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Tired of being tired? Me too!

A couple of quick items this week. As is frequently the case, I keep something of a digital scrapbook of ideas for the blog in my draft email folder. If I see a news item or some such that I think might be worth sharing, I’ll set it aside with the intent of using it at a later date. As things are wont to do, competing priorities, breaking news, etc., will sometimes push other items out of the way and I try to remember to go back and dig out stuff that continues to be at least somewhat timely—and sometimes what was kind of fresh in the moment can become even more significant over time.

For example, way back in June 2020 (if that doesn’t make me sound like an old codger, I don’t know what would), our friends in Chicago released an issue of its Quick Safety newsletter providing some thoughts regarding the challenges in promoting well-being during a crisis. At that point, I don’t know that many would have predicted that we would still be in the thick of it almost 18 months later and, anecdotally (doing client work and overhearing conversations as I travel), it does seem that folks are reaching the point of wearing out. I have no reason to think that is not the case for you folks as well, so this might be something you’d want to share with your organization—or maybe even at the Thanksgiving table.

Item #2 for this week kind of spins off the whole conversation regarding the management of workplace violence—the importance of being able to rapidly summon assistance in an emergency. Panic alarms are intermittently used in healthcare, but I think that, as part of being able to manage workplace violence, they are going to become ever more prevalent, particularly in remote locations—both within the “four walls” of your organization and in any community settings (clinics, business offices, etc.). In exchange for a wee bit of information, you can download a white paper from the good folks at Patient Safety & Quality Healthcare that discusses some of the considerations. Before you know it, budget season will be upon us and this might be something to think about adding to the mix.

Putting the O(SHA) back in OMG…

I’m sure you were right there with me last week pondering the potential impact of the Emergency Temporary Standard issued by our friends at the Big O (see the news release) in efforts to get ahead (and stay ahead) of COVID. As I travel, I’m not sure that this is going to be as successful as they’d like it to be. I still observe folks in airports, on public transportation, etc., who are surprised when they are reminded that masks are mandated in a lot of confined public environments. As somewhat of an editorial aside, I “get” that someone might forget to slide their mask back up after they’ve eaten, etc., but I don’t get the mindset that has masks buried at the bottom of their handbag, etc. I freely admit that my OCD slides to the fore when it comes down to mask wearing; when I’m traveling, the mask goes on in the car and doesn’t come off again until I get to my hotel room. I figure it’s worked well so far, so I’m going to stay the course for a while longer—maybe once we have a solid 12 months of vaccinations (and who knows when that might be…).

At any rate, under the ETS, covered employers must develop, implement, and enforce a mandatory COVID-19 vaccination policy, unless they adopt a policy requiring employees to choose to either be vaccinated or undergo regular COVID-19 testing and wear a face covering at work.

The ETS also requires employers to do the following:

  • Determine the vaccination status of each employee, obtain acceptable proof of vaccination status from vaccinated employees, and maintain records and a roster of each employee’s vaccination status.
  • Require employees to provide prompt notice when they test positive for COVID-19 or receive a COVID-19 diagnosis. Employers must then remove the employee from the workplace, regardless of vaccination status; employers must not allow them to return to work until they meet required criteria.
  • Ensure each worker who is not fully vaccinated is tested for COVID-19 at least weekly (if the worker is in the workplace at least once a week) or within seven days before returning to work (if the worker is away from the workplace for a week or longer).
  • Ensure that, in most circumstances, each employee who has not been fully vaccinated wears a face covering when indoors or when occupying a vehicle with another person for work purposes.

But in looking at all this stuff, I’m thinking healthcare (for the most part) has already embarked on this journey and when I started poking around the FAQs, FAQ 2J speaks very specifically to whether, in light of the existing Healthcare Emergency Temporary Standard (29 CFR 1910.502), and the answer (at the moment; more on that in a bit) is no, the protection of healthcare workers is already in play based on the existing ETS. But the potential “twist” is that if the Healthcare ETS were to expire/no longer be in effect, etc., before the expiration of this latest ETS, then the protection of healthcare workers would shift over. I don’t know that anything is jumping out at me from a practical standpoint that might represent a gap of protection if that shift were to occur, but if someone has different take on this, I’d be pleased as punch if you’d share it with us.

Sooooo…I think we’re OK for the moment, at least in terms of regulatory expectations, but keep an eye on things as they shift in and out of view/focus. If I sense a sea-change, I will do my best to keep you informed.

At the risk of “dating” this post, I’d like to conclude this week’s offering with a shout out to the veterans of our Armed Services. Not that they don’t deserve a shout out every week, but it just seems important to “push” Veterans’ Day a little bit this year. We are all the better for your service and I thank each and every one of you!

And now a brief word from…

The source of any number of potential nightmares…

Sorry for the extraordinarily late notice on this, but our friends at the Occupational Safety & Health Administration (OSHA) are hosting a healthcare symposium on August 31, but hopefully there are spots left. It’s a day-long event, so perhaps you can jump in and out depending on the presenters, etc. I suspect it would be nice to be able to take in the whole of it, but competing priorities might dictate otherwise. I am curious as to what they may have to say about suicide prevention (one of the planned topics), but alas I will be competing with my own priorities.

Recognizing that the “elephant in the room” at the moment remains responding to the pandemic (unless you are on the Gulf Coast and are dealing with Hurricane Ida and the storm’s aftermath—thoughts and prayers going out in that direction), I suspect that it will be topic that is covered rather extensively during the program.

A couple of items of note; the initial OSHA enforcement response plan has been archived in anticipation of OSHA completing a review of guidance from the Centers for Disease Control and Prevention (CDC) relative to precautions for fully-vaccinated folks, so we’ll have to keep an eye out to see what might be in the works on that count, which can be found (as well as the latest and the greatest) here.

And for those keen on partaking of some legalese as the summer begins its (all too rapid) wind-down, you can view the sum and substance of the Emergency Temporary Standard as it was initially published. Certainly, there are going to be some differences between the original and whatever comes out of the current (and perhaps future) review sessions, it’s tough to think that the whole thing is going to get tossed, so there may be one or two pointers lurking in the verbiage.

Again, my apologies for the late notice on the seminar/webinar/symposium; not quite sure how it slipped past me, but there is a lot of material out there. Hopefully you can “attend.”

Best wishes for a productive week and (with all luck) a restful Labor Day holiday. I suspect we’re looking at a busy autumn into winter stretch. Rest those weary bones for what I think we all hope will be the (finally!) home stretch of this event.

Looking back, looking ahead: Where did all the heroes go?

For those of you who have been watching this space for a while, it is probably a pretty good likelihood that you know that I (at times) have a tendency to reflect on the journeys of the past and this week’s conversation is no exception. To start things off, I would like to ask you to think about your response to the following multiple choice question.

In looking back over the past 12-15 months, I feel that I am:

a. Less appreciated than last year

b. Appreciated about the same as last year

c. More appreciated than last year

My hope is that your response is c. (for a whole host of reasons, more on that in a moment) and I also hope that that is the response for everyone in your organization. But somehow I suspect that my hope is not as widespread as perhaps it could/would/should be. Flip back to last year and the “rise” of the healthcare providers as modern-day superheroes (I would submit to you that heroism and healthcare have been joined at the hip since Hippocrates uttered his oaths); everyone had to come up with new and inventive ways to thank these awesome folks as social distancing became the order of the day. Signs, posters, videos, anonymous gifts—there was a whole lot going on last year.

In answer to the question posited in this week’s headline, the heroes are still here. They’re 12-15 months more exhausted than they were when they were everyone’s darlings, and, make no mistake, the siege that is COVID shows no signs of giving up or giving in to the ministrations of the folks on the front line.

But now, much as the weeks that follow the demise of a loved one and the crowds dwindle, not so much attention is being paid to the ongoing acts of heroism involved in getting by day after day. I know that part of the issue is that expectations have altered over time and now I fear that heroism has become taken for granted, which may be the worst “side effect” to this whole pandemic. The response of this nation’s healthcare workers was—and continues to be—nothing less than extraordinary, but the small kindnesses that were so freely shared last year just don’t seem to be in the mix these days, and they’re probably more important now than they’ve ever been. What you folks and your folks have done over the past 12-15 months is simply amazing, but in the day-to-day slog, somehow that perception of amazement has been lost to the news cycle or whatever attention grabbers have managed to wiggle their way into the social consciousness.

So, I want to thank each and every one of you in the studio audience for every big and little thing you do to keep your places in operation. You are all heroes and will continue to be for the duration and I take no small measure of comfort in knowing that you are out there doing the do, day in and day out. Just as we have “learned” to thank folks in the military for their service, as a nation, we should embrace that same philosophy for our healthcare workers. It’s the least we can do!

Maybe this time we should do things a little differently…

This may be a “me” thing, but it seems to me that I’ve seen a lot of annual evaluations recently that only minimally make note of organizational response to the pandemic. I know there are no “rules” about the contents of the annual evaluation and it seems unlikely (unless you have a very high-powered crystal ball) that response to a pandemic would have been a key point in identifying goals for 2020 (though I suppose if you’re using the fiscal year as your calendar and you had a starting point in the middle of 2020). Clearly, consideration of things relating to pandemics and emerging infectious diseases is going to be front and center for the foreseeable future (for good or ill), but I still have this (perhaps unreasoning) fear that we’re going to lose a ton of “good stuff” as we come out the other side of the current emergency.

And that “good stuff” that might be lost are the missteps that periodically intruded upon the response protocols that were, to a fair degree, made up on the fly. Innovation was definitely the overarching result, and there were certainly great successes, but there had to be some stuff that didn’t work. It seems I continue to hear about setting up tents, taking tents down, setting them up again, and on and on…

So my thought is: Go back to all those hotwashes and AARs that were written in the heat of battle and see if there were any items that really didn’t make the grade—and memorialize ’em! My sincere hope is that the learned lessons won’t have a practical application any time soon, but the reports of a resurgence of hospitalizations make me think that we’re not quite done with this sucker.

Stay tuned…

Night time in the switching yard: Listen to the train(ing) whistle whine…

I suspect that, amongst all the other things that have been pounding on the metaphorical rooftops, you saw the updated guidance from OSHA relating to the Emergency Temporary Standard. I don’t know that there’s a great deal in play that would be particularly problematic, but I think the training requirements might be worth a little bit of work to ensure that the required elements are readily discernible to a regulatory surveyor. That said, I wouldn’t necessarily consider these “new” requirements, as with so many of the post-pandemic “requirements,” it’s all kind of based on what you would do if you were facing whatever event was coming down the pike. I really don’t think this is anything about which you should be concerned, but I figure it can’t hurt to get the list out and make sure that your program speaks eloquently to the individual components.

Here they are:




The employer must ensure that each employee receives training, in a language and at a literacy level the employee understands, and so that the employee comprehends at least the following:


COVID–19, including how the disease is transmitted (including pre-symptomatic and asymptomatic transmission), the importance of hand hygiene to reduce the risk of spreading COVID–19 infections, ways to reduce the risk of spreading COVID–19 through the proper covering of the nose and mouth, the signs and symptoms of the disease, risk factors for severe illness, and when to seek medical attention;


Employer-specific policies and procedures on patient screening and management;


Tasks and situations in the workplace that could result in COVID–19 infection;


Workplace-specific policies and procedures to prevent the spread of COVID–19 that are applicable to the employee’s duties (e.g., policies on Standard and Transmission-Based Precautions, physical distancing, physical barriers, ventilation, aerosol generating procedures);


Employer-specific multi-employer workplace agreements related to infection control policies and procedures, the use of common areas, and the use of shared equipment that affect employees at the workplace;


Employer-specific policies and procedures for PPE worn to comply with this section, including:


When PPE is required for protection against COVID–19;


Limitations of PPE for protection against COVID–19;


How to properly put on, wear, and take off PPE;


How to properly care for, store, clean, maintain, and dispose of PPE; and


Any modifications to donning, doffing, cleaning, storage, maintenance, and disposal procedures needed to address COVID–19 when PPE is worn to address workplace hazards other than COVID–19;


Workplace-specific policies and procedures for cleaning and disinfection;


Employer-specific policies and procedures on health screening and medical management;


Available sick leave policies, any COVID–19-related benefits to which the employee may be entitled under applicable federal, state, or local laws, and other supportive policies and practices (e.g., telework, flexible hours);


The identity of the safety coordinator(s) specified in the COVID–19 plan;


The requirements of this section; and


How the employee can obtain copies of this section and any employer specific policies and procedures developed under this section, including the employer’s written COVID–19 plan, if required.

Note to paragraph (n)(1). Employers may rely on training completed prior to the effective date of this section to the extent that it meets the relevant training requirements under this paragraph.


The employer must ensure that each employee receives additional training whenever:


Changes occur that affect the employee’s risk of contracting COVID–19 at work (e.g., new job tasks);


Policies or procedures are changed; or


There is an indication that the employee has not retained the necessary understanding or skill.


The employer must ensure that the training is overseen or conducted by a person knowledgeable in the covered subject matter as it relates to the employee’s job duties.


The employer must ensure that the training provides an opportunity for interactive questions and answers with a person knowledgeable in the covered subject matter as it relates to the employee’s job duties.

Again, I feel pretty confident that these elements have been in place in most instances (PPE, risks associated with COVID, health screening, any changes to procedures, etc.) and (presumably) the effectiveness of the education process supported by data of COVID-related illnesses amongst the workforce. But it might be a good idea to “pull” these elements out as a syllabus (if that makes sense) to be able to walk a surveyor through the elements.

The trouble with normal?

It always gets worse!

While I can’t say with absolute certainty, it seems likely that I’ll be employing relatively brief missives over the next couple of weeks as we do seem to be shifting gears a bit as far as the “return to normal.” As I write this, it’s been a couple of weeks since my last air travel and (based solely on my own observations) I have every reason to think that the COVID surge being reported is going to be a disruptive factor—I am hoping that this is the last wave before we reach safe harbor, but I’m not just seeing noses in enclosed public spaces, I’m seeing lots of full faces. I received my second dose of the vaccine about 10 days ago, but I’m going to keep masking up for the foreseeable future when I’m traveling. I will be happy to be proven that it was more than I needed to do, but I’m still waiting on the data…

So, just a couple of resource items for moving into the next phase of normalcy. First up, I was always (OK, since last June) surprised by the variability of screening practices and that surprise continues today. But if you want to get a sense of what I’m seeing in the field, this would be a good starting point. I don’t know that there’s a whole lot of data regarding how effectively screening helped stem the tide of COVID or even how often cases were identified through that process, but maybe someday there will be some sense.

Another element for consideration is visiting folks in nursing homes and other care facilities. I don’t think there’s anyone who would argue that there has been a significant emotional toll since the onset of COVID, which, I suppose has given the powers that be a fair amount of time to come up with how to transition safely on the visitation front. In September 2020, CMS issued some guidance in that regard and, a few weeks ago, updated that guidance in light of vaccinations, etc. Again, if we get another spike, this might be the best we get for a while, but at least it’s something…

And that, as they say, is that—at least for this week. Who knows what might come flying out of nowhere to create havoc, so stay tuned.

Be well and stay safe. Every day brings us a little closer to the end of this thing!

Stay Centered and Carry On: PHE likely to persist through 2021!

As any of the Peanuts gang might opine: AAUGH!

In a letter to the governors, Norris Cochran, the acting secretary of HHS, indicated that it had been determined that the Public Health Emergency (PHE) will likely remain in place for the entirety of 2021, but there would also be a 60-day notification prior to the termination or expiration of the PHE.

Ostensibly, this removes at least some of the uncertainty of the quarterly updates of the PHE status and appears to provide a 60-day window for organizations to attain compliance with any regulatory requirements covered under the 1135 waiver process, including the blanket waivers currently in effect. I suspect this also means that support at the federal level will remain in place relative to response activities—the letter also indicates that this should be considered evidence of the government’s commitment to ongoing response to the pandemic.

Presumably, there is a cross-section of folks in the field who either didn’t adopt any of the waivers or have been able to move things back to “business as usual” in terms of inspection, testing and maintenance activities, so this may not mean that much from a practical standpoint. That said, if there are any of you out there who have been able to make good use of, you probably need to start thinking about a turnaround within 60 days. Maybe you start to reach out to your vendors—there’s probably going to be a queue for services once this whole thing breaks loose—and the indication is that the accreditation organizations are not going to be flexible once the PHE expires/terminates. I’m trying to think of what processes would take longer than 60 days to get back on track and nothing is springing to mind. Again, I suspect that scheduling the work is going to be the “sticky wicket” if there’s going to be any issue, so if there’s anything you can do to pre-load that process, it’s probably time well-spent.

Until next time, hope you are well and staying safe!

From the sky we look so organized and brave

Once again (I’m thinking there’s no surprise to this), the public health emergency wrought by the impact of COVID-19 on just about anything you’d care to name has been extended. You can find the somewhat reiterative announcement here (apparently, there’s no one at the federal level that proofreads this stuff—go figure). If the past sequence of review and extension continues to hold true, we can expect the next extension to “drop” sometime in April. It would be delightful to think that distribution of the vaccine would somehow interrupt a further extension, but I suspect we probably have at least one more after that, as we move ever closer to whatever is going to constitute the “new normal” (based on the latest numbers from CMS, things do seem to be retreating/receding from red, so to speak).

As we continue our slog through the pandemic, our good friends in the CMS workshop have been busy establishing a portal for all things waiver-related. It may be that there’s too much information (there are a whole bunch of links to various sites, etc.), but on the off chance that you folks might find something useful contained therein, you can check it out here.

There are a couple of YouTube videos in the mix to help complete the online waiver request forms (if you would feel so inclined, you can go directly to the waiver request site by using this link).

Ultimately, it’s all about being able to continuously provide appropriate care to our patients; sometimes that means going from one moment to the next—which, as we’ve learned over the last little while, breeds its own special brand of exhaustion…

I encourage you to make the most of what little “down” time you have to recharge your batteries as much as you can. The vaccination process seems to be gathering some momentum, but we’re still a ways away from the finish line. I guess this is one race we’ll all be finishing at the same time…

Until next time, please stay well and be safe!

Be afraid, be very afraid…but do it anyway!

Something of a mixed bag this week: Basically a couple of brief items with some interpolative commentary.

First off, in what is probably not really a surprise, the feds have not updated the status of the Public Health Emergency (PHE) (here’s the most recent correspondence in this regard) in a little bit, but I am hopeful that our sprint towards the New Year will prompt a revisitation. I guess one of the key thoughts moving forward is at what point are regulatory surveys impacted. It would seem that we are in a bit of a spike in cases (though how one can tell definitively is something of an art form), based on the information provided to folks traveling in and out of Massachusetts (which would include yours truly). While I can’t say that I’m getting used to being swabbed, I suspect that between now and Christmas, I’ll have a few more opportunities to embrace the swab.

At any rate, I’d be curious as to how folks are “falling” within their normal accreditation survey cycle. Early? Late? Pretty much on time? At some point, something’s going to have to give (and maybe that something involves virtual building tours and the like). I guess at this point all we can do is “stay the course,” and wait for the vaccine distribution challenge (we know it’s coming sometime)…

In other news, our friends in Chicago announced a revision to one of the performance elements dealing with the life safety implications of maintaining fire suppression systems. You might recall we chatted a bit about this back at the beginning of July, at least in terms of the whole spare sprinkler thang. If you accept (as I pretty much have at this point) that any change to a physical environment standard or performance element is “designed” to provide an opportunity for generating more findings (the sterling being the impending focus on the ambulatory care environments), then I think it would be prudent to really kick the tires on your spare sprinkler maintenance program to ensure that you are meeting not just the requirements of the revised performance element, but also the other related requirements. (The blog post above should serve as a good starting point, if you are so inclined.)

As always, please be well and stay safe. I appreciate everything you are and everything you do!