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Joint Commission updates LS, EC chapters

Three revisions to The Joint Commission’s Life Safety and Environment of Care chapters will go into effect on March 11. The respective changes add more clarity to requirements regarding non-rated doors, environmental features of anesthetics areas, corridor door latch. However, not all changes apply to all the same programs, so you should check to see which ones impact you. The changes are intended to improve alignment with CMS regulations. You can find the prepublication standards below:

•    Ambulatory Health Care
•    Behavioral Health Care
•    Critical Access Hospital
•    Hospital
•    Nursing Care Center
•    Office-Based Surgery
•    Home Care

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Dear BOAQ & PSMJ Subscribers,

We’re making much needed overhauls to BOAQ and PSMJ’s website this year. But before that happens, we want to hear your thoughts on how we can improve in 2018. Please share your feedback by taking this quick survey:

BOAQ Survey: https://goo.gl/kCPSER

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Your responses are invaluable to us and if you have ideas or suggestions for us, send them our way!

Brian Ward, Associate Editor

CMS Inpatient-Only List: Preparing for Critical Changes in 2018

Each year CMS revises its inpatient-only list of approximately 1,700 procedures. The most notable changes to the list that went into effect January 1, 2018 include the addition of coronary revascularization during an acute myocardial infarction and the removal of total knee arthroplasty. Knee replacements, according to CMS, now may be performed on either an inpatient or an outpatient basis.

These list revisions are vital for hospitals to track and take into account. For example, “removing knee replacement surgery from the inpatient-only list is going to cause major changes for hospitals and physicians who do these procedures,” says Kurt Hopfensperger, MD, JD, vice president of compliance and physician education at Optum Executive Health Resources. Moving forward, they will have to apply utilization review processes more rigorously.

Keeping pace with change

Hospitals that closely follow and interpret the CMS inpatient-only list benefit in several ways. The list follows evidence-based medicine and looks at the average length of stay, as well as typical risks and comorbidities, for each procedure. Thus, correctly placing a patient in inpatient status is a clinically good decision, and it helps organizations stay in compliance with Medicare rules.

Hospitals also protect revenue by making sure every patient undergoing a procedure on the inpatient-only list has a correct status determination, says Hopfensperger. As procedures drop off of the list, hospitals must do the same to avoid potential revenue integrity issues. “You want to make sure you are appropriately compensated for those patients who are high risk or who require a longer stay in the hospital,” he notes.

Continued at Health Leaders Media

CMS: Physicians and nurses can text, just not medical orders

CMS is clearing up recent confusion on what medical providers can text each other. The agency confirmed care team members are allowed to text patient information over a secure messaging app. However, texting medical orders is still verboten.

Some providers have taken to secure messaging platforms as a way to contact providers during emergency, to consult on medical cases, or send photos of the patient. The confusion started on December 18 after an article by the Health Care Compliance Association (HCCA) cited emails CMS had sent to two hospitals saying that “texting is not permitted.” People thought this meant “texting is never permitted” instead of “texting medical orders isn’t permitted.”

“Secure texting is an integral part of a community platform for organizations,” one manager told the HCCA. “If you pull secure texting out of that pathway, you have disrupted a huge chain of communications that will have a broader effect.”

Luckily, CMS explained this wasn’t the case in its newest S&C memo, and that it knows the value of instant messaging in the workplace.

“CMS recognizes that the use of texting as a means of communication with other members of the healthcare team has become an essential and valuable means of communication among the team members,” wrote David R. Wright, director of CMS’ Survey and Certification Group. “In order to be compliant with the CoPs or CfCs, all providers must utilize and maintain systems/platforms that are secure, encrypted, and minimize the risks to patient privacy and confidentiality as per HIPAA regulations and the CoPs or CfCs. It is expected that providers/organizations will implement procedures/processes that routinely assess the security and integrity of the texting systems/platforms that are being utilized, in order to avoid negative outcomes that could compromise the care of patients.”

CMS and Joint Commission change hospital eligibility requirements

Both organizations have changed their expectations on the defintion of a hospital. CMS’s new S&C Memo 17-44-Hospitals says that surveyors will use average daily census (ADC) and average length of stay (ALOS) data to determine if the hospital is primarily engaged in providing services to inpatients, and “a hospital must have inpatients at the time of survey in order for surveyors to directly observe the actual provision of care and services to patients, and the effects of that care” to determine if the facility is meeting the Conditions of Participation (CoP) in Medicare.

In addition, both CMS and The Joint Commission say that hospitals will need at least two active inpatients on site for an accreditation survey to be done. This change is effective immediately.

Joint Commission to Increase Hand Hygiene Focus

The Joint Commission will soon be scrutinizing hand hygiene more closely.

Starting in 2018, if a surveyor from the accrediting organization witnesses an individual who directly cares for patients fail to perform required hand hygiene, the person’s healthcare organization will receive a citation under The Joint Commission’s Infection Prevention and Control (IC) standard IC.02.01.01, element of performance 2, which requires organizations to use precautions such as hand hygiene to reduce infection risk. In addition, healthcare facilities must meet National Patient Safety Goal (NPSG) 07.01.01, which requires them to implement and maintain a hand hygiene program.

The change, announced Thursday, will go into effect on January 1, 2018.

Previously, healthcare organizations were not penalized for an individual failure to perform proper hand hygiene if that organization had an otherwise compliant hand hygiene program. But under this change, if a surveyor spots an individual who does not properly wash his or her hands, the surveyor will cite the organization for a deficiency resulting in a Requirement for Improvement.

In 2004, TJC first required all healthcare organizations to implement hand hygiene programs and keep track of individual performance within that plan. Proper hand hygiene, of course, is critical for preventing infections in a healthcare setting.

2018 version of “Patient Safety Systems” Chapter available

The Joint Commission has released the most recent versions of it’s PS Chapter for hospitals, nursing care centers, critical access hospitals, behavioral healthcare centers, laboratories, and more.

Main manual for CMS’ hospital Interpretive Guidelines updated

For the first time in two years, the online version of CMS’ State Operations Manual, Appendix A — also known as SOMA by some — is showing it has been revised!

The date on the appendix, which offers CMS surveyors Interpretive Guidelines to follow when implementing the hospital Conditions of Participation (CoP), is now Nov. 17, 2017. The last revision had been in November 2015.

The most recent update appears to mainly reflect changes to how CMS defines a hospital for survey. Those changes were announced in S&C memo 17-44-ALL-Hospitals.

And more changes should be on the way, especially in light of the recent publication of a new S&C memo on ligature risk. Among other things, S&C 18-06-Hospitals memo notes changes under Tag A-0701 that appear to delete references to emergency preparedness — now under their own set of CoP outlined in Appendix Z— and adds guidelines for checking out other physical safety concerns along with ligature risk within the environment of care.

CMS Emergency Prep rule is now enforceable by surveyors

It’s finally here.

CMS’ new Emergency Preparedness rule went into effect on Wednesday, November 15, which means surveyors can now cite facilities who aren’t compliant with the rule’s requirements.

The rule closes gaps in CMS’ previous regulations, such as requiring facilities to have contingency planning in place, emergency response training for staff, and communicate and coordinate their emergency plans with other hospitals and government agencies at the tribal, local, regional, state, and federal levels. Facilities have had over two years to prepare for this rule, and the agency has already said it won’t be accepting excuses for noncompliance.

While the rule itself is new, Steve MacArthur, a safety consultant at The Greeley Company in Danvers, Massachusetts, says that a lot of the new requirements are things that hospitals should have already been doing.

“I suppose I should stop and say that while this rule is new to the ‘marketplace,’ there are really no new concepts contained therein,” he says. “This may provide some guidance for CMS surveyors as they drill down on organizational preparedness activities. But none of this is groundbreaking or in any way representative of a change in how hospitals have done, and will continue to do, business. [It’s] just another set of official ‘eyes’ looking through the compliance microscope.”

Resources

BOAQ

Webinar: Suicide Prevention in Hospitals: Reduce Risk and Comply With Joint Commission Requirements

Presented on: Tuesday, November 21, 2017, 1:00-2:30 p.m. EST
Speaker: Ernest E. Allen, ARM, CSP, CPHRM, CHFM
Program Level: Intermediate 
Registration: http://hcmarketplace.com/suicide-prevention-in-hospitals

Summary:  Hospitals are continually working to reduce the risk of patient suicide in their facilities, but the problem persists. The Joint Commission has placed particular emphasis on reducing suicide risk, including a National Patient Safety Goal and a recent Sentinel Event Alert.

In this webinar, former Joint Commission surveyor Ernest E. Allen, ARM, CSP, CPHRM, CHFM, will explain how hospitals can identify and reduce suicide risks and improve compliance with Joint Commission requirements.

At the conclusion of this program, participants will be able to:

  • Identify suicide risks in hospitals
  • Be able to reference applicable Joint Commission standards and Sentinel Event Alerts
  •  Learn prevention methods to help lower suicide risk