Headway's Quality Improvement Committee (QIC)

Updated

What is the Quality Improvement Committee?

Headway's Quality Improvement Committee (QIC) is the clinical governing body responsible for decisions about a provider's standing in Headway's network. It is an interdisciplinary committee composed of Headway's clinical leadership, along with members representing multiple clinical license types.

The QIC is a sub-committee of the Credentialing Committee and managed inside Headway's clinically led professional corporation (PC) — not the business side of the organization. Under corporate practice of medicine (CPOM) requirements, decisions about credentialing, peer review, clinical performance, and a clinician's participation in the network must be made by licensed clinicians. The QIC is how Headway meets that standard: clinicians make clinical decisions about clinicians.

Why it exists

Quality and integrity of care across the network is a shared responsibility. The QIC exists to:

  • Make decisions about clinical quality concerns using standardized, consistent processes and guidelines
  • Keep clinical decision-making in the hands of licensed clinicians
  • Identify patterns across cases and direct network-wide process and policy improvements
  • Protect patients

Under direction of the QIC, Headway tracks patient concerns and grievances and implements process improvements.

Who is on the committee

The QIC is composed of Headway clinical leaders, with representation from licensure types that practices on the platform:

  • Licensed master's-level therapists
  • Licensed doctoral-level therapists
  • Nurse Practitioners licensed as psychiatric providers (i.e. Certified Psychiatric-Mental Health Nurse Practitioners)
  • Psychiatrists

This means a provider's case is evaluated by peers who understand their scope of practice. Membership changes over time as the network and clinical team evolve. Only clinicians are eligible to vote on a provider's privilege to practice on the Headway platform.

What kinds of cases reach the QIC

Most providers will never interact with the QIC. Concerns reach the committee in two ways: through Headway's ongoing clinical quality and risk monitoring, and through reports made to Headway by patients, health plans, or anonymous sources. A case is referred when it is not resolved through the standard review, education, and remediation pathways. Common referral routes include:

  • Chart review and clinical quality monitoring. Most documentation findings are resolved with feedback shared with the provider and short coursework. However, when major documentation deficits are identified and are not addressed following a remediation plan, the case may be presented to QIC. 
  • Patient concerns and grievances. If a review of a patient concern requires further action — including any step that could affect a provider's participation on the platform — the case is presented to the QIC.
  • Providers must submit documentation and participate in other required aspects of their Provider Agreement when requested. Failure to do so — including failure to respond to Headway's communication requests — may result in referral to the QIC for review.
  • Supervision concerns. When a concern about a supervisee raises questions about the quality of supervision provided, the supervisor's standing may go to a QIC vote.
  • Clinical practice concerns, and fraud, waste, or abuse. Headway QIC review occurs when care may violate clinical best practice, deviate from established standards of care, or where there is concern for fraud, waste, or abuse. This includes concerns about prescribing or treatment practices, and inappropriate billing or scheduling patterns.

How it works

The QIC follows a consistent, standardized, evidence-based process, in order to ensure that similar cases are handled the same way regardless of who raised the concern.

  1. Referral. A case is referred to the QIC after the relevant clinical, quality, or escalations team has completed its review.
  2. Preparation. The relevant information is compiled for committee review and all provider and patient information is deidentified.
  3. Committee review. The QIC assesses the case and determines the necessary actions. Providers under review do not attend QIC meetings; the committee reviews the case via the record compiled for presentation.
  4. Vote. When the committee review involves a question around a provider's privilege to practice on the Headway platform, the committee votes on the decision.
  5. Communication. The provider is informed of the outcome and any required next steps.
  6. Appeal opportunities (see below)

Possible outcomes

Outcomes are proportionate to the concern and can include:

  • Required education, remediation, or a curative action plan, with progress monitored to completion
  • A secondary or follow-up review of documentation
  • Restrictions on platform activity, such as pausing new supervisees or removing supervisory status
  • Termination of the Provider Agreement and removal from the Headway platform
  • A report to the relevant state licensing board, in circumstances where reporting is required
  • No action taken

Progress on remediation is monitored by Headway's clinical quality team, and successful completion closes the review.

Can I appeal a QIC decision?

Yes. Providers have the opportunity to appeal a QIC decision regarding their removal from the platform. After the results are communicated to the provider, the appeals must be submitted in writing, within the window of time communicated to you with the committee's decision. Decisions on appeal are final and may not be appealed further.

What the QIC is not

  • It is not the credentialing committee. While QIC is a sub-committee of the credentialing committee, credentialing and recredentialing decisions are made separately.
  • It is not your annual chart review. The annual chart review is a routine, retrospective review that every provider completes once a year. It is not triggered by a complaint, and the overwhelming majority of reviews pass successfully without any QIC involvement.
  • It is not a business decision. Clinical judgment about a provider's participation in the network rests with licensed clinicians.

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Disclaimer: This document is for educational purposes only and is not intended as professional or legal advice. It may contain errors or missing information, and recent changes in policies, regulations, or payer requirements may not be reflected. Because requirements vary by organization and jurisdiction, please consult legal counsel, the appropriate regulatory or licensing authority or your designated Headway contact for guidance specific to your situation.

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