Recent Articles
Reconsider Dating Open Multidose Vials
Over my 30 year carreer I’ve reviewed medication storage locations in about 500 hospitals. Guess what I’ve learned? It doesn’t work (except that it gives surveyors a “for sure” citation). I can remember only one hospital that succeeded in putting an outdating process in place for open multi-dose vials — it took tons of leverage from leadership and only lasted until the surveyor came back to clear them. So, what are the options? [more]
CMS Pushes for More Joint Commission Changes
The Joint Commission must for the first time meet CMS expectations to maintain its Medicare “deeming authority.” This has triggered significant changes, since the current Joint Commission standards and survey processes do not match CMS standards and survey processes. The first wave of change was the 300 or so new elements of performance that became effective on January 1, 2009. These changes were done “on the fly” (without the typical pause for comments from the field) and bring the Joint Commission standards in better (but not perfect) alignment with the Medicare Conditions of Participation. [more]
Is Staffing Effectiveness on its Way Out?
Apparently the Joint Commission is close to abandoning the requirement for staffing effectiveness measures. Ann Scott Blouin, the Joint Commission’s new Executive Vice President Division of Accreditation and Certification Operations, indicated that removing these standards is one of her high priorities. We have two questions:
1. What has taken JC so long? The staffing effectiveness requirement has been around for more than a decade. It has proven itself to be valueless over and over again. We’ve heard it was on the way out five years ago. We hope that this time it’s for real.
2. What about other standards without value, such as “prohibited entries” and “critical values.”
What’s in a name? NPSG 01.01.01 Patient Identification
Happy New Year! As of January 1st, the 2009 NPSGs are in full force. When we’re talking about NPSG 01.01.01, the patient identification goal, the Joint Commission requires that prior to collecting specimens, giving medications or providing treatments to the patient, staff are to actively involve the patient (or family as appropriate) in the identification process. And, when patient reliability is an issue, and participation from the patient is not possible, the hospital is to designate a responsible caregiver for verification of identity. We suggest designation of the patient’s primary nurse as the “responsible caregiver”. [more]
CMS Issues Updated Interpretive Guidelines
The updated Interpretive Guidelines to the Conditions of Participation have been published by CMS and are available by accessing CMS_Interpretive Guidelines 2008-10-17 Complete IG for Hospitals. The Interpretive Guidelines (IG) is presented in a slightly different format and has been consolidated to allow for each of the elements to nest under the categories of the Conditions of Participation (meaning while there is a distinct standard for restraint and seclusion, for example, you’ll find this consolidated under the condition of Patient Rights.) [more]
Examining the 2009 Universal Protocol FAQ
If you haven’t read the FAQs for the Universal Protocol published on November 5, 2008, please do so before reading the rest of this message. The FAQ can be accessed on this page: http://www.jointcommission.org/PatientSafety/UniversalProtocol/. A few nuances to the FAQ struck our attention. [more]
CMS Clarifies Use of Standing Orders and Signing of Order Sets
CMS has clarified its position on the use of standing orders in hospitals. The use of standing orders must be documented as an order in the patient’s medical record and signed by the practitioner responsible for the care of the patient, but the timing of such documentation is not to be a barrier to effective emergency response, timely and necessary care, or other patient safety advances. This means a standing order can be implemented without the physician expressly providing the order at the time, and the order can be obtained at a later date. These standing orders must be approved by the medical staff, and CMS does voice concern about exceeding scope of practice, so it is advantageous to make sure the medical staff has approved the standing orders for use by qualified and competent care providers, with the licensed independent practitioner validating the standing order in writing as soon as practicable. Also CMS clarified Signatures on Order Sets saying the last page must be dated and signed and any changes to the order set (other than checking which boxes apply, indicating type of treatment) initialed by the physician. Standing Orders in Hospitals – Revisions to S&C Memoranda
2008 FAQ enhances requirements for Look Alike-Sound Alike Drug Management
In the 2008 (March 2008) FAQ regarding NPSG 3C managing Look Alike, Sound Alike medications. The FAQ requires that error (interchange error) prevention stragegies should occur at all phases of medication management. This would include procurement, storage, transcribing, ordering, dispensing and administration. The FAQ continues to say that in addition to interchange error protection, prevention methods should include differing strengths of drugs. Therefore, staff involved at all levels of medication management processes should know the error prevention stragegies put into place to protect against interchange and dosing errors. Previously, many organizations focused on the Pharmacy and the site of administration only. Now organizations are to expand their scope to assure prevention strategies are implemented at each step of the medication management processes.
CMS grants DNV deemed status for accreditation of hospitals
Good News!! A new accrediting body joins The Joint Commission and the American Osteopathic Association’s Healthcare Facilities Accreditation Program (HFAP) in accrediting healthcare organizations for participation in the Medicare and Medicaid programs. Det Norske Veritas Healthcare, Inc., (known as DNV) has been granted, deemed status by CMS, and presents as another approved accreditation alternative. DNV’s accreditation program is called the National Integrated Accreditation for Healthcare Organizations (NIAHO). [more]
Change in wording changes everything in performing the immediate reevaluation for anesthesia
In reviewing the 2009 Provision of Care chapter from TJC I stumbled across another change that (according to information obtained at Executive Briefings “isn’t a change”.) Under PC standard 03.01.03 EP 8 the “hospital” is required to reevaluate the patient immediately before administering sedation or anesthesia. Frankly, I don’t see how a building can assess a patient, but semantics aren’t everything. With this new wording, the anesthesia provider is clearly not required to be the individual conducting the immediate reevaluation. Which means the nurse can take the patient’s vital signs and conduct a brief assessment and document this appropriately as the immediate reassessment. While most organizations have imbedded the anesthesia provider’s immediate reassessment into their procedure forms, if your organization is having difficulty with compliance by your anesthesia providers, you may want to reconsider how the immediate assessment process really works in your facility and make changes as appropriate. Stay tunned, as we continue to drill down into the 2009 standards, there are bound to be more changes coming our way.