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Joint Commission revises ‘notification of organization changes’

The Joint Commission has updated its “notification of organization changes” policy for accredited facilities.

Previously, organizations had 30 days to notify The Joint Commission that a significant change had been made. The updated policy now requires organizations alert the accreditor the moment the changes are confirmed (i.e., once leadership has decided to move ahead with a change and has created a timeline for completion).

The updated regulations go into effect on October 1. The changes apply to all Joint Commission-accredited programs. Click here to read the revised policy. 

Surgeons rail against reporting every 10 minutes to CMS

A proposed CMS change to the 2017 Medicare Physician Fee Schedule will require surgeons document and report data every 10 minutes for new billing codes (G-codes). The penalty for not submitting this data is 5% of a facility’s Medicare reimbursement.

CMS’ plans to phase out 10-day and 90-day global surgery packages over the next two years. Instead, the fee schedule would have a zero-day package, with all preoperative and postoperative care bundled together on the day of the surgery. Surgeons would receive a lump sum for their work and bill CMS on a piecemeal basis for care provided before and after the day of surgery.

Surgeons and medical groups have loudly decried the move, calling it impractical, untested, and a huge waste of time and money. In one survey of 7,000 surgeons, 37% said the new codes will cost them between $25,000 and $100,000 per surgeon.  Fifteen percent said it would cost them over $100,000 in hiring scribes to keep up with documentation, updating electronic health records, and having less time for patients.

Respondents also claimed that if the standards go into effect:
•    85.9% will have to modify EHR and billing systems
•    88.8% of physicians and 75.7% of staff will lose time tracking and processing global surgery information into EHR and billing systems
•    82.8% will have to develop new tracking and collecting methods for global surgery data
•    46.4% will need to buy more technology (such as handheld devices or stopwatches) to document time spent providing global surgery services

So far, the American College of Surgeons (ACS), the American Association of Orthopaedic Surgeons, the American Association of Neurological Surgeons (AANS), the Congress of Neurological Surgeons (CNS), the American Medical Association, and several others have filed protests with CMS.

“The claims-based data collection mandate is so burdensome that most physicians will not be able to comply by January 1, 2017, which will result in CMS being unable to collect accurate and usable data, particularly in light of the unfinished final rule at the time of this writing,” the AANS and CNS wrote in a letter to CMS.
For more, read the full article at HealthLeaders Media.

HFAP releases 2017 CAH, ASC prepublication manuals

HFAP this week released its prepublication manual for critical access hospital (CAH), and ambulatory surgical center (ASC) surveys. The manuals have been updated to include requirements of the 2012 Life Safety Code® (LSC), which was recently adopted by CMS.  The CMS adoption of the 2012 LSC went into effect in July, and the new requirements will go into effect for HFAP facilities on November 1, 2016.

The changes to the accreditation requirements for CAHs are in Chapters 3, Chapter 14, and Chapter 17. They also include a CAH Facility Demographic Report and a HFAP-CMS Crosswalk.

The changes for ASCs are in Chapter 5, and include a ASC Facility Demographic Report.

10 ways to prevent drug diversion

Preventing the theft of controlled substances at hospitals continues to be an issue even with increased security measures. Failed drug diversion programs in hospitals have led to record fines levied against facilities. The Mayo Clinic experienced a highly publicized case of drug diversion back in 2008, where a nurse was caught stealing fentanyl from patients about to have a catheter inserted. The incident prompted the Mayo Clinic to take proactive steps toward drug diversion, such as:

1.    Having a zero tolerance policy for theft of any drugs from anywhere
This includes workers who fail to properly witness a coworker disposing a drug that is not ultimately given to the patient. Workers should be given pre-employment drug screening and receive education on the dangers of drug addiction and misuse.

2.    Work with law enforcement agencies
This includes local police and U.S. Drug Enforcement Administration (DEA). Officials from these agencies can process search warrants of employees’ homes and cars to help prove a case. This also lets other facilities know whether a prospective job hire has been caught trying to steal drugs before.

3.    Employ a 24-hour diversion hotline for workers to report suspicious behavior
Place advertisements for the hotline around the facility and make sure that those working on the hotline are qualified.


CMS finalizes new emergency preparedness rule

CMS announced yesterday that it had finalized new emergency response requirements for healthcare providers participating in the Medicare or Medicaid system. The new rule comes as a response to a string of disasters, natural and mad-made, including the recent flooding in Louisiana. The rule requires that healthcare providers meet the following four standards:CMS Logo

  1. Emergency plan: Based on a risk assessment, develop an emergency plan using an all-hazards approach focusing on capacities and capabilities that are critical to preparedness for a full spectrum of emergencies or disasters specific to the location of a provider or supplier.
  2. Policies and procedures: Develop and implement policies and procedures based on the plan and risk assessment.
  3. Communication plan: Develop and maintain a communication plan that complies with both Federal and State law. Patient care must be well-coordinated within the facility, across health care providers, and with State and local public health departments and emergency systems.
  4. Training and testing program: Develop and maintain training and testing programs, including initial and annual trainings, and conduct drills and exercises or participate in an actual incident that tests the plan.

“As people with medical needs are cared for in increasingly diverse settings, disaster preparedness is not only a responsibility of hospitals, but of many other providers and suppliers of healthcare services. Whether it’s trauma care or long-term nursing care or a home health service, patients’ needs for health care don’t stop when disasters strike; in fact, their needs often increase in the immediate aftermath of a disaster,” said Dr. Nicole Lurie, Health and Human Services assistant secretary for preparedness and response, in a press release. “All parts of the healthcare system must be able to keep providing care through a disaster, both to save lives and to ensure that people can continue to function in their usual setting. Disasters tend to stress the entire health care system, and that’s not good for anyone.”


Study: Readmissions sometimes improve patient health

Are readmissions always bad? A new study by John Hopkins Medicine published in The Journal of Hospital Medicine says the answer is not as clear cut as once believed. Researchers looked at three years and 4,500 acute-care facilities worth of readmission and mortality data, finding that hospitals with high readmission rates tended to have lower mortality rates as well.

The study focused on the six conditions that CMS penalizes hospitals for in its readmissions reduction program: heart attack, pneumonia, heart failure, stroke, chronic obstructive pulmonary disease (COPD), and coronary artery bypass. In particular, high readmission rates seemed to correlate with better mortality rates for COPD, heart failure, and stroke.

“But using readmission rates as a measure of hospital quality is inherently problematic,” study author Daniel J. Brotman, MD, said in a press release. “High readmission rates could stem from the legitimate need to care for chronically ill patients in high-intensity settings.”

This especially applies to cases of medically fragile patients who may need that follow up care to stay alive, he said. Readmission rates are currently used in CMS’s hospital star ratings system and the agency financially penalizes hospitals that have high readmission rates.

Brotman said it’s “particularly problematic” that the star rating system applies equal weight to readmissions and mortality, saying that it unfairly skews the data against hospitals. While some readmissions are the result of preventable issues such as bad handoffs, he added, there are times when readmission results from serious disease and patient frailty.

“It’s possible that global efforts to keep patients out of the hospital might, in some instances, place patients at risk by delaying necessary acute care,” said Brotman.

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2017 reporting requirements for ORYX

The Joint Commission released it’s 2017 reporting requirements for ORYX. Changes in include deletion of the measure set reporting requirement.

ORYX is a performance measurement and improvement initiative, for which facilities are  required to collect and submit data on six sets of core measures.

Click here to see the full document. 

Avoid fire drill citations with new matrix

Several months ago, Virginia Mason Medical Center (VMMC) in Seattle was denied full Joint Commission accreditation, in part due to its handling of fire drills. The facility received its citation for failing to vary the times and days when drills were conducted.

Now, The Joint Commission has released a new fire drill matrix for facilities to forestall confusion on survey day. The matrix tracks the day, date, time, and shifts when fire drills are conducted to ensure that they were conducted according to Joint Commission and CMS regulations. While they’ll still examine fire drill forms, surveyors will also give a copy of the matrix to hospitals when they arrive; although you can download an Excel copy of it here. 

The accreditor requires facilities to hold fire drills at random times to ensure that staff are ready when an actual emergency happens. Jim Kendig, The Joint Commission’s field director for surveyor management and development, said in a press release that hospitals are often unaware that they are conducting fire drills at similar times and days. The matrix helps them notice any patterns in scheduling that otherwise might escape notice.

“It becomes apparent,” Kendig said. “Hospitals can use this ahead of time, see patterns, and self-correct.”

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Four methods to limit redundant and unnecessary prescribing

The Hospitals & Health Network recently published an article on the issue of polypharmacy, which occurs when a patient is given redundant or unneeded medications. Tamping down on polypharmacy is crucial as many facilities face drug shortages, as well as the fact that inappropriate prescriptions can result in addiction  or drug-resistant disease. The author of the article, Todd Kislak, points out it’s not difficult for inaccuracies to appear on a patient’s medication list.

“When a patient is transferred among facilities, [primary care providers] PCPs tend to lose connection with the patient’s medications regimen,” he writes. “New additions to the medications list may be buried in the details of a discharge notification. There may also be physician specialists adding prescriptions without notifying the PCP. Additionally, in many cases, PCPs lose track of over-the-counter medications and other supplements in the patient’s medicine cabinet.”

Four steps to reduce polypharmacy are:

1.    Build a comprehensive polypharmacy management plan directly into the patient’s transition-of-care program. The discharging physician needs to have direct responsibility for approving and reviewing their patient’s medications list.

2.    Include polypharmacy into the medications therapy management program. Pharmacists should review patients’ current medications list, line-by-line, and give their recommendations to the discharging physician. The optimized medications list should then be communicated to the patient’s PCP and their admitting physician if they’re sent to another facility.

3.    Educate patients as early as possible on their current medications.When possible, review with the patient their current prescriptions, expired prescriptions still in the cabinet, over-the-counter medications and other supplements. This can be done with family members or caregivers in attendance, or done via email or phone.

4.    Hire a medication consultant to conduct polypharmacy management. If you have the funds, hire a physician whose primary duty is reviewing medication records for inconsistencies.

“Facilities that assume a proactive role in polypharmacy management with meaningful physician engagement will enjoy a competitive advantage in managing the health of their local populations,” Kislak writes. “They will profit from improved outcomes for their patients while delivering a benefit to all stakeholders across the care continuum.”

ACOs improve patient care and save $1.29 billion since 2012

CMS reports that between 2012 and 2015, accountable care organizations (ACO) have generated more than $1.29 billion in total Medicare savings. In 2015 alone, all 392 Medicare Shared Savings Program (MSSP) participants and 12 Pioneer ACO Model participants saved a combined $466 million while improving care quality.

“The coordinated, physician-led care provided by Accountable Care Organizations resulted in better care for over 7.7 million Medicare beneficiaries while also reducing costs,” said CMS Acting Administrator Andy Slavitt in the press release. “I congratulate these leaders and look forward to significant growth in the program in the coming year.”

Since 2012, MSSPs’ quality scores have increased 21%, with nine out of 12 MSSPs achieving quality scores over 90%. ACOs showed improvement on 84% of quality measures in both 2014 and 2015. ACOs also improved performance on key preventive measures such as including screening for falls risks, depression, blood pressure, and providing pneumonia vaccinations by 15%.

“Accountable Care Organization initiatives in Medicare continue to grow and achieve positive results in providing better care and health outcomes while spending taxpayer dollars more wisely,” said Dr. Patrick Conway, CMS Principal Deputy Administrator and Chief Medical Officer. “CMS continues to work and partner with providers across the country to improve the way health care is delivered in the United States.”

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