suitable for bolus administration and continuous infusion (including PCA). • Repeated intramuscular injections can themselves cause pain and trauma and may deter patients from requesting pain medication. Rectal and sublingual administration are alternatives to intramuscular or subcutaneous routes when intravenous access is problematic. All routes other than intravenous require a lag time for absorption into the circulation. • Oral administration is convenient and inexpensive. It is appropriate as soon as the patient can tolerate oral intake and is the mainstay of pain management in the ambulatory surgical population. Nonpharmacologic Management • Patient teaching should include procedural and sensory information, instruction to decrease treatment and activity-related pain (e.g., pain caused by deep breathing, coughing) and information about the use of relaxation. • Cognitive-behavioral (e.g., relaxation, distraction, imagery) and physical interventions (e.g., heat, cold, massage) are intended to supplement, not replace, pharmacologic interventions. • Cognitive/behavioral interventions include a variety of methods that help patients understand more about their pain and take an active role in pain assessment and management. • Simple relaxation strategies can be effective in helping to manage pain. Basic approaches (see Table 2 for an example) require only a few minutes to teach and can reduce pain and anxiety. Patients benefit from periodic reinforcement and coaching in the use of relaxation techniques. • Commonly used physical agents include applications of heat and cold, massage, movement, and rest or immobilization. Applications of heat and cold alter the pain threshold, reduce muscle spasm, and decrease local swelling. • Transcutaneous electrical nerve stimulation (TENS) may be effective in reducing pain and improving physical function.
AHLA Seminar Materials Special Considerations for Elderly Persons The Clinical Practice Guideline contains a more complete discussion of the special considerations for pain management in the elderly. A summary is provided here. • Elderly people often suffer multiple chronic, painful illnesses and take multiple medications. They are at greater risk for drug-drug and drug-disease interactions. • Pain assessment presents unique problems in the elderly, as these patients may exhibit physiologic, psychologic, and cultural changes associated with aging. • Misunderstanding of the relationship between aging and pain is common in the management of elderly patients. Many health care providers and patients alike mistakenly consider pain to be a normal part of aging. Elderly patients sometimes believe that pain cannot be relieved and are stoic in reporting their pain. The frail and oldest-old (>85 years) are at particular risk for undertreatment of pain. • Aging need not alter pain thresholds or tolerance. The similarities of pain experience between elderly and younger patients are far more common than are the differences. • Cognitive impairment, delirium, and dementia are serious barriers to assessing pain in the elderly. Sensory problems such as visual and hearing changes may also interfere with the use of some pain assessment scales. However, as with other patients, the clinician should be able to obtain an accurate self-report of pain from most patients. • When verbal report is not possible, clinicians should observe for behavioral cues to pain such as restlessness or agitation. The absence of pain behaviors does not negate the presence of pain. • NSAIDs can be used safely in elderly persons, but their use requires vigilance for side effects, especially gastric and renal toxicity. • Opioids are safe and effective when used appropriately in elderly patients. Elderly people are more sensitive to analgesic effects of opiate drugs. They experience higher peak effect and longer duration of pain relief. Institutional Responsibility for Pain Management The institutional process of acute pain management begins with the affirmation that patients should have access to the best level of pain relief that may safely be provided. (See Table 3 for a summary of the scientific evidence for interventions to manage pain in adults.) Each institution should develop the resources necessary to provide the best and most modern pain relief appropriate to its patients and should designate who and/or which departments are responsible for the required activities. Optimal application of pain control methods depends on cooperation among different members of the health care team throughout the patient's course of treatment. To ensure that this process occurs effectively, formal means must be developed and used within each institution to assess pain management practices and to obtain patient feedback to gauge the adequacy of pain control. The institution's quality assurance procedures should be used periodically to
AHLA Seminar Materials assure that the following pain management practices are being carried out: • Patients are informed that effective pain relief is an important part of their treatment, that communication of unrelieved pain is essential, and that health professionals will respond quickly to their reports of pain. They are also told that a total absence of pain is often not a realistic or even a desirable goal. • Clear documentation of pain assessment and management is provided. • There are institution-defined levels for pain intensity and relief that elicit review of current pain therapy, documentation of the proposed modifications in treatment, and subsequent review of their efficacy. • Each clinical unit periodically assesses a randomly selected sample of patients who have had surgery within 72 hours to determine their current pain intensity, the worst pain intensity in the first 24 hours, the degree of relief obtained from pain management interventions, satisfaction with relief, and satisfaction with the staff's responsiveness. Table 2. Sample Relaxation Exercise Slow Rhythmic Breathing for Relaxation 1. Breathe in slowly and deeply. 2. As you breathe out slowly, feel yourself beginning to relax; feel the tension leaving your body. 3. Now breathe in and out slowly and regularly, at whatever rate is comfortable for you. You may wish to try abdominal breathing. If you do not know how to do abdominal breathing, ask your nurse for help. 4. To help you focus on your breathing and breathe slowly and rhythmically: Breathe out as you say silently to yourself, “out, two, three.” Breathe out as you day silently to yourself, “out, two, three.” Each time you breathe out, say silently to yourself a word such as peace or relax. 5. You may imagine that you are doing this in a place you have found very calming and relaxing, such as lying in the sun at the beach. 6. Do steps I through 4 only once or repeated steps 3 and 4 for up to 20 minutes. 7. End with a slow deep breath. As you breathe out say to yourself “I feel alert and relaxed.” Additional points: If you intend to do this for more than a few seconds, try to get in a comfortable position in a quiet environment. You may close your eyes or focus on an object. This technique has the advantage of being very adaptable in that it may be used for only a few seconds or for up to 20 minutes. Adapted with permission from : McCaffery M. and Beebe A. Pain: Clinical manual for nursing practice . St. Louis: C.V. Mosby. Table 3. Scientific Evidence forInterventions to Manage Pain in Adults Pharmacologic Interventions
AHLA Seminar Materials Intervention [1] Type of Evidence Comments NSAIDs Oral (alone) Ib, IV Effective for mild to mode Begin preoperatively. Rela contraindicated in patients disease and risk of or actu coagulopathy. May mask Oral (adjunct to opioid) la, IV Potentiating effect resultin sparing. Begin preop. Cau above. Parenteral (ketorolac) Ib, IV Effective for moderate to s Expensive. Useful where contraindicated, especiall respiratory depression an Advance to opioid. Opioids Oral IV As effective as parenteral doses. Use as soon as or tolerated. Route of choice Intramuscular Ib, IV Has been the standard pa but injections painful and unreliable. Hence, avoid t possible. Subcutaneous Ib, IV Preferable to intramuscula volume continuous infusio painful and absorption un this route for long-term re Intravenous Ib, IV Parenteral route of choice surgery. Suitable for titrate continuous administration PCA), but requires monito Significant risk of respirato with inappropriate dosing. PCA (systemic) Ia, IV Intravenous or subeutane recommended. Good, ste analgesia. Popular with pa requires special infusion p staff education. See cauti opioids above. Epidural and intrathecal Ia, IV When suitable, provides g analgesia. Significant risk depression, sometimes de onset. Requires careful m of infusion pumps require equipment and staff educ Local Anesthetics Epidural and intrathecal Ia, IV Limited indications. Expen pumps employed. Effectiv analgesia. Opioid sparing opioid to local anesthetic analgesia. Risks of hypote weakness, numbness. Us pump requires additional staff. Peripheral nerve block Ia, IV Limited indications and du action. Effective regional a Opioid sparing. Nonpharmacologi Interventions Intervention [1] Type of Evidence Comments Simple Relaxation (begin Jaw relaxation Progressive muscle Ia, IIa, IIb, IV Effective in reducing mild preoperatively) relaxation Simple imagery pain and as an adjunct to drugs for severe pain. Use patients express an intere relaxation. Requires 3–5 m time for instructions. Music Ib, IIa, IV Both patient-preferred and listening” music are effect mild to moderate pain. Complex Relaxation (begin Brofeedback Ib, IIa, IV Effective in reducing mild
AHLA Seminar Materials preoperatively) pain and operative site mu Requires skilled personne equipment. Imagery Ib, IIa, IIb, IV Effective for reduction of m moderate pain. Requires personnel. Education/Instruction (begin Ia, IIa, IIb, IV Effective for reduction of p preoperatively) include sensory and proce information and instruction reducing activity related p 5–15 minutes of staff time TENS Ia, IIa, III, IV Effective in reducing pain physical function. Require personnel and special equ be useful as an adjunct to Type of Evidence - Key Ia Evidence obtained from meta-analysis of randomized controlled trials. Ib Evidence obtained from at least one randomized controlled trial. IIa Evidence obtained from at least well-designed controlled study without randomization. IIb Evidenced obtained from at least one other type of well-designed quasi- experimental study. III Evidence obtained from well-designed nonexperimental descriptive studies, such as comparative studies, correlational studies, and case studies. IV Evidence obtained from expert committee reports or opinions and/or clinical experiences of respected authorities. Note: References are available in the Guideline Report. Acute Pain Management: Operative or Medical Procedures and Trauma . AHCPR Pub. No. 92-0001. Rockville, MD: Agency for Health Care Policy and Research, Public Health Service, U.S. Department of Health and Human Services. In press. Table 4. Dosing Data for NSAIDs Drug Oral NSAIDs Usual adult dose Usual pediatric dose [1] Comments Oral NSAIDs Acetaminophen 650–975 mg q r hr 10–15 mg/kg q 4 hr Acetaminophen lacks the anti-inflammatory activity NSAIDs Aspirin 650–975 mg q 4 hr 10–15 mg/kg q 4 hr[2] The standard against whic NSAIDs are compared. In aggregation; may cause p bleeding Choline magnesium trisalicylate 1000–1500 mg bid 25 mg/kg bid May have minimal antipla (Trilisate) also available as oral liqui Diflunisal (Dolobid) 1000 mg initial dose followed by 500 gm q 12 hr Etodolac (Lodine) 200–400 mg q 6–8 hr Fenoprofen calcium (Nalfon) 200 mg q 4–6 hr Ibuprofen (Motrin, others) 400 mg q 4–6 hr 10 mg/kg q 6-2-8 hr Available as several brand as generic; also available suspension Ketoprofen (Orudis) 25–75 mg q 6–8 hr Magnesium salicylate 650 mg q 4 hr Many brands and generic available Meclofenamate sodium (Meclomen) 50 mg q 4–6 hr Mefenamic acid (Ponstel) 250 mg q 6 hr Naproxen (Naprosyn) 500 mg initial dose followed by 250 mg 5 mg/kg q 12 hr Also available as oral liqu q 6–8 hr
AHLA Seminar Materials Naproxen sodium (Anaprox) 550 mg initial dose followed by 275 mg q 6–8 hr Salsalate (Disalcid, others) 500 mg q 4 hr May have minimal antipla Sodium salicylate 325–650 mg q 3–4 hr Available in generic form f distributors Parenteral NSAID Ketorolac tromethamine (Toradol) 30 or 60 mg IM initial dose followed by Intramuscular dose not to 15 or 30 mg q 6 hr Oral dose following days IM dosage: 10 mg q 6–8 hr Note: Only the above NSAIDs have FDA approval for use as simple analgesic, but clinical experience has been gained with other drugs as well. Table 5. Dosing Data for Opioid Analgesics Drug Approximate equianalgesic oral Approximate equianalgesic Recommended starting dose parenteral dose more than 50 kg body w Apioid Agonist Morphine[2] 30 mg q 3–4 hr (around-the-clock 10 mg q 3–4 hr 30 mg q 3–4 hr dosing) 60 mg q 3–4 hr (single dose or intermittent dosing) Codeine[3] 130 mg q 3–4 hr 75 mg q 3–4 hr 60 mg q 3–4 hr Hydromophone[2] 7.5 mg q 3–4 hr 1.5 mg q 3–4 hr 6 mg q 3–4 hr Hydrocodone (in Lorcet, Lortab, Vicodin, 30 mg q 3–4 hr Not available 10 mg 1 3–4 hr others) Levorphanol (Levo-Dromoran) 4 mg q 6–8 hr 2 mg q 6–8 hr 4 mg q 6–8 hr Meperidine (Demerol) 300 mg q 2–3 hr 100 mg q 3 hr Not recommended Methadone (Dolophine, others) 20 mg q 6–8 hr 10 mg q 6–8 hr 20 mg q 6–8 hr Oxycodone (Roxicodone, also in 30 mg q 3–4 hr Not available 10 mg q 3–4 hr Percocet, Percodan, Tylox, others) Oxymorphone[2] (Numorphan) Not available 1 mg q 3–4 hr Not available Opioid Agonist-Antagonist and Partial Agonist Buprenorphine (Buprenex) Not available 0.3–0.4 mg q 6–8 hr Not available Butorphanol (Stadol) Not available 2 mg q 3–4 hr Not available Nalbuphine (Nubain) Not available 10 mg q 3–4 hr Not available Pentazocine (Talwin, others) 150 mg q 3–4 hr 60 mg q 3–4 hr 50 mg q 4–6 hr Note: Published tables vary in the suggested doses that are equianalgesic to morphine. Clinical response is the criterionthat must be applied for each patient; tiltration to clinical response is necessary. Because there is not complete cross tolerance among these drugs, it is usually necessary to use a lower than equianalgesic dose when changing drugs and to retitrate to response. Caution: recommended doses do not apply to patients with renal or hepatic insufficiency or other conditions affecting drug metabolism and kinetics. Acute Pain Management in Adults: Operative Procedures-Selected Bibliography American Nurses Association. (1991). Position statement on the registered nurses' (RN) role in the management of patients receiving I.V. conscious sedation for shorterm therapeutic, diagnostic, or surgical procedures . Kansas City: American Nurses Association. American Pain Society, Committee on Quality Assurance Standards. (1990). Standards for monitoring quality of analgesic treatment of acute pain and cancer pain. Oncology Nursing Forum , 17, 952–954. Armstrong, P.J. & Bersten, A. (1986). Normeperidine toxicity. Anesthesia and Analgesia , 65, 536–538. Flaherty, G.G. & Fitzpatrick, J.J. (1978). Relaxation technique to increase
AHLA Seminar Materials comfort level of postoperative patients: A preliminary study Nursing Research , 27, 352–355. Hodsmann, N.B., Burns, J., Blyth, A., Kenny, G.N., McArdle, C.S., & Rotman, H. (1987). The morphine sparing effects of diclofenac sodium following abdominal surgery. Anaesthesia , 42, 1005–1008. International Association for the Study of Pain. (In press). Report of the task force on acute pain management . Kaiko, R.F., Wallenstein, S.L., Rogers, A.G., Grabinski, P.Y., & Houde, R.W. (1982). Narcotics in the elderly. Medical Clinics of North American , 66, 1079–1089. Kehlet, H. (1989). Postoperative pain. In Committee on Pre- and Postoperative Care. American College of Surgeons, Care of the surgical patient (vol. 1. pp. 3–12). New York: Scientific American Medicine. McQuay, H. (1989). Opioids in chronic pain. British Journal of Anaesthesia , 63, 213–226 National Institutes of Health. (1987). The integrated approach to the management of pain Journal of Pain and Symptom Management , 2, 35–44. Porter, J., & Jick, H. (1980). Addiction rare in patients treated with narcotics [letter]. New England Journal of Medicine , 302, 123. Ready, L.B., Oden, R., Chadwick, H.S., Bendetti, C., Rooke, G.A., Caplan, R., & Wild, L.M. (1988). Development of an anesthesiology-based postoperative pain service. Anesthesiology , 68, 100–106. Schmitt, F. & Wooldridge, P.J. (1973). Psychological preparation of surgical patients. Nursing Research , 22, 108–116. Wood. M.M. & Cousins, M.J. (1989). Iatrogenic neurotoxicity in cancer patients. Pain , 39, 1–3. Clinical Practice Guidelines and the Law: Applications and Implications Alice G. Gosfield In the overall health care reform debate, the clinical content of health care services is under scrutiny with unprecedented intensity. Some of the impetus for major reform in both financing and delivery has emanated from widespread uncertainty regarding what society's health care dollars currently buy--the “value” of health care. To make any type of judgment regarding the “value” of services purchased, some notion of what is necessary and appropriate to treat medical conditions (or to prevent them) is required. Increasingly, the goal is to define clinical content in terms founded upon a scientific basis rather than more arbitrary administrative judgments which have historically been used for these critical decisions. At the same time, the issue of costs are inextricably entwined in the debate over “value.” In a changing system which relies upon professional expertise to deliver care, but which continuously makes judgments external to the practitioner-patient relationship regarding what to buy (benefit packages), what to deliver (utilization management), and what to reimburse (medical necessity determinations), the tensions are not inconsiderable. A growing body of policy and law is grappling with the countervailing pressures in a new way. More and more, the law is incorporating into its controls, whether regulatory or
AHLA Seminar Materials contractual, methodologies intended to rest upon scientific evidence as the foundation for all of the myriad decisions which drive the ultimate determination of value. Variously referred to as “clinical practice guidelines,” “protocols,” “practice parameters,” “care maps,” “practice policies” and “critical pathways,”[1] they are all efforts to provide some objective statement of a common, more scientific view of the essential clinical choices which must be made in providing and buying health care services. More and more often, these guidelines are premised upon a nationally applicable approach to care. As is discussed here, guidelines have enormous legal implications--and not just for malpractice liability. Concurrent with this increased emphasis on the scientific validity and appropriateness of care choices and their impact on costs, additional factors have taken on new importance in the social dialogue. With the introduction of manufacturing principles of total quality management and continuous quality improvement into health care delivery,[2] not only has the view of the customer changed, but so has the view of the product. Waste and overutilization have long been discussed in any consideration of health policy and financing. Today, with the expansion of managed care initiatives of various types in both the public and private sectors, concern for underutilization (failing to deliver appropriate or enough services) is receiving attention in addition to overutilization (which is discussed today primarily in the context of fee-for-service medicine).[3] In the techniques of evaluation of both administrative and overall program costs as a component of service value, there has also been a shift away from the traditional emphasis on case-by-case, individualized judgments of appropriateness to consideration of effectiveness of services measured across populations--outcomes.[4] No longer is the debate simply over controlled costs. Today the definition of “value” that is emerging is controlled costs, using high quality processes, with good patient outcomes, as demonstrated in data. The measure of “value” in health care is dynamic, and is being defined by many players and forces--private group purchasers of health care services and benefits, financing systems seeking to succeed strategically, the government, and even individual consumers. Although the focus of value for individuals has often been on fees and charges,[5] there is a growing concern for patient satisfaction and patient preference for individuals as well as across groups.[6] All of these factors are at issue in the controversies, hopes and expectations for the applications of guidelines as a tool to mediate a wide variety of tensions in the health care system. No longer futuristic, clinical practice guidelines are well insinuated in the here and now of policy debate. Some estimate that thirty different commissions are now involved in developing guidelines, and that at least eighty different professional societies are working on more than 1,400 sets of guidelines.[7] But to the dismay of those who are wary of their effects, policy debate is not the end of the guideline story. Newsletters proliferate solely to report on real world applications of these tools, by hospitals, payors, managed care organizations and others.[8] Many of the health reform proposals currently under consideration include some aspects of this expanding movement, and, as discussed here, the federal government is firmly in the business of stimulating this new mini-industry aimed at creating,
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