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Financial Penalties in Hospital Readmissions Linked to Higher Mortality

By John Commins

Using financial penalties to reduce hospital readmissions has been linked to a significant rise in post-discharge mortality for patients with heart failure and pneumonia, a new, large-scale study shows.

In an article published last week in JAMA, researchers at Beth Israel Deaconess Medical Center examined the unintended consequences of the Hospital Readmissions Reduction Program, a component of the Affordable Care Act that began in 2012.

Under the HRRP, hospitals have faced financial penalties for higher-than-expected 30-day readmissions for heart failure, pneumonia, and heart attack. Nearly $2 billion in penalties have been imposed on hospitals by the HRRP since 2012.

“Policy makers had observed that hospital readmissions for these conditions were high and that many of these readmissions were potentially avoidable,” study first author Rishi Wadhera, MD, said in comments accompanying the study.

To one extent, HRRP worked. Hospitals made changes to avoid readmissions rates among Medicare beneficiaries and readmissions rates for those three conditions fell. However, a growing chorus of researchers and physicians have raised concerns that the drop in readmissions has led to increased mortality.

“Some policy makers have declared the HRRP a success because they believe that reductions in readmissions solely reflect improvements in quality of care,” Wadhera said. “But the financial penalties imposed by HRRP may have also inadvertently pushed some physicians to avoid readmitting patients who needed hospital care, or potentially diverted hospital resources and efforts away from other quality improvement initiatives.”

The researchers examined more than 8 million Medicare fee-for-service hospitalizations from 2005 to 2015. They evaluated mortality among Medicare patients who were hospitalized for heart failure, a heart attack or pneumonia before the establishment of HRRP in 2012.

Then, they compared those trends to determine if there was a significant change in mortality after the HRRP was announced in 2010 and then after the policy was implemented in 2012.

“Even though 30-day post-discharge mortality was increasing among patients hospitalized for heart failure in the years before HRRP was established, we found that the rise accelerated after the policy was implemented,” said co-corresponding author Changyu Shen, PhD, senior biostatistician in the Smith Center for Outcomes Research in Cardiology at BIDMC.

The team also found mortality rates among patients with pneumonia were stable prior to HRRP, but began increasing after the HRRP. “Whether the HRRP is responsible for this increase in mortality requires further research, but if it is, our data suggest that the policy may have resulted in an additional 10,000 deaths among patients with heart failure and pneumonia during the five-year period after the HRRP announcement,” Shen said.

Readmissions has become a controversial topic among physicians and researchers, with some studies indicating that it leads to a rise in mortality, and other studies indicating that HRRP has improved care delivery.

study published last month in the American Journal of Medicine showed that HRRP is having a positive impact beyond Medicare beneficiaries and beyond the medical conditions targeted in the initiative.

The primary implication of the research is that health systems and hospitals have made broad improvements to quality of care rather than changes aimed only at Medicare beneficiaries treated for the conditions targeted by HRRP.

EPA announces final rule to set new standards on hazardous waste pharmaceuticals

By A.J. Plunkett

Get the word out to everyone in your organization who handles hazardous waste pharmaceuticals that soon, flushing or rinsing those drugs down a drain into the sewers will be specifically prohibited by the EPA.

That’s harder. On the easier end, you can tell your nurses that the packaging for a patient’s nicotine patch, gum, or lozenge might soon go straight into the regular trash—as long as it is FDA-approved as an over-the-counter nicotine replacement therapy and your state signs off on the exemption of the packaging as hazardous waste under the federal Resource Conservation and Recovery Act (RCRA).

Those are just some of the changes you can expect in handling hazardous waste pharmaceuticals at your facility or business now that the Environmental Protection Agency has finalized its long-awaited “Management Standards for Hazardous Waste Pharmaceuticals and Amendment to the P075 Listing for Nicotine.”

The rule creates a new subpart P under RCRA that manages hazardous waste pharmaceuticals across a wide array of industries, including hospitals, physician offices, ambulatory care, and other providers who “distribute, sell, or dispense pharmaceuticals, including over-the-counter pharmaceuticals, dietary supplements, homeopathic drugs, or prescription pharmaceuticals,” according to the EPA.

The rule has benefits

Under the provision, in general, the EPA says hospitals

  • will no longer have to count hazardous waste pharmaceuticals in calculating generator status (those drugs often sent facilities into large-quantity generator, or LQG, status);
  • can collect and manage hazardous waste pharmaceuticals from satellite facilities as long as they are under the same business umbrella;
  • can accumulate the drugs on site without a RCRA permit for up to 365 days, an increase of 275 days over current regulations;
  • but will have specific basic training requirements associated with those managing hazardous waste pharmaceuticals.

Experts in hazardous waste management in healthcare hailed the ruling as a breakthrough in finally putting a regulatory focus on the need to better control the amount of pharmaceuticals going into the environment while easing up on confusing and often unnecessary restrictions that cost both money and cause aggravation in the healthcare sector.

Another big plus for hospitals in the final rule is that drugs considered controlled substances are no longer considered hazardous waste, erasing concerns about competing regulations between the EPA and the Drug Enforcement Agency.

The rule’s provisions will become effective within six months of its publication in the Federal Register. While the rule has been signed and is expected to be published in the Federal Register before the end of December, there is still the question of when states with their own RCRA-authorized programs will adopt the new regulations.

CMS examines possible Conflicts of Interests in Accreditation Organizations

By John Commons 

Federal regulators are asking for public comment and cite ‘disparity rates’ between state audits and AO reviews of healthcare facilities.

The Centers for Medicare & Medicaid Services is asking questions about potential conflicts of interest between Medicare accrediting organizations and the healthcare facilities they monitor.

“We are concerned that the practice of offering both accrediting and consulting services–and the financial relationships involved in this work–may undermine the integrity of accrediting organizations and erode the public’s trust,” CMS Administrator Seema Verma said in a media release.

“Our data shows that state-level audits of healthcare facilities are uncovering serious issues that AOs have missed, leading to high ‘disparity rates’ between the two reviews,” Verma said.

“We are taking action across-the-board to ensure the quality and safety of patient care through strengthened CMS oversight of AOs, and today’s RFI is a critical component of that effort.”

The query likely will include an examination of The Joint Commission, the nation’s largest hospital accrediting organization. In a media statement, The Joint Commission said it is reviewing CMS’s requests for comment, but said it is confident in the integrity of the “firewall” between its consulting and accrediting divisions.

“The Joint Commission recognizes the importance of assuring the integrity of the accreditation process, which we accomplish by prohibiting any sharing of information about consulting services for individual organizations with anyone involved in accreditation,” the statement read.

“The Joint Commission as an accrediting organization and Joint Commission Resources, Inc. as a provider of education and consulting services are two separate organizations. The Joint Commission enterprise has long-standing firewall policies, practices and procedures in place that assure that this goal is achieved,” the statement read.

TJC anticoagulant NPSG updated

The Joint Commission (TJC) announced revisions to its anticoagulant therapy National Patient Safety Goal (NPSG) on December 7. NPSG 03.05.01 has eight new Elements of Performance (EPs).

All the changes are listed in R3 Report 19 and will take effect on July 1, 2019. The update applies to all TJC accredited hospitals, critical access hospitals, nursing care centers, and medical centers accredited under the ambulatory health care program.

The update requires impacted facilities too:

  • Have evidence-based protocols for starting, continuing, reversing, and testing anticoagulant treatment.
  • Establish processes for responding to adverse drug events
  • Educate patients and their families on anticoagulant treatment
  • Use programmable IV pumps when administering heparin
  • Use pre-measured products to limit dosing errors

More on this topic will be in future editions of Briefings on Accreditation and Quality

Joint Commission Revises Suicide Prevention National Patient Safety Goal

The Joint Commission (TJC) this week announced revisions to its suicide prevention National Patient Safety Goal (NPSG) to improve quality and safety of care for patients treated for behavioral health conditions and who are identified as high-risk for suicide.

Effective July 1, 2019, NPSG.15.01.01 (Reduce the risk for suicide) is applicable to all Joint Commission-accredited hospitals and behavioral healthcare organizations. The revised requirements are based on more than a year of research, public field review, and analysis with multiple panels convened by TJC and representing provider organizations, suicide prevention experts, behavioral facility design experts, and other key stakeholders.

The requirements are detailed in a new R3 Report published by TJC. The NPSG encompasses seven elements of performance (EP) that TJC will use to review hospitals and behavioral healthcare organizations during accreditation surveys. This is an increase over the three EPs in the current version of NPSG.15.01.01 (Identify individuals at risk for suicide).

“The science of suicide prevention has really advanced over the past few years, including better tools for screening, assessment of suicidal ideation, identification of environmental hazards in health care facilities, and methods to prevent suicide after discharge,” said David W. Baker, MD, MPH, FACP, executive vice president, TJC’s Division of Health Care Quality Evaluation, in a release. “We had not updated the NPSG since its original release in 2007. This revised version and the accompanying resource compendium will more robustly support health care organizations in preventing suicide among patients in their care.”

The new and revised requirements cover:

  • Environmental risk assessment and action to minimize suicide risk
  • Use of a validated screening tool to assess at-risk patients
  • Evidence-based process for conducting suicide risk assessments of patients screened positive for suicidal ideation
  • Documentation of patients’ risk and the plan to mitigate
  • Written policies and procedures addressing care of at-risk patients and evidence staff are following them
  • Policies and procedures for counseling and follow-up care for at-risk patients at discharge
  • Monitoring of implementation and effectiveness, with action taken as needed to improve compliance

Suicides and drugs cut U.S. life expectancy

U.S. life expectancy dropped to 78.6 years in 2017, according to the CDC, with the main culprits of the decline being drug overdoses and suicides. The research shows that a baby born in 2017 had 1.2 months shaved off its life expectancy compared to one born 12 months earlier.  This is the third year in a row where life expectancy has declined.

“Life expectancy gives us a snapshot of the nation’s overall health and these sobering statistics are a wakeup call that we are losing too many Americans, too early and too often, to conditions that are preventable,” CDC director Robert Redfield, MD said in a public statement.

The CDC release three reports on November 28—one on suicide mortality, one on drug overdose deaths, and one on mortality overall. And while healthcare organizations have been working hard to treat, prevent, and respond to these issues, the CDC’s numbers show that more work is to be done.

In 2017 there was a grand total of 2.8 million deaths— 69,000 more than the prior year and the most deaths in one year since the government started recording over a century ago. Of those deaths 70,237 were due to drug overdoses and 47,000 were suicides.

Drug overdoses

The spike in drug addiction and deaths was rapid and devastating for many. Drug overdose deaths have increased 16% per year since 2014 says the CDC. And between 2016 and 2017 that number grew 9.6% to 21.7 deaths per 100,000. So far 20 states and the District of Columbia have overdose death rates higher than the national average, and eight have rates comparable to the national average.

Drug Overdoses Statistics

  • The rate of drug overdose deaths in 2017 was 21.7 per 100,000. That’s 3.6 times what it was in 1999 (6.1).
  • While drug use increased in all age groups, overdose rates were much higher for those aged 25–34 (38.4 per 100,000), 35–44 (39.0), and 45–54 (37.7)
  • Men are more likely to die of an overdose than women
  • The number of drug overdoses caused by synthetic opioids increased 45% between 2016 and 2017.

Suicide

As we’ve written about before, suicide has been the 10th leading cause of death since 2008, with suicide rates on the rise. There’s no single identifiable cause for the increase, though some suggest better reporting, a lack of accessible mental healthcare, economic stresses, and social isolation have played a role.

CMS and other healthcare organizations have made efforts in recent years to reduce ligature risks and patient suicides—new ligature regulations, resources and training, etc. Just on November 28, The Joint Commission released a new R3 report on improving suicide care.

Additional research has shown that many suicide victims visit a healthcare provider in the months leading up to the act. And screening programs, ligature risk checklists for patient rooms, and safety planning for after discharge have been shown to be effective.

Suicide Statistics

  • The CDC report says that between 1999 and 2017 the age-adjusted suicide rate rose 33%, up to 14 deaths per 100,000 from 10.5
  • In 2017 47,000 people died by suicide and 1.3 million made a suicide attempt
  • The number of suicides committed by women (9.7 per 100,000) is lower than for men (22.4). However, suicide rates for women have been growing rapidly and is up 53% since 1999
  • Suicide rates increased for men of every age except those aged 75 and older. However, men in this age group still commit suicide far more often than any other (39.7)
  • Suicides are more common in rural counties (20) than in urban ones (11.1). Between 1999 and 2017, suicide rates for rural areas increase 53%. Meanwhile the rate only grew 16% for urban areas.

 

Use TRAIN matrix to triage patients in mass evacuation

By  A.J. Plunkett (aplunkett@h3.group)

Modify the Triage by Resource Allocation for IN-patient (TRAIN) matrix to suit your facility’s needs in case of a mass evacuation.

Developed by the Lucile Packard Children’s Hospital at Stanford in Palo Alto, California, the matrix is combined with the hospital’s electronic medical records system to allow quick assessment of patients and the types of transportation needed to evacuate them to safety. The matrix is also available in PDF form online (see Resources).

“Caregivers have prompt access to a fully automated report that categorizes patients in terms of their specific needs, such as what types of intravenous medication they receive, whether they’re on ventilators or whether they need an intensive care unit bed,” according to the Stanford Medicine News Center in announcing the program in 2015.

Hospitals across California and other areas, including the Sharp Healthcare system in San Diego, have modified the matrix for use as part of their all-hazards preparation for emergencies, including wildfires (see p. 1).

According to a toolkit by Lucile Packard, the matrix allows a hospital to:

Be able to quickly assess and accurately request the right resources from the emergency operations center.

  • Streamline communication with a common code.
  • Implement a standardized and automated inpatient hospital evacuation triage system with minimal impact to workflow.
  • Increase awareness and disaster preparedness across the institution.

System is color-coded

“TRAIN helps determine what vehicles and equipment are necessary for continuous patient care during a crisis event and simplifies communicating patients’ needs to other hospitals or command centers coordinating transfers. For instance, TRAIN helps the hospital decide whether cars or vans are needed, how many ambulances or specialty transports are required and even how many IVs and ICU beds should be in place at the receiving facility,” according to the news center article.

“Under TRAIN, patients are assigned a color, with red designated for patients in critical condition. These patients need specialized transport, such as an ambulance or military vehicle, in addition to life-support equipment, such as ventilators and multiple intravenous drips for medication. TRAIN allows care teams to communicate the medical needs of this patient, as well as the severity of his or her condition, with a single word: red,” according to the news center. “In comparison, patients marked with blue tags are considered stable and can be transported in a car or bus, without any specialized equipment.”

The toolkit is available through HHS Assistant Secretary for Preparedness and Response’ Technical Resources, Assistance Center, and Information Exchange (ASPR-TRACIE) collection of evidence- and experience-based resources for emergency management. It is part of the Healthcare Facility Evacuation/Sheltering collection of resources.

Resources

Before the Plane Crash

In January 2009, all eyes were focused on the Hudson River after a plane flying out of New York’s LaGuardia Airport struck a flock of geese and crash landed in the river. Thanks to fast acting by the pilots, all 155 passengers survived, with few major injuries, in the disaster dubbed “the Miracle on the Hudson.” However, trouble emerged in the aftermath when people tried to find out which hospital their loved ones had been sent to.

“Some of the patients went to New York and some went to New Jersey. And because of HIPAA laws, it was very difficult for airline authorities to get the names of who was where,” says Sharon Carlson, RN, director of Emergency Preparedness at Sharp HealthCare in San Diego, CA. “As a family member you can imagine your terror knowing that your loved one was in a plane crash and not knowing where they are. That’s a big issue we always have, reunifying people after a disaster.”

“Because of [the Miracle on the Hudson] we decided in San Diego that we needed to make relationships before an event happens,” she adds. “Get to know each other, work together, know each other by first name, know each other’s number.”

Using the lessons learned from the Hudson, Carlson and her health system joined a disaster partnership with their local airport, San Diego International (SAN.) The airport has been growing steadily over the past decade, with over 22 million people flying in and out of it in 2017. The airport partnership was started originally in 2010 by UC San Diego Health system.

The transportation administration requires SAN to conduct major disaster drills periodically. As part of the partnership, Sharp Healthcare is included in those drills, Carlson says. They practice their communication process once a year to ensure everybody is on the same page and that there’s been no changes in the contact information.

“We have a partnership with the airports, so they know who to contact at our hospitals,” she says. “And we’ve sent it through our compliance and legal departments, they know what kind of information we can give them.”

In the event of a plane crash or disaster, airport staff have a list of hospital contacts so they can reach out, then read names off the plane’s manifest and the hospital will be able to tell them which people on the list are there or not.

“We don’t give out conditions, injuries, or illnesses,” she says. “We just say if they’re here or not. Because the airline is wanting to tell the family members ‘ok, go over here, your loved one is at this hospital.’”

Checklist: Re-opening after a disaster

On October 10, Hurricane Michael made landfall in Florida, forcing two Florida hospitals to evacuate more than 300 patients due to building damage. On the same day, The Joint Commission (TJC) published a new Emergency Management Health Care Environment Checklist on its website, which helps healthcare organizations reopening their facilities after a disaster.

While the timing of these two events were coincidental, providers should to take time to go over the checklist and their emergency plans in general.

A TJC workgroup developed the checklist at the request of the U.S. Department of Health & Human Services’ Office of the Assistant Secretary for Preparedness and Response. It aligns with the accreditor’s Emergency Management standards, covers both clinical and environmental issues, and addresses crucial post-disaster elements that need addressing before reopening. It should be noted that the checklist isn’t hurricane-specific.

Jim Kendig, TJC’s field director of Life Safety Code surveyors, says it’s critical that hospitals customize the checklist for their needs by examining the relationships they establish in the community, and at the regional and state levels.

“For example, in Florida, a county Office of Emergency Management met with utilities and other emergency support functions to determine hospitals and PSAPS [public safety answering points] are the first to receive power restoration,” he says. “Establishing an unidentified victims process is also a good start, as it the ability to share that information within an hour of a disaster event.”

“The Joint Commission’s Emergency Management Committee continues meeting with organizations after disaster events to glean important information to share with the field through our Environment of Care News and ongoing communications,” he adds. “This also give us the opportunity to ensure that our standards and elements of performance are effective and contemporary.”

WEBINAR – Preliminary Denial of Accreditation: Actions, Recovery, and Prevention

Presented on: Wednesday, December 12, 2018 |1:00-2:30 p.m. EST

Presented by: Kurt A Patton, MS, RPh.\

Register: https://hcmarketplace.com/preliminary-denial-of-accreditation

When the Joint Commission hands out a Preliminary Denial of Accreditation (PDA) decision, you have a small window to set things right. If you can’t get your hospital to band together to fix the problem, a PDA can cost you your accreditation, reputation, and ability to treat patients. And that’s before CMS gets involved.

Join former Joint Commission surveyor Kurt Patton, MS, RPh, this August as he reviews how you might get a PDA, what you can do about it, and what surveyors will expect during their follow-up.

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

  • Contest a PDA decision
  • Develop a corrective action plan in less than 10 days
  • Focus and prepare for the 60-day PDA follow-up survey
  • Get organized and keep staff and leaders accountable for deadlines
  • Prioritize the most difficult performance-based findings in preparation for the 60-day follow-up survey

Agenda

  • What to do if you think an “immediate threat” or “immediate jeopardy” situation is pending
  • What to do if your report is posted and you are surprised to learn it is PDA
  • How to develop a strategy to dig your way out of this situation
  • How to do a corrective action plan in contrast with an Evidence of Standards Compliance (ESC)
  • How to prepare for the most difficult survey you’ve ever experienced: the 60-day PDA follow-up survey
  • Live Q&A