bvvp, DPtV, VAKJP and DGPT criticize IQTiG's quality assurance procedures

08.12.2022 10:43

On August 18, 2022, the Federal Joint Committee (G-BA) released the final report of the Institute for Quality Assurance and Transparency in Health Care (IQTiG) on the “Development of a patient survey for the quality assurance process for outpatient psychotherapeutic care for those with statutory health insurance” for publication. This was created as part of the commissioning of the institute by the G-BA to develop a quality assurance instrument for outpatient psychotherapy. The questionnaire contains 40 items - with all sub-questions totaling 62 - items that patients should answer after completing psychotherapy.

The Federal Association of Contract Psychotherapists (bvvp), the German Society for Psychoanalysis, Psychotherapy, Psychosomatics and Depth Psychology (DGPT), the German Psychotherapists Association (DPtV) and the Association of Analytical Child and Adolescent Psychotherapists (VAKJP) rate the questionnaire as unsuitable for its quality of psychotherapeutic treatment and thus improve the quality of treatment. In addition, there is a risk that it will have an unfavorable influence on the therapeutic process and that its introduction could result in a selection to the disadvantage of patients for whom a difficult course of therapy is foreseeable or the prognosis for success is uncertain.

“It is already part of every therapy process as a standard intervention to regularly obtain feedback from patients,” say the associations, “but a follow-up survey can no longer serve to improve ongoing treatment.” However, this goal must be achieved Introduction of a useful quality assurance (QA) instrument.

The associations criticize:

• The statistical problem of the small number of cases in psychotherapeutic practices. The number of treatments completed in the focused period is again significantly lower. Added to this is the expected low response rate. Statistically valid statements cannot be made on this basis.
• There was no operationalization of the indicators with the involvement of experts from practice.
• There are manipulative question and answer formulations, as many questions have negative, suggestive connotations.
• Distortions may occur due to a lack of memory of the start of therapy. In addition, a significant proportion of the questions are aimed at educating and informing patients before the start of therapy. They correspond to a pure checklist that determines whether the requirements of the professional regulations and the Patient Rights Act have been met. However, it is not the task of a quality assurance instrument to monitor the fulfillment of legal requirements.
• The overall result is guided by subjectivity, because a large number of the questions refer to purely subjective impressions and assessments of the patients. The justiciability, especially with regard to the resulting sanctions for psychotherapists, is therefore questionable.
• There is no benefit to the current therapy because the results are only available months after the therapies have been completed. In contrast, there is the quality assurance already practiced by the profession: feedback is collected in order to make changes in the ongoing therapy process if necessary, also in a timely manner with the support of supervision and intervision and professional exchange.
• A risk adjustment based on the duration or severity of the illness, previous and additional treatments or other inhibiting and promoting factors for psychotherapeutic treatment is not possible based on the variables collected.
• There is a significant risk that psychotherapeutic practices will primarily select “good risks” for treatment as part of the planned QA process (risk selection).
• The appropriateness of the reference ranges for the quality indicators is questionable as they were set by IQTIG without sound technical justification.
• If psychotherapeutic treatments are completed and relapse prevention is then carried out, the external patient survey will take place in the middle of the ongoing therapy process and can have a negative impact on it, because relapse prevention is still part of the treatment. This must be ruled out.
• Carrying out a QA procedure represents a significant increase in bureaucratic effort for the bodies involved.

The associations demand:

The points mentioned as well as the statements on the interim report must be taken into account when re-commissioning and revising the patient survey. The entire process needs to be put to the test again! If IQTiG is unable to do this or does not see this as its task, then the associations will demand an extensive evaluation over several years in a model region. It should be taken into account that the procedure itself represents an intervention whose (side) effects must be urgently checked. Surveying psychotherapists and patients should not be a laboratory experiment! In addition, the bureaucracy costs must be collected and assessed in a differentiated manner. The fundamental question arises as to which quality characteristics have been scientifically proven to have substantial quality deficits in current outpatient psychotherapeutic care. This is the only thing that needs to be evaluated – using appropriate means.