July 17, 2017 | | Comments 0
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But I got the crystal ball, he said!

And he held it to the light…

In their (seemingly) never-ending quest to remain something (I’m not quite sure what that something might be, but I suspect it has to do with continuing bouts of hot water and CMS), our friends in Chicago are working towards modifying the process/documentation for providing post-survey Evidence of Standards Compliance (for the remainder of this piece, I will refer to the acronymically inclined ESC). The aim of the changes is to “help organizations focus on detailing the critical aspects of corrective actions take to resolve” deficiencies identified during survey. Previously, the queries included for appropriate ESC submittals revolved around the following: identifying who was ultimately responsible for the corrective action(s); what actions were completed to correct the finding(s); when the corrective actions were completed; and, how will you sustain compliance (that is, as they say, the sticky wicket, to be sure).

The future state will be (more or less) an expansion of those concerns, as well as including extra-special consideration for those findings identified as higher-risk Requirements For Improvement (RFIs) based on their “position” in the matrix thingy in your final report (findings that show up in the dark orange and red areas of the matrix). The changes are roughly characterized as delving “deeper into the specifics” of the original gang of four elements, so now we have the following: assigning accountability by indicating who is ultimately responsible for corrective action and sustained compliance (not a big change for that one); assigning accountability for leadership involvement (only for the high-risk findings—whew!) by indicating which member(s) of leadership support future compliance; corrective actions for the findings of noncompliance—this will combine the “what you did” with the “when you finished it”; for high-risk findings, you will also have to provide information on the corrective actions as a function of preventative analysis (this sounds like a big ol’ pain in the rumpus room, don’t it?); and , finally, an accounting of how you will ensure sustained compliance, which will have to include monitoring activities (including frequency), the type of data to be collected from the monitoring activities, and how, and to whom, the data will be reported.

In the past, there was always the lurking (almost ghoulish) presence of what’s going to happen if you have repeat findings from survey to survey, and this new process sounds like it might be paving the way for more obstreperous future survey outcomes. But I’d like to know a little bit more about what might be considered a repeat finding—does it have to be the same condition in the same place or is it enough to get cited for the same standard/performance element combo. If the former is the case, then I “get” them being a little more fussy about the process (in full recognition that every organization has some repeat-offender tendencies), but if it’s the latter, then (insert deity of choice) help us all, ‘cause it’s probably going to get more ugly before we see improvement. Or maybe it will just be repeats in the high-risk zone of the matrix—I think that’s also pretty reasonable, though I do think they (the Chicagoans) could do a little better in ensuring consistent approaches/interpretations, particularly when it comes to ligature risks.

All that said, I stand on my thought (and let me tell you, that’s not an easy task) that there are no perfect buildings, no perfect physical environments, etc., and that’s pretty much supported by what I’ve seen being cited during surveys—the rough edges are where the greatest number of findings can be generated. And since they only have to find one instance of any condition in order to generate an RFI, the numbers are not in favor of the folks who have to maintain the physical environment. If you’re interested in the official notice, the links below will take you the announcement article, as well as a delightful graphic presentation—oh boy!

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Steve MacArthur About the Author: Steve MacArthur is a safety consultant based in Bridgewater, Mass. He brings more than 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro's Hospital Safety Director's Handbook and is contributing editor for Briefings on Hospital Safety. Contact Steve at stevemacsafetyspace@gmail.com.

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