Subcommittee on IH and CMC Reports - Advisory Board on Toxic Substances
Subcommittee Charge: To review the work of industrial hygienists and staff physicians to ensure quality and consistency. Previous recommendations include establishing a direct interview process with claimants and making records searchable. The Subcommittee Meeting discussed follow-ups and improvements, such as tracking comments and revising policies. Challenges with IH and CMC reviews were highlighted, leading to recommendations for better organization of claimant records and quality improvement efforts.
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Presentation Transcript
Subcommittee on IH and CMC Reports ADVISORY BOARD ON TOXIC ADVISORY BOARD ON TOXIC SUBSTANCES AND WORKER HEALTH SUBSTANCES AND WORKER HEALTH 4/19/2017
Subcommittee Charge To review the work of industrial hygienists and staff physicians and consulting physicians of the Department and reports of such hygienists and physicians to ensure quality, objectivity, and consistency. Members: Sokas, Griffon, Vlieger, Domina, Whitley, Friedman-Jimenez
Previous recommendations > That DEEOIC establishes a process where the industrial hygienists interview the claimant directly. > That the DEEOIC policy teleconference notes taken by DOL be redacted and made searchable and publicly available. > That DEEOIC make the entire claimant case files available to the claimant online. > That DOL create a departmental occupational medicine resource that serves the agencies in a manner similar to the office of the Solicitor of Labor. > That the entire case file be made available to the industrial hygienists and CMCs.
Subcommittee Meeting 12/16/2016 Follow-up for 10/18 10/19/2016 public comments Very helpful to have DOL personnel and Ombudsman present and able to provide immediate responses to individuals, request increased local office presence as well. Develop formal approach to tracking and responding to comments, similar to Radiation Board. Review and revise DOL policy requiring claimants to travel up to 200 miles for DOL directed medical evaluations.
IH Review It is not clear whether IH review is triggered in all cases where it would be beneficial It is not clear whether the IH review, when triggered, involves a review of all relevant data. Claimant records easily run several hundred to a thousand pages and are poorly organized
CMC Review > CMC qualifications appear to be solid, but some reviewers use their own standards of causation rather than the accepted DEEOIC standard that work exposure must have caused, contributed to or aggravated the medical condition being considered. > Claimant records sometimes are several hundred to a thousand pages, are poorly organized and are non-searchable pdf files; it appears that this is an obstacle preventing some CMCs from accessing the entire record.
Recommendations for discussion > Organize claimant records into sections and make the records searchable pdfs. > Conduct QI for sample of past CMC letters resulting in denials utilizing worker-centered occupational physicians (consider AOEC subcontract). > Based on results of QI review, develop guidance materials for CMCs. > Provide a briefing package for CMCs that emphasizes the DEEOIC standard that the work exposure must cause, contribute to or aggravate the medical condition being considered, and program definitions and presumptions for each, eg COPD, asthma, or Beryllium disease. > Provide CMC with online access to entire record.
