INTERNATIONAL HEALTH FACILITY ACCREDITATION & MEDICAL TOURISM:

CRITICAL CONSIDERATIONS FOR NEW FACILITATORS AND REFERRAL AGENCIES

Many hospitals (and the facilitators and referral agents that refer patients to them) advertise that their hospitals are internationally accredited by one or more accrediting bodies.

Accredited status is the result of a site visit inspection that involves a “snapshot in time” of the hospitals’ written policies and procedures for quality and safety, observed once over a 3-4 day site inspection and conducted every 2-3 years, depending on the accreditor. My team and I have assisted hospitals to successfully prepare for accreditation site visits in 15 countries - with 100% success, so I know about this topic better than most medical tourism marketing consultants who compete with us. I've also personally prepared health facilities and then conducted mock surveys and ultimately escorted the accreditation surveyors through hospitals, clinics, and ambulatory surgery centers worldwide over the past 35 years as both a consultant and also as a health facility administrator during my career. As a result, few health tourism marketing and strategy consultants who write or consult on healthcare marketing and branding in medical tourism can compete with me on this point.

Many outsiders who enter medical tourism lack deep healthcare industry knowledge. Some view medical tourism as an extension of digital and internet marketing of health services. The see opportunity to make money on software, internet clicks, and digital marketing services. Travel agents who add medical tourism sales view it as an extension of wellness and feel good travel and holidaymaking. They view medical tourism as an expanded revenue opportunity to collect referral and booking commissions from an additional supplier. Others, known as medical tourism facilitators often enter medical tourism with intentions to get "a piece of the cash flow" for setting appointments for consumers that wish to access health services away from their usual place of residence. Then there's another group - the ones who organize conferences and sell exhibitor stands and advertising and promotional sponsorships. They seek to earn revenues from desperate uninitiated medical tourism neophytes eager to connect with referral agents, insurers, employers and others expected to be in attendance at the event.

In reality, few of these individuals listed above see more than the branded logo of the accreditation scheme. They know it means something because of how frequently it is mentioned, but few have professional knowledge or understanding of what accreditation actually entails. To most, it is a mere tick on a checklist. If the facility has it, that's supposed to be a good thing. Yes?

The actual cost of the triennial inspection often currently exceeds USD $250,000 between fees and costs of the site visit, application fees, and internal preparation costs. That's a big budget commitment. The Board of Directors or Trustees often approve the expenditure if the petitioner requests budget allocation to prepare for international accreditation. One recognized entity, the The International Society for Quality in Health Care (ISQua), inspires, promotes and supports continuous improvement in the quality and safety of healthcare and has been the accreditor of the international hospital and clinic accreditation schemes for years and operates its ISQua’s International Accreditation Programme (IAP). The program provides a mechanism for external evaluation and standards setting organizations to assure themselves that their standards, their surveyor training programs and that they themselves, as an external evaluation organisation, meet international best practice requirements and to demonstrate this to their clients, insurers, investors, and other stakeholders. 

Currently there are more than 20 accrediting bodies that are themselves accredited through ISQua's IAP. And easily another 20 that are not accredited by any external validator and are just proprietary options in the marketplace. Anyone can attempt to sell anything, anywhere, anytime. But rather than invest in their own accreditation through ISQua's IAP, they invest that money in their brand promotion to the medical tourism industry. The general consumer, the media, and third party payers know little more about these proprietary brands of accreditation and designations than they do about the ones that are accredited under ISQua's IAP. This is unfortunate because many of the uninformed are led to believe that accreditation schemes are all equally meaningful and equal in significance. They aren't.

What it takes to prepare for an accreditation survey

Have you ever spit-shined your home for a visitor? Once you’ve done it, and the event has passed, do you keep it that way or do you revert back to your “normal” state over time? Experienced hospital executives can spit shine a hospital for a surprise inspection on about 4 hours notice, if necessary. That happens more often than people realize. Unannounced surveys and inspections happen every now and then, usually as a response to a complaint or buzz in the marketplace. Why? because the accreditor has a brand to defend. If a hospital, clinic, ambulatory center or academic medical center were to lose their accreditation status - even temporarily, then display of the accreditors' logos are a violation of their contract with the accreditor. This is why you don't see the logo all over the telephone book and other "once yearly" ad graphics.

In the accreditation standards book, it is clearly stated that if you even suggest that you are aiming towards, or scheduled for or preparing for accreditation with an accrediting body, you cannot use this as any part of your marketing message. You either are or are not currently accredited. Period. Yet, throughout the world, in country after country, I am take on familiarization ("fam") tours of hospitals and destinations where I hear these words all the time. I seen it in videos, pamphlets, websites, brochures and heard it in panel presentations. Each time, I make a mental note to cross the facility off the list of potential candidates. Why? Lack of integrity!

If they will so cavalierly violate this requirement clearly stated in the front of the standards manual, what else will they flagrantly violate? This should be a heads up warning to any new medical tourism facilitator or referral agency. If they will violate this provision of the accreditation standards, will the flagrantly disregard your standards and expectations of your contract terms and conduct with your clients? How could you possibly believe otherwise? Are you special or something?

What does the accreditation status mean?

What many people outside healthcare fail to realize is that the accreditation standards of most international hospital and clinic accreditation schemes often are no more than external validation that the hospital or clinic in question performs and is organized at the “average” level for all hospitals in that particular community - no more; no less. It does not infer or represent in any way that the hospital meets “foreign” standards associated with where the accreditation scheme is headquartered. Think about this for a moment. These hospitals are advertising that they are at "average" service, quality and safety as the other similar facilities in their community. Is that something worth advertising? And what if they are a sole community provider? Average as compared with which other facility. In which community?

To drive this point home, when touring a destination under consideration as a medical tourism destination for your network, for comparison, go and tour some of the other non-such accredited hospitals in the same community if they exist. Compare what you see on the surface. Do you see a huge difference? This is what the unsophisticated consumer sees. Your client will be expected to pay for that USD $250,000 expense, loaded incrementally into the facility's medical tourism pricing structure. They will also have to cover the incremental direct cost associated with the marketing and advertising to announce to the world that the facility are accredited. How does this benefit your client? How does it benefit your brand as a competing referral agency or facilitator? if your client knew that this was a designation of average-ness, would your current and future clients be willing to pay extra incremental direct costs for this designation? 

And if so many hospitals now have this external validation, is it still a “value differentiator” in terms of branding? Enough to command a premium price? Why? Could there be better bases upon which to differentiate that are more meaningful to the average consumer? After all, what do consumers really understand about healthcare accreditation schemes? What value do they place on its tic on the checklist?

Your liability as a medical tourism facilitator increases with accreditation

Does your contract with the hospital or clinic require that they notify you if their accreditation is revoked or suspended pending investigation or remediation? Because if this happens and you continue to market them as “accredited” you become liable for false advertising and misuse of the accreditor’s brand. The accreditor can come after you for copyright violation and trademark infringement if you continue to show them as accredited.

Whenever I mention this in a seminar or presentation, I see audience members pick up their pencils and pens and make notes. Why is this point not already understood by people in this business? Because they lack adequate training to enter medical tourism as a business owner and they often lack adequate startup capital to either obtain the training or hire someone to work for them who has this training and knows better. Refer back to my 3rd paragraph in this article. The people entering the medical tourism business who are not providers with clinical background can't possibly be expected to know this unless they've read books like "The Handbook of Medical Tourism Program Development" or the "Medical Tourism Facilitator's Handbook".

There are many reasons to maintain a market recognized accreditation as a healthcare entity.

For U.S. hospitals, it was, in the past, a requirement to have been accredited by "The Joint Commission" in order to participate with and be paid by the federal Medicare program. But years ago, that exclusivity was expanded to include several other accreditor options including Medicare Certification.

Hospitals must meet eligibility standards established by the federal government in order to receive reimbursement from the federally-funded programs, Medicare and/or Medicaid. The Centers for Medicare and Medicaid Services (CMS) has been designated as the organization responsible for certification of hospitals, deeming them certified and meeting established standards. The Joint Commission is one of several organizations approved by CMS to certify hospitals. If a hospital is certified by The Joint Commission, they are deemed eligible to receive Medicare and/or Medicaid reimbursement. Hospitals must be a member and pay a fee to The Joint Commission to be included in their survey process.

Therefore, a simple way to look at it is that a hospital that is accredited by The Joint Commission is by definition compliant with CMS as to its accreditation status. However, a hospital that is compliant with CMS is not necessarily accredited by The Joint Commission, a proprietary accreditor located in Oakbrook Terrace, near Chicago, Illinois. The Joint Commission International, a different proprietary company, is not the same, nor under common ownership, operated from an entirely different location as The Joint Commission within the same general township. The two sets of standards are also markedly different. Many hospitals and clinics and healthcare entities that were once Joint Commission accredited in the USA are now accredited by some other brand because Joint Commission lost its exclusive status as the only such "deemer". Slowly, the Joint Commission's former death grip on market share as new ISQua IAP accrediting schemes enter the marketplace and compete for similar advantage at a lower price.

If it was easier to read the accreditation standards of the American accreditors near Chicago without investing a small fortune (the standards books cost about $300 or more each and are written at a technical level, beyond the general comprehension of most non-medical people and are tightly controlled by the sellers) it would be easy to compare the standards sets line by line. There are several reason they are not easily accessible for purchase. Comparison is one, but the accreditors sell their training and preparation. As such, they view purchases of the standards sets as "sales leads".

We buy reference copies when released because of the consulting we do in the space. But they are always such a hassle to obtain without enduring the 3rd degree of questions. Sometimes, we just have the client buy a second copy and we reimburse them. But we don't just obtain the American accreditors' standards, we actually maintain a library of copies of the standards from many IAP accrediting bodies. The others who are not IAP accredited also sell their standards books - some want as much as USD $15,000 to purchase a copy! We won't buy their books and don't have time to read them. I won't invest the time to read them until there is a market demand for their product or they become otherwise significant.

There are other reasons that accreditation is important. Most accreditors support the idea and commitment of continuous improvement in healthcare for the public by assuring organizations are providing safe and effective care of the highest quality and value. But the line gets drawn on continuous improvement in other areas - for example, most do little, if anything to evaluate coding and billing practices, drug diversion, charge practices and documentation of services rendered and medical necessity, regulatory compliance, False Claims and other frauds and abuses and contract breaches ....all of which at the end of the day will shut a hospital's doors and cause scandal that can result in fines and censure for executives. All those things can impact your clients' bills, patient experience, and your own reputation by association.

If one of your network hospital or clinic suppliers is involved in a scandal and it results in patient injury or determent, you may also be liable as the network organizer and referral partner under the OSTENSIBLE AGENCY relationship. Since the Medical Tourism Facilitator or referral agent could be viewed by the general public as an official agent of the hospital or clinic, and is selling the professional service of coordination and having performed due diligence prior to the representation or referral.

Dependence on current healthcare facilities accreditation in lieu of proper and adequate due diligence and contractual agreements citing a standard of conduct or performance would be no defense as it is reasonably expected by the reasonable person (a phrase frequently used in tort and criminal law to denote a hypothetical person in society who exercises average care, skill, and judgment in conduct and who serves as a comparative standard for determining liability in any jurisdiction in any country.)

Many medical tourism facilitators also rely on a variety of disclaimers with their clients to abdicate responsibility for vicarious liability for the acts of the doctors and health facilities of their represented providers. Vicarious liability refers to a situation where someone is held responsible for the actions or omissions of another person. In a healthcare context, a medical tourism facilitator could face risk exposure and liability for the acts or omissions of its network doctors, hospitals, clinics, and hotels, provided it can be shown that the client assumed that the facilitator performed adequate due diligence in the course of their product or network development. That's why ticking the box of accreditation in lieu of proper of due diligence is so risky.

Professional liability underwriters that insure medical tourism facilitators now dig much deeper into the due diligence procedures than they did 5-7 years ago before agreeing to accept liability and issue an insurance policy for medical tourism facilitators' and other referral agents' professional liability. You aren't in the business of appointment setting as a Medical Tourism Facilitator. You are in the business of coordinating care to a trusted network of medical, dental and other healthcare professionals and the facilities with which they are associated and privileged to admit or treat patients assigned to their service.

I hope this information has been helpful to you. This is but one of the areas I can address in private one-on-one coaching for medical tourism facilitators who want to avoid unnecessary business risk and start their business with the right policies, procedures, and business practices in place prior to launch. If you have questions or want my help, please read this article here on LinkedIn to learn how to get started working with me.

Call me today to discuss your unique situation. (+1.800.727.4160) or send an email via LinkedIn or directly to our corporate email address to [email protected].

About Maria Todd

Chief Executive Officer at Mercury Healthcare International, Inc.

Clients dramatically improve their medical tourism operations, business growth, and profitability after working with Maria Todd. They realize increases in their reimbursement, volumes of new patients, and global brand awareness and appeal.

Her unique skill set comes from over 35 years of experience at all six seats at the table, clinical, administrative, insurance contracting, travel and tourism, marketing and branding, and health law paralegal work. She intertwines these skills in a way that no other consultant can offer because most usually only offer one of these expertise and have to call upon others - each with their own fees and expenses to comprise the other five. She solves problems for clients and shortens time and reduces expenses associated with hiring a consultant. This is an additional value added benefit of working with her.

Maria adds value to every project she accepts. If she doesn't believe she can add value, she turns the project down. In reality, the demand for her time is so high that she cannot accept every project she is invited to. After more than 35 years helping clients succeed, her time is scarce. She is often booked to start new projects or present keynote addresses and workshops as much as 18 months in advance. She loves watching her clients' successes and watching them grow and thrive. She is also brutally honest with clients which they tend to appreciate when working with her. She is direct. She pulls no punches and doesn't sugar coat bad news or constructive criticisms.

Reach out to her to by phone or by email. Maria accepts most invitations to connect with her on LinkedIn and at her professional Facebook page. Maria prefers direct email to her @mercuryadvisorygroup.com address or through LinkedIn for all contacts via email.