BSRC Clarifies Requirements
September 18, 2006

The Bariatric Surgery Review Committee (BSRC) has clarified several of its policy interpretations, which were initially released on August 22, 2006.  The clarifications can be found below in red typeface.

The BSCOE requirements are re-evaluated by the Bariatric Surgery Review Committee on a regular basis to eliminate confusion, solidify requirements and strengthen the quality of the program.

1. Requirement Two: Documentation of Volume Requirements
Volume requirements will be determined by counting the number of surgeries performed in the 12 months from the date first reported on the Full Approval application, or during the 12 months immediately prior to the site inspection; whichever number is greater will determine the volume used. This covers those situations in which a Center may have experienced a temporary drop in volume in the weeks preceding the inspection but can demonstrate the required volumes were met during the application period.

2. Requirement Four: ACLS Qualified Physician
ACLS coverage may be fulfilled by a Senior Resident. The on-site and 24/7 requirements must also be met.

3. Requirement Five: Toilets
"Floor supported" toilets are now a requirement. The BSRC will consider manufacturer weight limit certifications of non-floor supported toilets.
Toilets not directly mounted into the floor must be floor supported.  For toilets which are not floor mounted, the applicant is required to provide a manufacturer's weight limit certification, which sets the maximum load capacity of the fixture.

4. Requirement Six: Covering Surgeon CME Requirements
The Continuing Medical Education requirements for covering surgeons will become effective for all new applicants January 1, 2007. Existing BSCOEs must meet the requirement at the time of reapplication.
Under review: Surgical Review Corporation is gathering data on the prevalence of ICUs at existing COE hospitals.  The BSRC will consider whether applicant hospitals should be required to have an on-site ICU. 

5. Requirement Seven: Clinical Pathways
Clinical pathways must be formally adopted and implemented at the time of the site inspection. Failure of the Center to provide documentary or other evidence at the site inspection that pathways have been adopted and are being implemented is grounds for denial of the application for Full Approval.
Under review: The BSRC is considering adopting more detailed descriptions of required clinical pathways.

6. Requirement Eight: "Part-Time" Bariatric Coordinators
The situation of a "part time" bariatric coordinator will be evaluated by the BSRC on a case by case basis. The BSRC believes that a part time position may be acceptable for a lower volume center, but may be indicative of a lack of institutional support in a higher volume center.
Surgical Review Corporation is gathering data on the education and licensing of bariatric surgical coordinators.  The BSRC will consider whether to adopt minimum education, training and/or licensing requirements for bariatric surgical coordinators.

7. Requirement Nine: Support Group Leadership
The support group moderator must be a licensed or certified health care professional. This requirement becomes effective October 1, 2006. Applicants whose site inspection occurs prior to October 1 will be reviewed under the current interpretation, which does not require licensure.
A licensed or certified health care professional must either lead or be present for support group meetings.  In addition, the effective date for this policy is now June 1, 2007 for new applicants.  Applicants whose programs are site inspected prior to June 1, 2007 will be inspected under the current policy, which does not require that the moderator be a licensed health care professional.  Current COEs will be required to comply with the new policy at the time of reapplication.

Additionally, the application question regarding whether the applicant hospital covers bariatric surgery is for information gathering purposes only and is not considered in the review of the application.

8. Ethical Issues Regarding Applicant Surgeons
The surgeon's application will be changed to include questions pertaining to a surgeon's disciplinary and ethical complaint history.

9. Approval Period
The term for Full Approval as a BSCOE is three years. Approval for a one or two year period has been discontinued. However, in the event of a noted issue or deficiency of particular concern, the BSRC may grant approval and designate that an interim review of the program be undertaken at one or two years (or any other time). In this case, the deficiency or concern and need for interim review will be outlined in the Center's Full Approval letter. If the deficiency has been satisfactorily rectified prior to the interim review, the Center's term will continue uninterrupted. If the deficiency has not been resolved, the Center may be placed on probationary status if it fails to meet program requirements, consistent with general program guidelines.

10. Changes to the BSCOE Application
Additionally, several changes have been made to the Center of Excellence applications. The surgeon's application has been updated to include questions regarding (but not limited to):

• License and privilege revocations, felony convictions and other potential ethics violations
• CME courses completed by the applicant surgeon
• Greater specificity on patient demographics
• The bariatric surgery training and experience of all covering surgeons

Questions in the surgical group application have been virtually eliminated. Name, address and other contact information will be the only questions required in the future. The hospital application will be updated to include questions regarding (but not limited to):

• The availability of bariatric surgery benefits for hospital employees
• Whether the Bariatric Medical Director is a compensated position
• Whether patient support groups (if provided by the hospital) are open to all patients, regardless of where their surgery was performed

Pediatric Program Update
The BSRC has determined that it will collect data from existing programs on pediatric and adolescent surgeries.  That data will ultimately be used to formulate specific pediatric program requirements.