Distinct and Separate Legal Stuctures for Clinical Programs of Schools and Colleges of Optometry

April 1st, 2008

Please read this article in .pdf format as it contains graphs and charts best seen at higher resolutions. Click here for the full article.

Background
In a decisive effort to move into the mainstream of health care and to address concerns about the legal exposure of an educational institution providing services to Medicare and Medicaid beneficiaries, The New England College of Optometry (NECO) in 2002 spun off its clinical system and its assets into a separate subsidiary corporation, the New England Eye Institute (NEEI). This was the first time a private college of optometry was to form an optometric analog to the medical school/teaching hospital structure. The new clinical corporation has its own Articles of Incorporation, By-laws, Board of Directors and administration similar to those of a teaching hospital. NEEI’s governance documents reflect considerable oversight by NECO. A detailed position description for the CEO was written which incorporated the elements of the incorporation documents. NEEI has made significant progress in realizing the potential of this new structure and has demonstrated that the oversight mechanisms in place have been effective. This summary outlines the advantages of a separate clinical corporation, supports the advantages with available data, restates the College’s oversight processes to assure added value and mission alignment, and notes concerns and misunderstandings that need further discussion…

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Issues Facing the Profession of Optometry Related to Clinical Education

November 25th, 2007
  • There is need to “forecast” the future of the profession given the dynamics in the eye care marketplace, rapidly changing demographics of the profession, high graduate debt and continued expansion of the scope of practice so that the schools and colleges can adjust their curricula accordingly to adequately prepare the graduate to succeed in this changing environment.
  • Uncertainty concerning eye care manpower needs in the United States.
  • Need to clarify the future direction of optometric residencies including specialization and advanced competency certification.
  • Expansion of college-affiliated clinics into urban and suburban areas will lead initially to increased tensions between academia and private practitioners. However, cooperative approaches will evolve.

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Emerging Trends in Optometric Clinical Education and Applied Research

November 25th, 2007
  • There will be a decrease in dependency upon large campus-based facilities for the clinical training of optometric students. Driven by economic considerations and the need for greater diversity of clinical experiences, community-based training sites will replace the need for large single-purpose and costly campus-based clinics.
  • It will be imperative that the private optometric colleges reduce the cost of campus-based clinical education in order to keep student tuition competitive.
  • Cost-effective technology assisted patient simulation laboratories and other innovative means will provide early clinical training for beginning optometric students rather than the large campus clinics.
  • Smaller academic eye centers of excellence staffed by college faculty will be positioned proximal to the college of optometry. These centers will operate incentive based faculty compensation plans that integrate student and resident training.
  • Interdisciplinary clinical education will emerge as the new standard.
  • The Department of Veterans Affairs, the Armed Forces and the U.S. Public Health Service will continue as a major resource for clinical training of students and residents. Federally-sponsored fellowship programs will be expanded.
  • Private practice externships and other extern sites will continue as a component of clinical training for students and residents. However, site selection and evaluation criteria will become more stringent.
  • Private practice externships will emerge as the vital resource to provide students with practice management experience.
  • There will be an increased emphasis on clinical education in low vision, pediatrics and traumatic brain injury and associated vision problems.
  • A national clearinghouse and placement service for externships in optometry will be established. Through the clearinghouse, all institutions of optometric education will fully share in the enormous national resource and each site will be appropriately and fully utilized. National standards for externships will be more stringently applied and will lead to accreditation for participating sites.
  • Clinical faculty will increasingly take advantage of the large and diverse clinic population to expand clinical research in contact lenses, ophthalmic pharmaceuticals, traumatic brain injury, strabismus and refractive error.
  • Schools and colleges will formally recognize community-engaged scholarship and it will apply to the review, promotion and tenure processes for community-engaged faculty members.
    Medicare regulation pertaining to student participation in billable services will require a change in the curriculum model and nomenclature. Current student fourth professional year will be changed to first residency year. More information can be found in: Development of a New Clinical Training Model.

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Emerging Trends in Optometric Patient Care

November 25th, 2007
  • Incentive-based compensation plans that integrate student and resident training will become an essential component of optometric education and provide the means to enhance faculty income and improve the ability to recruit and retain highly qualified clinicians.
  • Patient-centered and efficient health care will replace the current educational or training environment in college-operated clinics.
  • Telemedicine technologies, such as imaging and interactive care management systems, transmitted from practitioner to centers of excellence for immediate consultation on cases will become the standard of care in rural areas and certain urban areas where access to specialists is limited.
  • In an environment made possible by advances in technology and made necessary by economic imperatives to be as efficient as possible, there will be unprecedented pressures for academic optometry and ophthalmology to work together in a cooperative spirit. For more information see the articles posted in the Academic Affiliations section.
  • Interdisciplinary care will become the standard as optometrists manage more complex clinical conditions requiring consultation and the close coordination of care with other disciplines.
  • Electronic medical records will become the standard of care.
  • New technologies and the need for optometrists to be more efficient in a competitive health care market will lead an increased demand for more optometric technicians.

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Emerging Trends in Health Care Policy Pertaining to Optometric Clinical Education and Patient Care

November 25th, 2007
  • There will be a convergence of clinical services provided and community health care needs as expressed in the National Institutes of Health (NIH) Vision Objectives.
  • Growth in the volume of care provided to Medicare beneficiaries will increase significantly.
  • Optometry will eventually become a full participant in the federal programs Graduate Medical Education (GME) and the National Health Service Corps (NHSC) and other federal programs for patient services providers. Participation in these programs will likely require a separate clinical legal entity and collaboration with community-based health care programs and/or hospitals.
  • (GME) will provide significant funding to the clinical entity for the training of optometry students.
  • (NHSC) will provide loan repayment for optometry students assigned to Federally Qualified Community Health Centers (FQCHC) possibly beginning in their 4th year. Residents assigned to FQCHCs and optometrists who are employed by FQCHCs will also be eligible for educational loan repayment. The NHSC program will also fund resident stipends for community-based programs.
  • Schools and colleges of optometry will become proactive in influencing national and state health care policy.
  • There will be an increase in the number of optometrists pursuing careers in public health.
  • There will be an increase in the number of optometrists in federal policy making positions.
  • The National Rural Health Alliance (NRHA) and the National Association of Community Health Centers (NACHC) will support optometry’s legislative and regulatory initiatives.
    The Department of Veterans Affairs (VA) will contract with FQCHC’s to provide care to Veterans.
  • The Department of Defense (DOD) and the VA will significantly enhance capabilities in treating vision problems associated with Traumatic Brain Injury (TBI).

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Emerging Trends in Optometric Clinical Programs Administration

November 25th, 2007
  • Quality assurance, risk management, compliance and accreditation of clinical facilities will become increasingly important.
  • There will be more proactive risk management and patient safety initiatives.
  • Quality of care assessment and peer review using published clinical practice guidelines as the benchmark will become the standard of assessment.
  • There will be more collaboration with community health care programs and an increased awareness of public health needs.
  • College affiliated clinical organizations will realize performance improvements in partnering with health center administrations in addressing common clinical practice and administrative issues by sharing of evidence-based best practices and then adapting them to their local environments.
  • Patient services revenue management from patient registration to coding and documentation to submission of charges to net collections will become increasingly important.
  • Comprehensive marketing programs consisting of public relations, advertising and direct sales will be essential to succeed in a competitive health care market.
  • Incentive-based compensation will become commonplace for attending staff and clinical administrators.
  • Accreditation groups and funding sources will set standards relating to academically affiliated clinical programs addressing public health needs.

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Emerging Trends in Optometric Clinical Programs Governance

November 25th, 2007
  • Optometry colleges’ clinical programs will be reorganized into separate legal entities with their own governing boards and administrations. Creating a legal entity will provide for separation of risk - giving a degree of protection for College assets from risks associated with the provision of health care. For further information please read: Distinct and Separate Legal Structures for Clinical Programs of Schools and Colleges of Optometry
  • Schools and colleges will establish accounting models that differentiate clinical program capital and operating costs from the costs associated with clinical education.
  • Negotiated educational services payments will be made to the separately-organized clinical programs for educational services. The clinical entity will make administrative services payments to the school or college for any shared services.
  • The ability for soliciting funds will be improved as foundations, patients, alumni and others who do not support educational institutions will find patient care a worthy cause to support. Free care pools provided through various organizations will become available to the clinical organization.
  • Separation of the college and clinical programs Boards of Trustees/Directors and Administrations will facilitate the appointment of individuals with different skill sets appropriate to the mission, values and priorities of the respective organizations. Separation of the Boards and Administrations will encourage more focused attention to the priorities of the respective entities which are often different.

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Testimony in Support of Senate Bill 1255, An Act Relative to the Modernization of Optometry

May 2nd, 2007

I am Charles Mullen. I am a graduate of the University of Virginia and received my Doctor of Optometry degree from the New England College of Optometry. I have over 36 years of experience in optometric education at three institutions. I am the former President of the Illinois College of Optometry and former Director of the Department of Veterans Affairs Optometry Service, the largest optometric patient care and clinical training program in the Nation. Currently I serve on the Board of Trustees of the Pennsylvania College of Optometry and the Board of Directors of the New England Eye Institute. I am also an Adjunct Clinical Professor at the State University of New York.

My remarks today pertain to the impact that the current restriction on Massachusetts optometrists treating glaucoma has on the clinical education of students enrolled at the New England College of Optometry. From a national perspective, this restriction places the College and its faculty at a competitive disadvantage for the best and brightest applicants for admission. Upon learning of the restriction in the treatment of glaucoma, many highly qualified applicants and, for that matter, many highly qualified optometrists seeking a faculty appointment at the New England College of Optometry choose other Colleges of Optometry – simply because Massachusetts cannot offer the comprehensive opportunities they are seeking. No other optometry school across the country faces this problem.

Forty-nine states permit optometrists to treat glaucoma. It is now the national expectation; if not the standard. Students of the New England College of Optometry are expected upon graduation to be fully prepared to treat eye disease; including, the management of patients with glaucoma. Yet, without the ability to practice in Massachusetts, the New England College of optometry must seek training venues outside the Commonwealth or in federal facilities where the treatment of glaucoma is permitted. This is ironic given that Massachusetts is known to be a world leader in health care education. Forty-nine states and the federal system allow for optometrists to treat glaucoma, but the home state of one of the best optometry schools does not. Again, no other optometry school in the Nation is so limited.

Nationwide, optometrists provided $846 million in eye care services to Medicare beneficiaries in 2006. As the incidence of glaucoma increases with age and with the onset of the “baby boomer” retirement, graduates of the New England College must be fully prepared to meet the health care needs of the rapidly growing elderly population. This means they must be able to treat glaucoma.

I can assure you that optometric education and the profession of optometry are constantly evolving. Advances in the biomedical and visual sciences impact both the methods of treating patients and the methods of educating students. Given this quickly changing environment, it is essential that optometrists in Massachusetts be granted the authority to treat glaucoma – allowing both the New England College of Optometry and its students to remain competitive on a national level.

Thank you for the opportunity to testify before the Joint committee on Public Health. Accordingly, I respectfully request that this Committee release SB 1255 with a favorable report.

Testimony of Charles F. Mullen, O.D.
Delivered May 2, 2007

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