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Charles F. Mullen

Challenges and Opportunities in Optometry and Optometric Education

Restructuring the Profession of Optometry – The Next Bold Move

We must not let anyone else write our future.

– Dr. Ronald Hopping, President AOA

Restructuring the Profession of Optometry (PDF)

Restructuring the Profession of Optometry (PPT)

Charles F. Mullen
Roger Wilson
Janice E. Scharre
David S. Danielson

August 16, 2013 by Charles F. Mullen

Affordable Care Act: Opportunity for New Optometry Student Clinical Training Model

I am writing this paper to urge schools and colleges of optometry to change from Student-Driven Clinical Training to a Teaching Physician-Centered Model to facilitate compliance with the Center for Medicare/Medicaid Services (CMS) Guidelines for Teaching Physicians, Interns and Residents as the Guidelines pertain to Students. With the implementation of the Affordable Care Act (ACA), it is an opportune time for optometry schools and colleges to change to a Teaching Physician-Centered Model and reinforce their CMS compliance policy and Electronic Health Records (EHR) procedures for students. I realize such a dramatic change in optometric clinical training would have significant budgetary implications as teaching physician/faculty expense would increase and patient services revenues would likely decline. However, the current Student-Driven Training Model continues to pose a high risk of CMS violations with associated fines and other sanctions. It is anticipated that audits of Federal Health Care Programs will increase with the implementation of the Affordable Care Act (ACA).

The paper does not discuss the educational benefits of the Teaching Physician-Centered Model. However, the model has been successfully utilized in medical student education for many years.

Background

Because the Department of Health and Human Services (HHS) does not consider optometry residents to be “real” residents, I do not address optometry residents’ compliance in this paper since CMS Teaching Guidelines do not technically apply. An optometry resident once licensed is no different than any licensed optometrist. Also, optometry residency programs do not qualify for the Graduate Medical Education (GME) program. Nor does optometry have a trainee classification that qualifies as intern. A teaching physician is defined as optometric school/college faculty, affiliate attending staff, or extern preceptor.

The CMS Teaching Guidelines apply to Medicare, other Federal Health Care Programs, Medicaid in most states, and most major private insurers.

Page 3 of the Teaching Guidelines state:

Evaluation and Management-Documentation Provided by Students—Any contribution of a student to the performance of a billable service must be performed in the physical presence of a teaching physician or resident… the student may document in the medical record. However, the teaching physician may only refer to Review of Systems (ROS) and Past Family/Social History (PFSH)….the teaching physician may not refer to the students findings and must verify and re-document the history of present illness and perform (repeat) and re-document the examination and medical decision making (treatment plan).

Page 7 – Medicare does not pay for any services furnished by students.

I base my recommendation to change the teaching model on research and writing on the subject, consultation with American Optometric Association (AOA) Medicare experts, consultation with teaching physicians, interviews with medical students and residents and ongoing discussions with (AOA) Federal Relations staff and optometric academic administrators and faculty along with viewing the Office of the Inspector General (OIG) False and Fraudulent Claims Report, where CMS Teaching Guidelines violations are reported. I also have extensive experience in optometric clinical education and with Federal Health Care policy. See: Dr. Charles Mullen CV.

Compliance with CMS Teaching Guidelines and EHR Procedures

Failure to fully comply with the Teaching Guidelines and EHR procedures creates self-induced risk which could result in institutional fines, legal fees and other severe penalties. There is also the potential of individual liability and damage to the reputations of faculty members, affiliate attending staff or extern preceptors since Medicare/Medicaid Fraud and Abuse sanctions are reported to the National Practitioners Data Bank. Should an extern preceptor be sanctioned for Medicare fraud or abuse the damage to optometry school/college alumni relations would be extensive. HHS has intensified its efforts to identify and prosecute Medicare fraud by increasing the reward pool for “whistle blowers” to $10 million.

Student Notations Risks with Electronic Health Record (EHR)

If student notations are placed in the patient’s record (either written or EHR), they must be clearly delineated and not used to bill for services. Intentionally and knowingly using student examination findings to bill Medicare is considered a fraudulent claim. The Association of Academic Medical Centers (AAMC) issued a Compliance Advisory regarding students and Electronic Medical Records (EMR). The Compliance Advisory cautioned teaching physicians about the risks of student notations in the electronic medical record and delineated procedures to avoid Medicare violations and sanctions.

Self Disclosure

Optometry schools and colleges that suspect Medicare violations in their clinical operations may want to consider Self Disclosure rather than exposing the institution to an uninvited Medicare audit which could result in catastrophic fines, legal fees and severe sanctions. The OIG Self Disclosure program may permit the institution to negotiate any fines and potentially prevent higher fines and more severe penalties such as exclusion from all Federal Health Care Programs. Medicare Fraud and Abuse fines are up to $10,000 to $50,000 plus three times the damages for each violation. The Self Disclosure protocol requires the institution to furnish extensive information on the Medicare/Medicaid violations including how the school/college plans to prevent future violations. Suggested measures to prevent CMS violations are delineated in the next section of the paper.

Teaching Physician-Centered Model

The current optometric Student-Driven Clinical Training Model is not compatible with CMS Teaching Guidelines, while the Teaching Physician-Centered Model is consistent with all of the following CMS compliance expectations:

  1. that the teaching physician is in charge of the patient
  2. that patient care is personally rendered or repeated by the teaching physician and
  3. that the examination is personally documented in the medical record by the teaching physician including history of present illness, diagnosis and management/treatment plan.

This model is successfully utilized in medical student clerkships.

Optometry programs must clearly demonstrate how students are incorporated in the care of the patient to learn and practice clinical procedures and not to provide patient services. Also, programs must demonstrate how students participate when the care of the patient is actively and personally provided by the teaching physician. Schools and colleges should view student clinical placements as clerkships where the student can practice history taking and examination procedures along with assisting the supervising physician, but not provide patient services except ROS and PFSH.

Optometry schools and colleges must ensure:

  1. a CMS compliance policy is in place, including a EHR policy regarding student notations
  2. that the compliance policy is monitored and enforced by annual internal compliance audits
  3. that all clinical affiliates and extern preceptors receive copies of the institution’s compliance policy along with CMS and OIG supporting documents
  4. that regular briefings on compliance by senior school/college officials are presented to all external training venues
  5. that all college faculty and optometry students receive compliance training prior to participating in patient care
  6. that the school/college or teaching clinic has a Compliance Officer
  7. that lines of communications are open

The Veterans Health Administration (VHA) Eye Care Handbook also mandates compliance with CMS Teaching Guidelines in all optometric teaching programs. Annually, 1400 optometry student clinical rotations are available at VA facilities along with 186 residents and 3 research fellows. Although optometry residents are not considered residents by HHS, the VA requires compliance with CMS Teaching Guidelines for both optometry residents and students.

Although implementation of the Teaching Physician-Centered training model would be a major step forward in addressing optometry student compliance with CMS Teaching Guidelines, serious consideration should be given to the overall restructuring of optometric education by placing optometry in parallel with medicine for both student and postgraduate clinical training. Restructuring the curriculum would present the opportunity for inclusion in GME and further enhance CMS compliance. See: Restructuring the Profession of Optometry – The Next Bold Move.

Reference Documents

  1. CMS Guidelines for Teaching Physicians, Interns and Residents (Students)
  2. OIG False and Fraudulent Claims Report
  3. OIG Self Reporting Protocol
  4. Medicare Fraud and Abuse Summary
  5. Veterans Health Administration (VHA) Eye Care Handbook
  6. Restructuring the Profession of Optometry – The Next Bold Move

July 14, 2013 by Charles F. Mullen

Unresolved Matters of Importance to Optometric Education

Authors Charles F. Mullen and Lesley L. Walls

Q: What do you, as former president of a private college of optometry, consider the most important issues facing the profession of optometry?

The absence of a current optometric manpower study and a comprehensive assessment of the state of optometric education.

The last optometric manpower study was completed in 1999 by Abt Associates, Cambridge, Massachusetts. The last study of optometric education was in 1993 at the Georgetown Summit. A current optometric manpower study and a comprehensive assessment of the state of optometric education are needed given the expanded scope of optometric practice, proliferation of new schools of optometry, national health care reform, the aging population and uncertain optometric manpower needs.

The high cost of optometric education.

Private optometry colleges’ endowments and sources of revenue other than tuition are not sufficient to support college and clinic operations and increased costs are often passed on to the student in the form of higher tuition, resulting in higher educational debt. This may also apply to public institutions although my experience is largely in private colleges. Currently, the cost of an optometric education is a sound investment, however continuing increases in educational costs measured against the income potential of optometrists will likely diminish the attractiveness of an optometric career in the future. Graduate debt is excessive, over $200,000 at some optometric institutions.

Q: Why are optometric educational institutions so dependent on student tuition to support clinical training when medicine and podiatry receive substantial federal support?

At the Georgetown Conference (1992-1993), a meeting of all constituents of the optometric profession to discuss the optometric curriculum/clinical training programs, it was decided that optometric education would remain a four year curriculum with no requirement for post-graduate training for entry level into the profession. This conclusion meant that increases in the scope of practice for optometry and the resultant demands on the curriculum and clinical training requirements and related costs had to be contained in the four year educational program.

The four year optometry program is unlike medicine which requires post-graduate clinical training for licensure due to the expanded educational requirements for entry level medical practice. Graduates of medical and podiatry programs are not eligible for licensure until satisfactory completion of post-graduate clinical training. Because medicine and podiatry require post-graduate training, these two professions along with post-graduate dentistry are eligible for $9.5 billion annually in Graduate Medical Education (GME) Residency Program funds while optometry programs are not eligible.

Q: What are the contributing factors to the high cost of optometric education?

Clinical education is the most easily identified cause of increased operating costs and the most significant. There are numerous factors contributing to higher clinical training costs:

Unlike the successful medical patient care and clinical teaching approach, optometry’s clinical model is student centered rather than patient centered. A student centered model increases the patient examination cycle, decreases patient satisfaction and limits faculty practice growth.

Since the 1970’s with the introduction of pharmaceuticals and advanced clinic. procedures, optometry has been in a state of transformation. Optometric education has evolved in response to the expanded patient care management and treatment responsibilities of optometric practice, significantly increasing training requirements and related costs.

Clinical education is inherently inefficient when compared with the provision of care in non-teaching sites and patient services revenues are inadequate to cover the deficit of clinic operations. Unlike medicine, dentistry and podiatry, optometry is not eligible for federal funds (GME) to compensate for training inefficiencies and increased training requirements and costs.

When the amount of charity care provided by college optometry clinics and patient services payment sources are taken into consideration, state, foundation, corporate and alumni support are currently also inadequate to fund clinic operating deficits. (The cost of clinical education is not always considered in the clinic operations accounting model.)

Clinical faculty incentives and/or expectations to increase patient services revenues are usually not usually components of employment contracts and maximizing revenue is not considered a priority by faculty members nor rewarded by colleges. Providing efficient patient services is not emphasized. Faculty and staff training in patient services coding and billing procedures is inadequate.

Q: What are your suggestions to reduce the cost of clinical training?

Federal support for optometric clinical training would have a dramatic and lasting impact on the cost of optometric education. Efforts to include optometry in the Graduate Medical Program (GME) and other federal programs, such as the National Health Service Corps should be intensified. However, in order to qualify for the current GME Residency Program significant changes in the clinical education model would be necessary. Post graduate clinical training (residency), as a requirement for licensure, would need to be included in the optometric clinical education model. A Certification Board would be needed as well. Numerous issues involving state licensing boards, national examining boards, accreditation groups, etc would need to be addressed. The Social Security Act amended to include optometry in the Graduate Medical Education Program GME).

Radical new thinking about optometric patient care and clinical teaching is recommended. A major paradigm shift is required where clinical faculty/attending optometrists are in charge of the patient rather than faculty in charge of the care of the student.

Emphasis needs to be placed on patient care during clinical education sessions. Everything that occurs in the exam room should be to the benefit of the patient and patient satisfaction. Great clinical teaching can only occur in the context of great doctoring and role modeling of exceptional care. If this is the norm, then patient cycle time will be decreased and faculty will retool their thinking to be attending optometrists in charge of the patient rather than faculty in charge of the care of the student. This is the successful medical clinical training approach.

The expectations of these attending optometrists are different than academic optometrists. They are expected to drive the performance of the clinical program, both with volume and revenues and their performance evaluations should be strongly linked to their clinical and operational performance. This enables an institution to recruit and retain the best practitioners at market rate salaries with expectations that their income will be paid through their clinical performance resulting in increased revenues from clinical services.

All clinicians should be held accountable to compliance rules and regulations regarding documentation and clinical testing. Regular training sessions should be held pertaining to patient services coding and billing.

Large campus-based clinical facilities are costly and operating costs often passed on to the student in the form of higher tuition. Colleges should consider less expensive affiliations with proximal health care facilities such as community health centers, medical centers, federal facilities and externship placements for clinical training. New colleges of optometry should not build expensive campus based clinics, but rather establish networks of clinical training sites in existing health care facilities.

Q: Are there other causes for the high cost of optometric education?

Yes, there are issues involving the academic program and research. Academic leadership is often slow to react to advances in the clinical practice of optometry and reluctant to make significant changes in the curriculum including addressing course redundancies. Course material remains in the curriculum even though it could be made a pre-optometry requirement and not taught in the core optometric curriculum.

State of the art technology such as distance learning is available, however faculty are reluctant to embrace new teaching methods. More emphasis should be placed on self learning by the student.

The current tenure process at private colleges of optometry greatly restricts the institutions ability to react to changing economic conditions and imposes long term financial obligations. Private colleges of optometry do not reserve funds to meet future obligations imposed by tenure.

Q: What solutions do you propose to reduce the costs of the academic program?

A comprehensive review of the curriculum is suggested, specifically to remove redundancies and course material that could be changed to a pre-optometry requirements, more fully utilize current technology and consider distance learning for selected courses. A national faculty of recognized scholars could provide much of the classroom component of the curriculum via distant learning technology.

When the curriculum is completed, regardless of length, post-graduate training would be required. The post-graduate requirement would therefore make optometric education an exact parallel with podiatry and medicine and position optometry to qualify for Federal support (GME).

Private colleges of optometry should review the long term financial liability that tenure imposes, offer alternatives to tenure such as contract tenure or discontinue tenure. Colleges should calculate the long term financial obligation of tenure already granted and apprise the governing board of the magnitude of that commitment. Consideration should be given to reserving funds to cover tenured faculty.

Q: Why do you believe research at private institutions may be contributing to the cost of optometric education?

Meaningful research programs are costly to develop and maintain. External funding is highly competitive and failure to secure new and ongoing funding may lead to absorbing the costs of research personnel and related expenses in the operating budget. Since the budget is largely funded by student tuition, in the absence of external research funds, increases in student tuition would likely be needed or funds would need to be diverted from the core educational program to support research.

Q: What measures should private colleges take to prevent research programs being funded by student tuition should external funding not be available.

Caution should be exercised in investing in expensive research infrastructure as a return on investment can not be assured.

Translational scholarship such as publications, book chapters, presentations and posters at the AAO, leadership positions in the profession, appointments to NBEO and ACOE Boards, community service could replace traditional research as an expectation of faculty.

It should be clear when appointing faculty who are primarily researchers, that he/she must support all research activities and research personnel with external funding. If funding is lost, continued employment can not be guaranteed.

Caution should also be exercised in granting traditional tenure to research faculty.

Q: Are there other matters you would like to discuss?

Even if all the above recommendations were implemented, revenue would still not be sufficient to support quality optometric education without regular increases in student tuition resulting in higher student debt. It is essential that alumni support their alma maters. Financial support from alumni is far from its potential and is critical to sustaining the quality of optometric education and for attracting the best and brightest students. Both are vital to the prestige and long term success of the profession of optometry.

Strategic alliances among the private colleges of optometry are suggested as a means to reduce costs, stabilize enrollments and strengthen their position in a finite student market. Affiliations with public universities should be considered. Affiliations with medical school departments of ophthalmology provide consultation and surgical services for the college’s clinic patients as well as cost effective clinical teaching encounters for optometry students and residents.

Private colleges should not always count on a robust student applicant pool or increased class size to develop operating budgets. The student applicant pool is cyclical and in combination with increased competition for students from new schools, it could leave the college with unfunded expenses without sufficient tuition revenue.

Colleges should consider reorganizing their clinical program into a separate subsidiary of the college. The advantages of this structure are:

  • Provides for a reasonable separation of risk.
  • Facilitates the appointment of Board members with skills in health care administration.
  • Provides for more focused attention to the respective missions of education and patient care.
  • Enhances the ability to solicit funds from foundations and other funding sources which do not contribute to educational institutions.
  • Participation in GME would require a separate legal structure as payment are made to the clinical entity and not the college.

Externship sites need strict guidelines and oversight. Consideration should be given to the establishment of a central clearing house for extern placements. Only extern sites that comply with guidelines should be included. Some form of accreditation is needed for individual sites.

August 25, 2011 by Charles F. Mullen

Illinois College of Optometry Commencement Address (Video & Transcript)

Thank you for this high honor.

Trustees, President Augsburger, colleagues, honored guests and above all doctoral degree candidates.

I know you are eager to receive your degrees and celebrate your hard earned achievements, however, as tradition dictates, there will be no degrees until the old guy speaks.

Congratulations on earning your Doctor of Optometry degree.

Today, I join with your families and friends in sharing the pride of your outstanding accomplishments.

Your future is bright with unparalleled practice opportunities.

You have been fortunate for the past four years to be touched by the uncommon power of the ICO experience.

This experience ensures your success in a changing health care environment.

An outstanding faculty has prepared you well for opportunities in the areas of public health, patient care and clinical education.

In the area of public health there is an increasing awareness of unmet visual health needs in medically underserved areas.

And there are opportunities for you to meet the needs of special populations: for those who live in poverty, the homeless, the frail elderly, the homebound, the developmentally disabled and the visually impaired.

The Illinois Eye Institute’s community outreach to the underserved population of Chicago serves as an outstanding example of collaborative medical care.

I hope you will use your ICO training to help others in need.

In patient care, opportunities are available to you in interdisciplinary care as optometrists manage more complex clinical conditions and diseases, requiring close coordination with other professionals.

Also, telemedicine technologies and electronic health records provide the means for more effective patient management.

ICO’s commitment to excellence in patient care is affirmed by grant awards from prestigious organizations and corporations.

The College’s network of over 150 clinical training sites in 47 states and abroad is one of the most extensive in optometry.

In clinical education, there are opportunities for you, as preceptors, by sharing your experiences in: patient-centered education and cooperative clinical training between optometry and ophthalmology.

ICO’s support from external sources for clinical training is the highest of all optometric institutions and is an acknowledgement of the College’s excellence in clinical education.

My education, like yours, prepared me not only to be a competent clinician but also to contribute to the profession’s future.

Your professional status will also provide entree to numerous social, civic and political activities.

In the past, it has been the foresight and persistence of many dedicated individuals to move the profession forward.

You are now called upon to make such a contribution.

Given the aging population, uncertain optometric manpower needs and the impact of national health care reform, there is a need for broad based strategic planning including professional, academic and corporate participation.

I encourage your active involvement at the local, state or national level in planning for your profession’s future.

Current Board Certification and Continued Professional Competency initiatives require your attention and understanding of their place in your profession.

There are unprecedented opportunities for optometry to seek inclusion in three major Federal programs while the federal budget is being re-structured.

These programs could potentially benefit the current generation of optometrists as well as future optometric students, residents and graduates.

The first initiative which is already in progress is the expansion of optometry’s impact in the community health care system.

Community health centers provide accessible and cost effective primary medical care to 20 million Americans in rural areas and poor urban neighborhoods.

However, only 20% of federally qualified health centers offer eye care services, despite the growing need in rural and inner-city America.

Federal funding is required to establish optometric services in all of the Nation’s community health centers.

It is estimated that 5,000 optometrists would be needed in the Nation’s underserved areas over the next decade providing not only new practice opportunities, but also additional student and resident clinical training placements.

The second program is the National Health Service Corps.

Efforts must be made to attract more optometrists to medically underserved areas through financial incentives, such as tax free student loan repayment, by including optometrists in the National Health Service Corps.

Classification of optometry by the Federal government as a Primary Care Profession is a necessary next step to qualify for this program.

Third and long overdue, is optometry’s inclusion in the Graduate Medical Education program, GME, the clinical educational component of Medicare.

Optometrists have been included in the Medicare program since 1987 and currently provide $970 million in services annually to Medicare beneficiaries.

Now it is time to join medicine, dentistry and podiatry as a recipient of GME funding for clinical training.

Optometry’s inclusion in the $9.5 billion program would address: the increasing costs of clinical training and the need for workforce development as the scope of optometric practice continues to expand and growth in the demand for eye care services by the Medicare population.

Although the work ahead will be challenging, inclusion in these three major Federal programs would provide visual health care to tens of thousands of underserved individuals, strengthen the profession of optometry’s position at the national level and forever change the financial landscape of optometric education.

I am confident that the profession’s future leaders are in this Chapel today.

And as those before you, you must move forward with a balance of discretion and audacity.

Be willing to take risks with innovative approaches.

In whatever you do, follow the example of your Alma Mater and strive for pinnacles of excellence.

For in the final analysis, it is neither about financial rewards nor power, but pride in your professional and personal achievements.

Character and contribution will define your success.

Thank you and congratulations.

May 21, 2011

May 21, 2011 by Charles F. Mullen

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Signature Papers

  • Optometry Specialty Certification Boards Provide a Uniform Indicator of Advanced Knowledge and Skills
  • A New Paradigm for Optometry
  • Optometric Education in Crisis
  • Opportunities Lost – Opportunities Regained
  • Mergers and Consolidations of Optometry Colleges and Schools
  • Transformation of Optometry – Blueprint for the Future
  • Required Postgraduate Clinical Training for Optometry License
  • Why Optometry Needs the American Board of Optometry Specialties (ABOS)
  • The Future of Optometric Education – Opportunities and Challenges
  • A Strategic Framework for Optometry and Optometric Education
  • Changes Necessary to Include Optometry in the Graduate Medical Education Program (GME)
  • Unresolved Matters of Importance to Optometric Education
  • Illinois College of Optometry Commencement Address (Video & Transcript)
  • Charles F. Mullen’s Speech at the Kennedy Library: Development of NECO’s Community Based Education Program
  • Illinois College of Optometry Presidential Farewell Address (Video & Transcript)
  • Commitment to Excellence: ICO’s Strategic Plan
  • Illinois College of Optometry and University of Chicago Affiliation Agreement
  • An Affiliated Educational System for Optometry with the Department of Veterans Affairs

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