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Joint Commission revises Medication Management EPs

The Joint Commission has revised Medication Management elements of performance (EP) for several of its programs. The changes will go into effect on January 1, 2018 and will impact hospitals, ambulatory care, behavioral care, home care, nursing care centers, critical access hospitals, and office-based practices accredited by The Joint Commission. The revisions will require organizations to:

•    Record the date and time of any medication administered in the patient’s clinical record.
•    Implement a policy to provide emergency backup for essential medication dispensing equipment and for essential refrigeration for medications.
•    Have a written policy addressing the control of medications between when they are received by a provider and given to a patient. Those policies should now include what to do for the “wasting of medications.”
•    Implement a policy describing the types of medication overrides for automatic dispensing cabinets that will be reviewed for appropriateness and the frequency.

The revisions vary depending on the program.

CMS withdraws proposal to have AOs post survey reports online

A proposal by CMS to have accrediting organizations (AOs) post the details of survey reports online was withdrawn by the agency, not because of negative comments — although there were plenty — but because, well, it might be prohibited under federal law.

CMS first made the proposal in April, tucking it into the latter pages of the always-long proposed on changes to the Inpatient Prospective Payment System (IPPS) for the upcoming fiscal year.

The proposal was to have AOs post final survey reports online within 90 days that the same information is available to the hospital or other health care organization, including details of all initial and recertification surveys at that provider in the prior three years, as well as the accepted plans of correction (PoCs).

AOs now post only whether an organization is accredited or not, and do not make details of findings public.

CMS argued its proposal was to promote transparency in health care, and noted that it posts its own  survey reports online. But critics responded that the CMS reports are made available in a hard-to-read spreadsheet and that the federal agency was responsible for far fewer surveys at health care organizations that were often surveyed only after a complaint (IJC 5/1/17).

In public comments to CMS concerning the proposal, The Joint Commission said that requiring survey details be made public would have “chilling effect” on efforts to raise standards of quality. Dr. Mark R. Chassin, president and CEO of The Joint Commission, wrote: “There will be a race to the bottom on quality as health care organizations seek out oversight bodies that will report on the least number of standards comparable to the Medicare requirements. This may also lead to a growth in non-accredited facilities that will then be surveyed at taxpayer expense and with fewer oversight visits.”

Other groups similarly weighed in against the proposal, and offered alternatives. In the end though, it was shot down because it might potentially be prohibited.

In the IPPS final rule published Aug. 2, CMS noted that its proposal included revising the federal regulations overseeing Medicare to incorporate the requirement for AOs to post report details publically.

“Section 1865(b) of the Act prohibits CMS from disclosing survey reports or compelling the AOs to disclose their reports themselves. The suggestion by CMS to have the AOs post their survey reports may appear as if CMS was attempting to circumvent the provision of section 1865(b) of the Act. Therefore, this provision is effectively being withdrawn.” — A.J. Plunkett (aplunkett@h3.group)

Resource:

Options to CMS’ proposed transparency rule

This April, CMS sent out a memo with big proposals for accrediting organizations (AO). If passed, The Joint Commission, DNV, HFAP, and others would have to post final survey reports online within 90 days of that information becoming available to the healthcare organization.

However, The Joint Commission and accreditation specialists have voiced worries that the move creates an uneven playing field in hospital quality and oversight. It’s also argued that the public might have trouble deciphering the contents of the report.

“This proposed rule is troubling from a risk and safety perspective for a variety of reasons, including the potential for misuse, misunderstanding and other unintended consequences, writes Christina Thielst, FACHE, for MultiBriefs.“However, it is especially concerning because survey reports can include confidential internal quality/performance improvement information. This information is shared when trust has been established between staff and surveyors who agree to maintain that confidence. Making the details of survey reports available will impede the flow of information and interfere with this the performance of this important component of every hospital’s quality improvement program.”

While many disagree with CMS’ proposed method, that doesn’t mean there aren’t options to promote transparency. Theilst says that CMS can reduce variation and increase transparency for consumers while avoiding unintended consequences using its existing policy.  Her suggestions include:

1.    Respecting the delineation of responsibilities and functional boundaries. This avoids the scope creep which comes from shifting private AOs away from their role evaluating adherence to standards of care and toward inspecting for regulatory compliance instead.

2.    Produce summaries of the information most relevant to consumers from accreditation reports.

3.    Have hospitals, AOs, and CMS team up to create a dashboard of findings and trends that consumers can understand and act upon.

4.    CMS and their AOs must comply with the terms of their agreements and investigate the causes of variation, identify breakdowns in the system, and make needed improvements.

Uniqueness is not unique

Editor’s Note: This is a free Briefings on Accreditation and Quality article from yesteryear! If you like it, check out more of our work covering quality and accreditation! 

With all the regulatory and reimbursement changes occurring in our industry at an ever-increasing rate, one thing is for certain: Your organization is not unique.

When speaking to organizations, I often hear things like, “Well, we don’t have the resources that the university hospital has” from community hospitals and then the university hospitals will say things like, “We aren’t as nimble as those community hospitals.” It’s frustrating and ultimately self-defeating. It creates a semi-plausible excuse that permits low performance, and it must be stopped.

I see it in everything from patient experience, core measures, throughput, and profitability. “We are unique,” “Our patients are sicker,” “Our payer mix is bad,” “We have more psych patients,” “We have more beds,” and the list goes on and on.

The reality is that all hospitals are facing the same issues at the same time and those that are top performing do not allow themselves to take this mindset. Simply put, none of our organizations is unique.

Imagine if we took that same mentality when it came to treating patients. If clinicians second-guessed every cardiac rhythm that came across a monitor, think of the conversations between cardiologists. “Maybe ventricular fibrillation is good for this patient. I mean it’s not like he looks like the last guy who had it.” It is an absurd example that makes my point.

Hospitals can argue about the metrics and the systems in place for a millennium, doctors can debate the efficacy of the data points and whether things are “good measure” and that is healthy. However, the reality is just because you don’t like it doesn’t mean you are allowed to not do it or succumb to the idea that it is an impossible goal based solely on the fact that “your hospital is different.”

The metrics in healthcare are to create as level a playing field as there can be while trying to ensure high-quality care at reasonable or decreasing costs. Is it perfect? No, it is not, but it’s a start and part of the calling of being in medicine.

Clinicians don’t come to work expecting to provide bad care. In all my experience, I have never met a clinician that had that motive. The excuses come when compared to similar organizations and not performing well. The excuses come from everywhere rather than focusing on the core issue of poor performance.

Top-performing entities move through the Kübler-Ross 5 stages of grief faster and focus on the acceptance. Once that happens and the organization gets past its uniqueness, true organizational change can begin.

When dealing with an issue that causes your organization to lament how different it is to the standard, try these techniques. Allow the leaders an unadulterated complain fest. It’s a period of time not to last more than a day where complaining and feeling sorry for yourself is encouraged, get it all out on the table. It’s unfair, they don’t like us, and so on. Get all the negativity out in one moment of time. Grieving is natural and needs to happen. People in organizations need to feel like they are being heard and empathized with.

Next, require all the leaders to come up with short action plans that will move the organization forward. It does not have to be a total change in how you do business, but it starts the momentum going in the correct direction. This is not easy, and requires a substantial amount of effort. It shifts the energy in a positive direction and is the first essential step toward making a positive difference. Finally, reward and recognize people and departments making the gains, and the ones that are putting forth a strong effort.

The data is never perfect. There will always be concerns about percentiles, and comparative measures for everything we do in healthcare. Accepting it and focusing on the care each patient receives every time is the single most powerful curative tool an organization has in its armory. Doing the right thing, the right way, for the right reasons will always be correct, regardless of what the metric is.

Editor’s note: Patrick Pianezza, MHA, has worked with the Studer Group and Johns Hopkins Hospital. In his most recent role, Pianezza’s work drove organizational performance in Hospital Consumer Assessment of Healthcare Providers and Systems. to an all-time hospital best in the 90th percentile. He can be reached at ppianezza@gmail.com.

Maintaining security during a Joint Commission survey

Facilities often have questions when surveyors come to visit. Some of the most frequently asked questions involve security and confidentiality, how to make sure surveyors see what they need to without violating hospital safety. In the July issue of Perspectives, The Joint Commission answered some of the most frequent questions.

Access to Computer Systems: Surveyors will sign security agreements with the facility in order to receive a user ID and password to access a computer system (for example, in order to review policies and medical records) if the facility requires it.

Confidentiality Agreements: If a facility wants surveyors to sign a confidentiality agreement, then that agreement has to be sent to the Joint Commission Central Office for review before the survey.

That said, asking surveyors or reviewers to sign an agreement is unnecessary, according to The Joint Commission. Accreditation and certification contracts, plus the Business Associate Agreement between The Joint Commission and the facility, already bind individual surveyors and reviewers to confidentiality.

Security Sign-In: If a facility requires visitors to sign into the building as part of the organization’s regular security process then surveyors will sign in too. In lieu of asking to copy a surveyor’s driver’s license, Joint Commission badge, or any other form of ID, facilities should refer to surveyors’ pictures and biographies on the Joint Commission Connect™ secure extranet site.

Videotaping Survey Activities: Videotaping or recording any part of a survey or review, including the exit conference is forbidden.

Joint Commission: Six EPs deleted for Critical Access Hospitals

Later this year The Joint Commission will delete six elements of performance (EPs) from the Distinct Part Unit (DPU) standards for Critical Access Hospitals. The accreditor says this will streamline the standards and the changes go into effect on September 24, 2017.

The deleted EPs are from the Medical Staff, Leadership, and Rights and Responsibilities of the Individual chapters. You can read all six standards at the Joint Commission website. Those with questions can contact Laura Smith, MA, Joint Commission project director at lsmith@jointcommission.org.

https://www.jointcommission.org/standards_information/prepublication_standards.aspx

The Focused Standards Assessment tool goes temporarily offline in July

The Focused Standards Assessment (FSA) tool on The Joint Commission’s Intracycle Monitoring (ICM) Profile will be taken offline from June 30, (5:00 PM Central Time) through  July 10 (9:00 PM CT)

The FSA is an interactive standards self-assessment tool for facilities that lists the standards applicable to each organization’s accredited programs and services. An extension due date will be set to Monday, July 24, 2017 for facilities with an ICM submission date between July 1 and July 10.

https://www.jointcommission.org/facts_about_the_intracycle_monitoring_process/

(TBT) Checklists: Easy to take for granted

Editor’s Note: This is a free Briefings on Accreditation and Quality article from yesteryear! If you like it, check out more of our work covering quality and accreditation! 

Checklist

In any organization’s quality department there lives a nefarious, ever-present beast. It’s usually in paper form and comprises a list of seemingly innocuous phrases or sentences and to the far right is the “checkbox.” It’s easy to become disdainful of checklists, but the reality is they play an important role.

I’m sure we’ve all heard some of the complaints.

Often these checklists include things such as, “Are there any wall penetrations?” or “Do staff know where the closest fire extinguisher is?” These questions often can be grating to hospital administrative teams because it’s “one more thing” they have to worry about and it can be frustrating during surveys to be “caught” on things that “don’t matter” in the clinical realm.

I hear the reactions to such mundane questions all the time, “Yes, it’s important but we are more concerned with medication errors, fall rates, sentinel events. Who has time to check for escusions? Shouldn’t there be a weighting scheme to it all?”

The reality is that checklists are important, and they’re focused on patient safety and care. Escusion plates and wall penetrations exist for those unthinkable times when hospitals catch fire, a rare and devastating event. When fires occur, though, those safety measures limit the impact fire and smoke can have to the most vulnerable of populations. The same can be said about medication errors and sentinel events: they are rare and potentially devastating. The measures organizations take to prevent harm must be all-encompassing.

When being confronted with checkboxes, do not put them off as non-mission critical, or roll your eyes at the people who bring them to your attention. These are safety measures, clear and simple, that must be addressed with the same type of immediacy.

Moreover, the idea of checkboxes must become incorporated into the everyday fabric of hospital operations and not delegated to one person doing safety rounds once per quarter. Educate frontline leaders to remain abreast of their own areas or have them round on other departments to keep a fresh set of eyes on the organization. Have it be part of the expectation as opposed to being something extra you ask of your leadership team.

Healthcare isn’t easy; it takes a concentrated effort to remain diligent. Healthcare exists to take care of people at their most vulnerable, which means being vigilant about the checkboxes, too.

Editor’s note: Patrick Pianezza, MHA, has worked with the Studer Group and Johns Hopkins Hospital. In his most recent role, Pianezza’s work drove organizational performance in HCAHPS to an all-time hospital best in the 90th percentile. He can be reached at ppianezza@gmail.com.

CMS releases interpretive guidance on emergency preparedness

CMS unveiled interpretive guidance and survey procedures on its emergency preparedness rule. The emergency preparedness rule went into effect last November. The interpretive guidelines apply to all 17 provider and supplier types.

Read the full memo here. 

Joint Commission Updates on HAI-related National Patient Safety Goal on HAIs

The Joint Commission has revised several of its requirements for National Patient Safety Goal (NPSG) 7, which focuses on the issue of healthcare-associated infections (HAI). The revisions go into effect on January 1, 2018, and apply to hospitals, critical access hospitals (CAH), and nursing care centers (NCC).

NPSG 07.03.01: Multidrug-resistant organisms (MDRO)

•    NCCs are now expected to follow the MDRO NPSG.07.03.01. Nursing homes experience a high rate of MDROs such as methicillin-resistant staphylococcus aureus (MRSA) and vancomycin-resistant enterococci (VRE). This was particularly concerning because nursing home patients were bringing MDROs to hospitals and vice versa.
•    The Joint Commission is adding a new infection, carbapenem-resistant enterobacteriaceae (CRE) to NPSG.07.03.01. This change applies to hospitals, CAH, and NCCs.

NPSG 07.04.01: Central line-associated bloodstream infections (CLABSI)

•    The EPs for the NPSG 07.04.01 have been reordered.
•    EP 11 was revised to specify the use of chlorhexidine for antiseptic skin preparation.
•    For both NPSG 07.03.01 and NPSG 07.04.01, facilities are now allowed to determine how frequently they need to re-educate staff and licensed independent practitioners on MDROs and CLABSIs.