RSSRecent Articles

CMS approves DNV application to accredit hospitals

Hello, everyone. I just wanted to update you on a developing story:

The Centers for Medicare and Medicaid Services (CMS) announced Friday the approval of DNV Healthcare, Inc. as a deeming authority for U.S. hospitals. DNV is the first new organization to receive deeming authority for hospitals in more than 30 years.

According to the pre-Federal Register announcement, DNV was recognized “as a national accreditation program for hospitals seeking to participate in the Medicare or Medicaid programs” effective September 26, 2008 through September 26, 2012.

“We’re coming into this business not just as another option,” says Yehuda Dror, president of DNV Healthcare. “We want to take a leadership position.”

“I think a lot of people will explore the possibility,” says Bud Pate, REHS, is Vice President for Content and Development for The Greeley Company; a division of HCPro, Inc. “There are some hurdles that people will need to walk through—since DNV is new they’re going to need to work through some residency issues, contract issues, that may exist and may mention The Joint Commission but none of these are insurmountable.”

DNV has crafted a system intended to combine CMS Conditions of Participation (CoP) with ISO 9001 quality management. This program, called the National Integrated Accreditation for Healthcare Organizations or NIAHO(SM), was created to make the accreditation process more streamlined as well as identify means for improving current standards and promoting continual improvement.

“The ISO-9001 certification seems to be a logical progression to the focus on quality assurance and quality improvement that has occurred in healthcare, primarily in hospitals,” says Larry Poniatowski, RN, BSN, CSHA, principal consultant for Accreditation Compliance Services with The University HealthSystem Consortium. “The issue here now will be to see how well it’s embraced by hospitals.”

Twenty seven U.S. hospitals in 22 states have been accredited by DNV Healthcare using the NIAHO(SM) program in addition to other accreditation services.

In mid-2007, DNV Healthcare acquired Cincinnati-based TUV Healthcare Specialists with the belief that the acquisition would help cement DNV’s application to CMS. In 2006, TUV had unsuccessfully applied for deeming authority.

DNV Healthcare is a division of Houston-based DNV USA, a subsidiary of the Norwegian company Det Norske Veritas. DNV focuses on risk management and training in several industries, including healthcare.

We’ll be providing additional coverage here on the blog as well as in Briefings on The Joint Commission in the upcoming issue.

What is your sense of DNV’s chances? Is your facility considering looking into moving away from Joint Commission accreditation? Are you interested in further details on how DNV’s process works?

Joint Commission continues its focus on anticoagulants

The Joint Commission released today its latest Sentinel Event Alert targeting anticoagulant use and medical errors, the fourth alert this year. There have been a number of high-profile medical errors involving anticoagulants in the national media, and The Joint Commission’s alert is intended to offer methods for preventing further errors.

This is not the first time The Joint Commission has targeted anticoagulants. Requirements introduced into the 2008 National Patient Safety Goals are set to hit the point of full implementation on January 1, 2009. The Joint Commission also addresses anticoagulants under the medication management standards.

Common factors in anticoagulant errors highlighted in The Joint Commission’s report include labeling and packaging issues, documentation errors, communication failures, an inappropriate use of medication.

The alert offers fifteen steps to error prevention, including

-An assessment of the risks involved in using anticoagulants like heparin and warfarin

-Use of best practices or evidence-based guidelines to prevent errors using anticoagulants

-Reassessment of labeling and storing of anticoagulants to avoid errors

-Greater communication and collaboration between staff members

-More extensive education for patients

For more information or to view the Sentinel Event Alert itself, go to The Joint Commission’s Web site here.

Executive Briefings debriefing, New York edition (#1)

Hello, everyone. I’ve just returned from the New York Executive Briefings. There weren’t any bombshells dropped this year by any of the presenters, who focused on the National Patient Safety Goals (NPSG), problematic standards, the new e-dition of the Comprehensive Accreditation Manual for Hospitals, and lastly gave an overview of the new scoring methodology.

Audience questions this year focused unsurprisingly on medication reconciliation, which continues to be a struggle for hospitals across the country. Universal Protocol was also a focal point during question and answer sessions.

Dr. Peter Angood said that The Joint Commission does not intend at this point to add any new NPSGs in 2009, though revisions are to be expected—and remember, just a few months ago we saw the release of the 2008 NPSGs that, though they did not contain any brand new Goals, did contain significant changes and left much work to do.

An important note on Periodic Performance Review (PPR): If your facility is due to submit a PPR before October, 2008, there are no changes. After October, PPR is optional for this year because of the numbering changes in the manual. If you choose to submit a PPR, though, it will need to be done before December 1 because The Joint Commission’s PPR tool will be offline.

If your PPR is due in January, you will have an extra 90 days to submit it. If due in February or March, you have an extra 60 days to submit it.

Was anyone else in attendance on Friday? What observations did you take away from the New York Executive Briefings?

I’ll be posting additional observations over the next few days, so please check back.

News from Executive Briefings: "D"s Will Not Change

Just wanted to share this posting from Bud Pate, REHS, Vice President of Content and Development for The Greeley Company. Bud is currently attending Executive Briefings in Los Angeles.

Although there may be some errors, the “D”s [indicating that documentation is required] for the new standards will remain as written in the current version of the manual according to Dr. Robert Wise, Vice President for the Division of Standards and Survey Methods for the Joint Commission. Although he acknowledges that there may be errors, Dr. Wise committed that, until they change, documentation is not required unless there is a Circle D logo in the accreditation manual.

Stay tuned for more.

Matt Phillion, Senior Managing Editor of Briefings on The Joint Commission, will be reporting back from the New York Executive Briefings.

An Inside Look at Successful RFI Clarification

Just wanted to share this white paper from Lisa Eddy, RN, CPHQ, CSHA, Senior Consultant for The Greeley Company, a division of HCPro, Inc. Those of you who participated in our working group calls on suicide risk assessment should be familiar with Lisa. Hope you find this white paper useful.

Go to http://www.hcpro.com/content/217282.pdf to download a PDF of the white paper.

Brian Driscoll
AHAP Director

Distinguish Between Medical and Behavioral Restraint

From Bud Pate, REHS, Vice President of Content and Development for The Greeley Company:

Surveyors commonly misapply the behavioral health rules to medical restraint. In fairness, the Joint Commission standards and CMS regulations are a more than a little confusing, even when you study them carefully. But the rules for behavioral health restraint are vastly different than those for medical restraint, so your definition should be crystal clear.

Regardless of the location, behavioral health restraint rules should only be applied to address violently aggressive or self disruptive behavior. We recommend that your policy clearly apply the medical restraint rules to the following situations:

- a patient who is in the critical care unit after a suicide attempt and is being restrained to avoind accidental extubation due to twitching or trying to sit up in bed;

- a patient experiencing involuntary thrashing during acute withdrawal syndrome;

- a confused patient who is interfering with nursing care.

“But wait,” you say, “we should use the behavioral health care rules because we are caring for patients with clear emotional disorders.” Or you may say “The confused patient is trying to hurt the nurse, shouldn’t the behavioral health rules apply?”

But remember, all restraint (medical and behavioral) is implemented to address behavior. And if you truly believed the behavioral health care rules applied you would already be staffing these situations with psychiatric nurses. Ask yourself, “would a debriefing be helpful to see how a future episode would be avoided?” I don’t think so.

There will certainly be those who object to this position. If you are one of them, then I encourage you to fully (and I mean fully) implement all the behavioral health care rules to these situations, including: continuous observation, 15 minutes assessments by a staff member with psychiatric training, post-restraint debriefing with the patient, and all the other very restrictive rules. If you don’t feel these measures are clinically necessary, then you agree with me: these are not behavioral health restraint. So define them as medical restraint in your policy.

Remember: we can debate the fine points of a policy with regulators all day long without reaching an adverse conclusion. However, you will definitely be guilty of an infraction if you violate your own policy. In other words: say what you do and do what you say.

Restraint benchmarking survey

Hello, all. I just wanted to share with you some results from our recent benchmarking survey:

Managing the use of restraints and complying with related requirements continue to be major challenges for accreditation professionals throughout the country. And one of the biggest areas of concern is the use of medication restraints, according to AHAP’s most recent benchmarking survey.

According to the members-only survey, conducted in June and July 2008, 46% of accreditation professionals find medication restraints the most troublesome under CMS’ updated restraint Interpretive Guidelines (24% listed soft limb restraints as most troublesome, while 17% listed “other,” 7% listed zippered comforter restraints, and 6% listed low bed restraints).

The number for medication restraints seems high, says Elizabeth Di Giacomo-Geffers, RN, MPH, CNAA, BC, CSHA, member of the AHAP advisory board, healthcare consultant in Trabuco Canyon, CA, and former Joint Commission surveyor. “Perhaps the organizations need to review their definitions of chemical restraint,” she says. “They may, in fact, not be following the CMS/Joint Commission definition—theinappropriateuse of a sedating psychotropic drug to manage or control behavior. To give a medication may in fact be medical management of the patient’s condition and not inappropriate use.”

When asked how they used medication restraints, 51% of survey respondents said they use them to de-escalate aggressive, destructive behavior. Thirty-seven said they use medication restraints to manage behavior, 25% said they use them for other purposes, and 7% said they use them to restrict freedom of movement.

Hope you found this useful. Go to http://www.accreditationprofessional.com/benchmarking_survey.cfm?topic=WS_AHP_QBS to download the full 11-page report, as well as other benchmarking reports from this year.

Medicare Improvements for Patients and Providers Act

I just wanted to update you on a news brief I posted to the group a few weeks back. Congress overruled yesterday President Bush’s veto of the Medicare Improvements for Patients and Providers Act, based on a bill authored by Senate Finance Committee Chairman Max Baucus (D-Mont.).

While the primary focus of the bill is to improve several key aspects of Medicare, for those of us working in the area of accreditation, under the category of “Enhancements for Rural and Other Hospital Care,” note this short passage:

Revokes unique authority of the Joint Commission on the Accreditation of Healthcare Organizations to deem hospitals in compliance with Medicare Conditions of Participation.

There will be a 24-month transition period for The Joint Commission to complete the application process for deeming authority, and “the amendments made by this section shall not effect the accreditation of a hospital by the Joint Commission, or under accreditation or comparable approval standards found to be essentially equivalent to accreditation or approval standards of the Joint Commission, for the period of time applicable under such accreditation.”

Additional information can be found online here: http://finance.senate.gov/sitepages/medicare2008.htm

What are your thoughts? Does this level the playing field for other accrediting organizations? What effect do you think this will have on hospital accreditation, if any?

We have reached out to The Joint Commission and several other organizations for comment; I will be sure to distribute to the group follow-up information as it arises.

Latest Sentinel Event Alert: Disruptive behavior

I just wanted to make you aware of some breaking news: The Joint Commission has issued its latest Sentinel Event Alert today addressing bad behavior by healthcare professionals.

Disruptive behavior was considered as a possible National Patient Safety Goal for 2008 but was not selected. The Joint Commission has stated in this most recent alert that rude behavior, unpleasant language, hostile attitudes and other bad behaviors does not only create an unpleasant environment but are detrimental to patient safety and quality of care.

This alert ties into new standards going into effect January 1, 2009, which will require healthcare organizations to create a code of conduct defining acceptable and unacceptable behaviors as well as crafting a process for dealing with poor behavior.

The Sentinel Event Alert provides 11 steps to curbing disruptive behavior. These range from providing education and training for healthcare providers about professional behavior and appropriate interactions with coworkers; creating accountability for maintaining appropriate behavior; establishing a zero tolerance policy for disruptive behaviors and a means for enforcing this policy; and crafting non-confrontational methods for reporting and addressing inappropriate behavior.

The Joint Commission’s Sentinel Event Alert can be found online here: http://www.jointcommission.org/SentinelEvents/SentinelEventAlert/sea_40.htm

2009 National Patient Safety Goals released

Just wanted to let you know that The Joint Commission released the 2009 National Patient Safety Goals earlier today on its Web site:

http://www.jointcommission.org/PatientSafety/NationalPatientSafetyGoals/

http://www.jointcommission.org/NR/rdonlyres/31666E86-E7F4-423E-9BE8-F05BD1CB0AA8/0/09_NPSG_HAP.pdf

The first link also has a chart identifying which goals have received changes/deletions/additions, and provides a crosswalk to the new numbering system.