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I am barely breathing: Gas Equipment is on TJC’s Radar!

The past couple of weeks, I’ve been fielding some questions relative to some new performance elements under the Medical Equipment Management standard that covers inspection, testing, and maintenance activities. Apparently, folks have been receiving some sort of notifications from profession groups (in this case, it seems to be the respiratory therapy folks that are being targeted with the notifications.

At any rate, I think we can say (pretty much for all time) that any changes to the standards/EPs is likely to result in (at the very least) consternation and a potential uptick in findings related to said standards/EPs. At least some of the questioning is focused on a certain element of reliance on vendors (and we know how that can go). So, while I do believe that for the most part folks are going to be OK with the changes, I also recognize that a little conversation couldn’t possibly hurt…

In case you’ve not yet encountered the new stuff, what we have is this. For equipment listed for use in oxygen-enriched atmospheres (more on that in a moment), the following must be “clearly and permanently” labeled on the equipment (permanently meaning the labeling withstands cleaning and disinfecting—how many labels are like that?): 1) Oxygen-metering equipment, pressure-reducing regulators, humidifiers, and nebulizers are labeled with name of manufacturer or supplier; 2) Oxygen-metering equipment and pressure reducing regulators are labeled “OXYGEN–USE NO OIL”; 3) Labels on flowmeters, pressure-reducing regulators, and oxygen-dispensing apparatuses designate the gases for which they are intended; and 4) Cylinders and containers are labeled in accordance with Compressed Gas Association (CGA) C-7.

The source material for these “new” requirements is in NFPA 99-2012 11.5.3.1; and please note that color coding is not to be utilized as the primary method of determining cylinder or container contents; I suppose when you come right down to it, cylinders are no different than any other secondary container when it comes to identifying the contents.

The follow-up question becomes one of what constitutes an “oxygen-enriched atmosphere”; in the definitions section of NFPA 99-2012, section 3.3.131 gives us this: “3.3.131 Oxygen-Enriched Atmosphere (OEA). For the purposes of this code, an atmosphere in which the concentration of oxygen exceeds 23.5 percent by volume. (HYP)” Now, you may notice the little tag at the end of this definition, which gives us some indication of where we need to be particularly mindful, with “HYP” referring to hyperbaric therapy. I know there are more hyperbaric therapy locations than there used to be, but some folks aren’t going to have to worry too much about this. But in the interest of a complete picture, I looked over the materials in the NFPA 99 Handbook and I think the information there further narrows down the field of concern:

“The normal percentage of oxygen in air is 20.9 percent, commonly expressed as 21 percent. The value of 23.5 percent reflects an error factor of ± 2.5 percent. Such a margin of error is necessary because of the imprecision of gas measurement devices and the practicality of reconstituting air from gaseous nitrogen and oxygen. Hyperbaric chambers located in areas of potential atmospheric pollution cannot be pressurized with air drawn from the ambient atmosphere. Such chambers are supplied by ‘air’ prepared by mixing one volume of oxygen with four volumes of nitrogen. It is impractical to reconstitute large volumes of air with tolerances closer than 21 percent ± 2.5 percent. The code does not intend to imply that the use of compressed air cylinders in normal atmospheric areas (i.e., outside hyperbaric chambers) would create an oxygen-enriched atmosphere. The compressed air expands as it leaves the cylinder, drops to normal atmospheric pressure, and is not oxygen-enriched. This definition varies slightly from the one appearing in NFPA 53, Recommended Practice on Materials, Equipment, and Systems Used in Oxygen-Enriched Atmospheres [12], which states that the concentration of oxygen in the atmosphere exceeds 21 percent by volume or its partial pressure exceeds 21.3 kPa (160 torr). The scope of the definition is limited to the way the term is used throughout NFPA 99. The definition is independent of the atmospheric pressure of the area and is based solely on the percentage of oxygen. In defining the term, the issue of environments, such as a hyperbaric chamber, where the atmospheric pressure can vary, was taken into consideration. Under normal atmospheric conditions, oxygen concentrations above 23.5 percent will increase the fire hazard level. Different atmospheric conditions (e.g., pressure) or the presence of gaseous diluents, however, can actually increase or decrease the fire hazard level even if, by definition, an oxygen-enriched atmosphere exists. An oxygen-enriched atmosphere, in and of itself, does not always mean an increased fire hazard exists.”

At the moment, given the definition above, I can’t think of anything other than hyperbaric environments that would be covered under the new requirements, but I’ll keep my ear to the ground and pass on any information that seems worth sharing; beyond that, I would do an analysis of equipment for hyperbaric therapy and go from there.

When we consider how we’re going to make this happen (if it isn’t already; I’m thinking/hoping that the gas equipment suppliers are paying attention to the new rules), at the end of the day, compliance with Joint Commission standards and performance elements rests solely in the hands of the organization. Again, presumably/hopefully/expectantly, the vendors from whom you obtain medical gases, equipment, etc., will be familiar with the requirements as they are based on the currently adopted/approved version of NFPA 99, as well as the requirements of the Compressed Gas Association (CGA). I would reach out to them to see what their plans are for compliance, remembering that (at least for the moment) the new requirements apply only to the gases and equipment used in oxygen-enriched atmospheres. I suspect that there will come a time when all related equipment, etc., is similarly labeled, but you may find that in the short term that you will have to keep a close eye on equipment used in surgery, hyperbaric oxygen, etc., to ensure that everything is as it should be. The general concept of not using oil on oxygen equipment is not new, so it may be that this is not going to be as big a struggle as might first appear. I’d be interested in finding out what you learn from the vendors you’re using, just to establish a baseline for advising folks.

 

Breaking good, breaking bad, breaking news: Ligature Risks Get Their Day in Court

As I pen this quick missive (sorry for the tardiness of posting—it was an unusually busy week), the final vestiges of summer appear to be receding into the distance and November makes itself felt with a bone-chilling greeting. Hopefully, that’s all the bone-chilling for the moment.

Late last month brought The Joint Commission’s publication of their recommendations for managing the behavioral health physical environment. The recommendations focus on three general areas: inpatient psychiatric units, general acute care inpatient settings, and emergency departments. The recommendations (there are a total of 13) were developed by an expert panel assembled by TJC and including participants from provider organizations, experts in suicide prevention and design of behavioral healthcare facilities, Joint Commission surveyors and staff, and (and this may very well be the most important piece of all) representatives from CMS. The panel had a couple of meetings over the summer, and then a third meeting a few weeks ago, just prior to publication of the recommendations, with the promise of further meetings and (presumably) further refinement of the recommendations. I was going to “cheat” and do a little cut and pasting of the recommendations, but there’s a fair amount if explanatory content on the TJC website vis-à-vis the recommendations, so I would encourage you to check them out in full.

Some of the critical things (at least at first blush—I suspect that we, as well as they, will be discussing this for some little while to come) include an altering of conceptual compliance from “ligature free” to “ligature resistant,” which, while not really changing how we’re going to be managing risks in the environment, at least acknowledge the practical reality that it is not always possible to provide a completely risk-free physical environment. But we can indeed appropriately manage the remaining risks by appropriate assessment, staff monitoring, etc. Another useful recommendation is one that backs off on the notion of having to install “alarms” at the tops of corridor doors to alert that someone might be trying to use the door as a ligature point. It seems that the usefulness of such devices is not supported by reported experience, so that’s a good thing, indeed.

At any rate, I will be looking at peeling these back over the next few weeks (I’ll probably “chunk” them by setting as opposed to taking the recommendations one at a time), but if anyone out there has a story or experience to share, I would be more than happy to facilitate that sharing.

As a final note for this week, a shout out to the veterans in the audience and a very warm round of thanks for your service: without your commitment and duty, we would all be the lesser for it. Salute!

 

Workplace Violence: One Can Never Have Too Much Info…

I will freely admit that sometimes it takes me a while to get to everything that I want to share with you folks and this is one of those instances…

Back in May (yes, I know—mea culpa, mea culpa, mea maxima culpa—it was even longer ago that I was an altar boy), ECRI Institute published some information on violence in healthcare facilities that includes a white paper, some guidance on how to share the risk landscape of your facility as it relates to workplace violence and some other information that is accessible upon enrolling in a membership program (they have quite a few different programs, this week’s stuff comes from the Healthcare Risk Control program). I suspect that the provided information may be representative of a loss-leader to drive traffic to their website and service programs (much as this blog is a labor of love and obsession, its function is rather much the same—I don’t know that they would put up with my yammering otherwise), but the information available through the above links are certainly worth checking out (there are also free newsletters; as noted in this week’s headline, information coming directly to you saves having to hunt it down).

Another item on my mental to-do list (and it may very well be that it is on my to-done list, but a little reiteration never hurt anyone) was to encourage you to keep an close eye on The Joint Commission’s standards FAQ page (you have to do a lot of scrolling to get to the Hospitals section—they’ve changed the formatting of this section of their website and it just feels quite clunky to me). At any rate, there are way more FAQs than there used to be (maybe more than there needs to be, but if you make the presumption that the characterization of these questions as being frequently asked, then it is what it is) and you can’t really tell which ones have changed (they do highlight new FAQs; lots of pain management stuff on there right now). They used to include a date so you could more or less keep track of stuff. I’m going to guess that there’s going to be a lot of following up relative to the whole management of ligature risks—and make sure you talk to your organization’s survey coordinator to make sure you access the Suicide Risk Booster (there just seems to be something odd about that as a descriptor). As much as any issue there’s ever been in the physical environment, the management of ligature risks is one for which you cannot be too well prepared (think an infinite number of Boy Scouts and you’ll be moving in the right direction).

 

Fall On Me: Keeping Emergency Management Changes in Perspective

As I was ruminating on a topic for this week’s conversation, the October issue of Perspectives came zipping over the electronic transom, and I think there is just enough stuff here to cobble together a relatively cogent offering to you all out there in the blogosphere (that’s right—after 10+ years, I’m working on cogency—who’d a thunk…)

First up is the announcement of proposed changes to the Emergency Management chapter (I say proposed, because the indication is that these changes still require approval by CMS) with an intended survey implementation date of November 15, 2017 (when the Emergency Management final rule takes full effect). From my experiences with folks, I still don’t think they’re barking up a tree for which we cannot (collectively) provide a reasonable response, but if you’re interested in what they think they need to change in the standards, the list of additions includes consideration of:

  • Continuity of operations and succession plans
  • Documentation of collaboration with local, tribal, regional, state, and federal EM officials
  • Contact information on volunteers and tribal groups
  • Documented annual training of all new/existing staff, contractors, and volunteers
  • Integrated health care systems
  • Transplant hospitals

Again, I don’t see anything that strikes me as being particularly daunting, though there’s still a fair amount of angst relative to these changes (as is the case with anything that changes). I know there’s been some consternation relative to managing Memorandums of Understanding (or Memoranda, if that be your preference) and Alternate Care Sites, but I think the important thing to keep in mind is that the journey to the Final Rule started back when the 2008 TJC standards were in full bloom. And I suspect that those of you who have been doing this for a while recall those heady days of focus on MOU’s, ASC’S, COOP’s and the like, concepts that have really kind of faded into the operational ether as the efficacy of those approaches has yielded wildly inconsistent levels of preparation. For some folks, MOU’s, ASC’s and COOP’s are essential, but I’ve also seen evidence that when the feces is striking the rapidly rotating blades, it is often the group that shows up first with the closest thing to cash that has access to resources. When you think about it, things like MOU’s are only an agreement to do the best one can under the circumstances—that’s why the interface with local and regional EM authorities is so very important. At any rate, next we’ll chat a bit about what the CMS survey instructions involve and why I think you folks are going to be in pretty good shape. I am curious as to whether or not there is an intent to modify the emergency response exercise requirements to more closely mirror the Final Rule—I guess all in the fullness of time.

Moving on to other Perspectives topics, it would seem that last month’s Clarifications and Expectations column was indeed the last official communication under George Mills’ direction. The column is on hiatus for the moment—I guess we’ll have to wait and see whether November brings it back (though oy could certainly make the case that EC-EM-LS topics are taking up a fair amount of space in the monthly Perspectives, Clarifications and Expectations columns notwithstanding).

There is a new Sentinel Event Alert (#58!) regarding issues relating to inadequate hand-off communications; the reason I mention it here is that, while the focus in Perspectives is very much on the clinical side of things, I think there is more than a little crossover into the safety / physical environment realm. I’m just planting the seed here, but I suspect that I will have more thoughts on this in the coming little while.

Finally (for this week), there is a piece on Workplace Violence as a function of screening for early detection of risk to harm self or others. I suspect that this may be a harbinger of next steps as it relates to how organizations are managing at-risk patients, particularly as a function of the current focus on ligature risks. In recognition that all the risks that are not medically/clinically necessary have removed, if you don’t have a pretty robust screening process in place, it makes it very challenging to manage the risks that remain. At any rate, I’d keep an eye on this one—much as they’ve been peeling the Infection Control “onion” over the past couple of years, I think this is how they’re going to expand focus in the behavioral health realm.

But, as a subset of that, I did want to muse a bit on those instances when entities that were thought of as “friendly” turn out (under certain circumstances) to be not so much. I suspect that most of you saw the news item back in July regarding the nurse working in the ED of a hospital in Salt Lake City, UT, who was forcibly arrested by local police for not acquiescing to a request that was not allowed by organization policy (if you missed it, you can see some of the story here or here.) I mention this only to point out that the management of this stuff is not always simple (OK, it pretty much never is simple), but this does offer up yet another facet to how facilities safety and security professionals have to proactively advocate for staff (and patient) safety. Some of the images of the arrest are most harrowing and definitely beg the question of how this came to pass in this day and age (or maybe it’s not as questionable an outcome as perhaps it might once have been). At any rate, it’s always important to periodically review what I refer to as the “rules of engagement,” particularly when it comes to interacting with law enforcement folks. If our folks can’t be protected from our “friends,” then what shot do we have against an unknown/unknowable “foe.”

Keep calm and stock up on emergency supplies

Hospitals are generally prepared for emergencies, but don’t be afraid to kick those tires one last time.

I don’t know that this last spate is officially the most congested high-intensity weather pattern we’ve ever encountered, but it has got to be right up there in the uppermost tier. As we continue to keep our thoughts on those who have been managing the effects of Harvey, Irma, and Jose, I suppose it’s only a matter of time before the critiques start arriving.

I do believe that hospitals in general are appropriately prepared to respond to emergencies (and I know for certain a number of hospitals that appropriately prepared). As I pen this, I am sitting at the airport in Charlotte, North Carolina, waiting to see if Irma is going to let me get to some client work this week or force me to be Boston-bound.

My philosophy about these things is that there is very little, if any, control that can be exercised as events unfold; the only true aspect of control is to be able to position yourself to make good decisions for the duration of whatever event you might be facing. From what I can gather, this was very much in effect as hospitals in the southeastern U.S. and into the Caribbean responded to recent weather events.

Not every physical plant fared as well as some, but one of the quirky things about catastrophes is they tend to be, well, catastrophic—if it had been business as usual, we probably wouldn’t be talking about it at the moment. At any rate, kudos to those folks who did what they had to do to keep things together, and our best to those for whom every preparation in the world could not have been enough.

In other news

I was going through some stuff I’ve had in the queue for a while that really didn’t fit thematically in the conversation of the week but that I think would be useful to bring to your collective attention. So, in brief (some of you will probably question my definition of brevity, but I can live with that), here they are:

  • For the foreseeable future, there will be a fair amount of scrutiny of the physical environment in your outpatient locations, and a key component of managing those environments is making sure that the folks who are keeping the place clean are on top of their game. It is not uncommon for organizations to have to use independent contract cleaning services for their outpatient locations, but clean is clean is clean—and we know some of the surveyors are not shy about getting out their white gloves and rooting around for GFM (gray fibrous material, a.k.a. dust). Patient environments need to be properly maintained–and you know who’ll suffer the consequences if that’s not happening.
  • Back in April, our friends in Chicago, The Joint Commission, published Quick Safety 32: Crash-cart preparedness; while not everything on their list is specific to the physical environment, there is a lot of fair info relative to process. There are certainly safety and security (not to mention life safety) implications if resuscitation supplies and equipment are not properly maintained—and this applies to your outpatient settings as well. Keep an eye on crash carts wherever they may be.
  • Finally, (and going way, way back to January 2017), The Joint Commission’s Quick Safety 30 covered the all-too-current topic of protecting patients during utility system outages. I think we can all agree that this summer has brought a few too many opportunities to test our mettle in this regard (and, again, great job everyone!), but, as we all know, utility systems can crap out at any time, with minimal warning. So, the watch words (or watch concepts, as it were) are “contingency” and “plans”—redundancies, staff ability to respond to disruptions, etc. are some of the keys to success. Quick Safety 30 also provides a couple of links to some contingency planning resources. The truism underneath all this stuff is that one can never be too prepared, so don’t be afraid to kick those tires one last time.

 

Any world that I’m welcome to…

Sometimes a confluence of happenings makes me really question the legitimacy of coincidence. For example, it can’t possibly be coincidence that our friends in Chicago use the backdrop of September to tell us how poorly we are faring relative to compliance in the management of the physical environment. Yet, like clockwork, September brings the “drop” of the most frequently cited standards (MFCS) during the first half of the year. (I did look back a few years to validate my pre-autumnal angst—they waited until October to publish the MFCSs in 2012.) And, for a really, really, really long time, the physical environment continues to maintain its hegemony in the hierarchy of findings.

In years past, we’ve analyzed and dissected the living heck out of the individual standards, looking at the EPs likely to be driving the numbers, etc. Anybody wishing to revisit any of those halcyon days, you can find the (not quite complete) collection here:

Anyhoooo… I really don’t see a lot of changes in what’s being found, though I will tell you that there has been a precipitous increase in the number of organizations that are “feeling the lash.” Last year’s most frequently cited standard, which deals with various and sundry conditions in the care environment (you might know it as EC.02.06.01, or perhaps not), was found in about 62% of organizations surveyed. This year, the percentage has increased to 68% of organizations surveyed, but that number was only good enough for 5th place—the most frequently cited standard (the one that deals with all that fire alarm and suppression system documentation*) was identified in a whopping 86% of the hospitals surveyed!

I think it’s important, at this point, to keep in mind that this is the first year of a “one and done” approach to surveying, with the decommissioning of “C” or rate-based performance elements. I don’t know that I have encountered too many places with absolutely perfect documentation across all the various inspection, testing, and maintenance activities relating to fire alarm and suppression system documentation. I also don’t know that I’ve been to too many places where the odd fire extinguisher in an offsite building didn’t get missed at some point over the course of a year, particularly if the landlord is responsible for the monthly inspections. Face it, unless you have the capacity to do all this stuff yourself (and I’m pretty sure I haven’t run into anyone who has unlimited resources), the folks charged with making this happen often don’t have an appreciation for what a missed fire extinguisher, missed smoke detector, etc., means to our sanity and our peace of mind.

As I’ve been saying right along, with the exceptions being management of the surgical environment and the management of behavioral health patients, what they are finding is not anything close to what I would consider big-ticket items. I refrain from calling the findings minutiae—while in many ways that is what they are, the impact on folks’ organizations is anything but minute. If the devil is indeed in the details, then someone wicked must have passed their CORI check for a survey job…

Relative to last week’s rant regarding policies; first a shout-out of thanks to Roger Hood, who tried to post on the website (and was unable to ) regarding the CMS surveyor Emergency Preparedness survey tool as a potential source for the TJC policy requirement. (It’s an Excel spreadsheet, which you can find here, in the downloads menu near the bottom of the page: Surveyor Tool – EP Tags.) While I “see” that a lot of the sections invoke “policies and procedures,” I still believe that you can set things up with the Emergency Plan (Operations / Response / Preparedness—maybe one day everyone will use the same middle for this) as your primary organizational “policy” and then manage everything else as procedures. I suppose to one degree or another, it’s something of an exercise in semantics, but I do know that managing policies can be a royal pain in the tuchus, so limiting the documents you have to manage as a “policies” seems to make more sense to me. But that may just be me being me…

*Update (9/7/17): Quick clarification (I could play the head cold card, but I should have picked up on this); the most frequently cited standard deals with fire suppression system stuff—gray fibrous material (GFM) on sprinkler heads, 18-inch storage, missing escutcheons, etc. While I suppose there is some documentation aspect to this, my characterization was a few bricks shy of a full load. Mea maxima culpa!

I said you’ll pay for this mischief…

In this world, or the next! Stand by for news…

In this most momentous of years / survey cycles, it appears that there may be at least one more shift in the firmament, that being a transition for a most notable AHJ. The grapevine has been singing this week. (You can reference either the Marvin Gaye or Gladys Knight version; at the moment, I’m leaning toward an invocation of Marvin as it pushes a follow of “What’s Going On”—Brother, Brother, indeed!) There seems to be a changing of the guard afoot in Mordor (or Oak Park, Illinois—take your pick) as it appears that the estimable Director of Engineering for The Joint Commission, George Mills, is transitioning out of the crucible that provides so much in the way of heartburn in the industry.

Word is that one of the engineers in the Standards Interpretation Group (SIG), John Maurer, will be taking the director’s position on an interim basis. Not by any means a comparison (my personal dealings with the departing incumbent have always been reasonable and assistive), but my past interactions with Mr. Maurer have always been thoughtful, helpful and equitable, including indication of how one might plot a course toward satisfactory compliance. In that regard, I don’t anticipate that this will engender a significant change in how business will be conducted, including the practical administration of the Life Safety portion of the accreditation survey process. While details have not yet been officially confirmed, I have no reason to think that the information in general is incorrect, so all I can say is best of luck to everyone as they (and we) embark on their new journeys and pray for a resurgence of benevolence across the board.

To round things out for this week, I would bring your attention to last week’s Joint Commission Quick Safety Issue (QSI #35 in an ongoing series—collect ‘em like baseball cards!) and the topic du jour: minimizing noise and distractions in OR and procedural units.

Now, you’ll get no argument from me that there are certain environments and situations for which noise minimization is desirable, and perhaps, essential. And, empirically, I can’t disagree with any of the characterizations indicated in QSI #35—there are quite a number of footnotes, none of which I have had the time to track down, but, again, I have no reason to think that the scholarship of the article is anything less than spot on. I guess the thought/question/concern I have relates to the practical application of this as an improvement activity (keeping in full mind that sometimes surgeons like to operate to music that ain’t exactly in the realm of quiet—think AC/DC’s “Back in Black” and you’ll be on the right track).

QSI #35 has a whole list of “safety actions to consider,” and the indication is that these are actions that “should” be considered. (But how often have you seen a “should” become very musty during survey…) I wonder if you’ll have the leeway to make the determination of whether you are appropriately managing noise in the procedural environment. I suppose it’s good that this hasn’t shown up in Perspectives

You are so beautiful, to me…

In the interest of a little summertime reading, I wanted to diverge a bit from the usual rant-a-minute coverage (rest assured, the ranting will continue next week—too much going on in the world) and cover a couple of “lighter” topics (though one does have to do with my favoritest topic—risk assessments).

First up, we have Soliant Healthcare’s list of the 20 most beautiful hospitals in the U.S. (as a music lover, I find that I am an absolute sucker for lists—go figure!); while I have not had the opportunity to do any work at the listed facilities (and have done some work at places I think measure up pretty well from a design perspective, etc.), I can say that the buildings represented on the list are pretty easy on the eye. I don’t know if anyone out there in the Mac’s Safety Space blogosphere works at any of the listed facilities, but congratulations to you if you do or did!

The other item for this week focuses on the pediatric environment; from my experiences, a lot of community hospitals have really scaled back their pediatric care facilities, mostly because demand is not quite what it used to be. Where there might once have been dedicated pediatric units, now there are a handful of rooms used for pediatric patients when they need in-hospital care, but not much in the way of dedicated spaces.

If you happen to be in a position in which your dedicated pedi spaces are not quite as dedicated as they once were, you might find it useful to perform a little risk assessment based on a toolkit provided by the University of California, San Francisco, and endorsed by a couple of professional groups. While the focus is more towards the home environment, I think it’s helpful to simply ask the questions and be able to rule out the concerns outlined in the toolkit. Any time you have to “run” with an environment that has to function for different patients, risk factors, etc., it never hurts to be able to pull a risk assessment out of your back pocket when a surveyor starts jumping ugly because they don’t agree with what they’re seeing or how you’re managing something.

The National Center for Missing & Exploited Children used to provide some risk assessment guidance for healthcare professionals, but in looking at their website, it appears to me that they are confining guidance to law enforcement, media, and families. (Some of the stuff for families is interesting and worth sharing in general.) Since they’re an at-risk patient population, you never know when your efforts to provide an appropriate environment for infants, children, and teens will come under survey scrutiny—and it never hurts to periodically review your efforts to ensure that your plan is current.

Reefing a sail at the edge of the world…

What to do, what to do, what to do…

A couple of CMS-related items for your consideration this week, both of which appear to be rather user-friendly toward accredited organizations. (Why do I have this nagging feeling that this is going to result in some sort of ugly backlash for hospitals?)

Back in May, we discussed the plans CMS had for requiring accreditation organizations (AOs) to make survey results public, and it appears that, upon what I can only imagine was intense review and consideration, the CMS-ers have elected to pull back from that strategy. The decision, according to news sources, is based on the sum and substance of a portion of Section 1865 of the Social Security Act, which states:

(b) The Secretary may not disclose any accreditation survey (other than a survey with respect to a home health agency) made and released to the Secretary by the American Osteopathic Association or any other national accreditation body, of an entity accredited by such body, except that the Secretary may disclose such a survey and information related to such a survey to the extent such survey and information relate to an enforcement action taken by the Secretary.

So, that pretty much brings that whole thing to a screeching halt—nice work of whoever tracked that one down. Every once in a while, law and statute work in favor of the little folk. So, we Lilliputians salute whomever tracked that one down—woohoo!

In other CMS news, the Feds issued a clarification relative to the annual inspection of smoke barrier doors (turns out the LSC does not specifically require this for smoke doors in healthcare occupancies) as well as delaying the drop-dead date for initial compliance with the requirements relating to the annual inspection of fire doors. January 1, 2018 is the new date. If you haven’t gotten around to completing the fire door inspection, I would heartily recommend you do so as soon as you can—more on that in a moment. So, good news on two fed fronts—it’s almost like Christmas in August! But I do have a couple of caveats…

I am aware of 2017 surveys since July in which findings were issued because the inspection process had not been completed, and, based on past knowledge, etc., it is unlikely that those findings would be “removable” based on the extended initial compliance date. (CMS strongly indicates that once a survey finding is issued in a report, the finding should stay, even if there was compliance at the time of survey.) So hopefully this will not cause too much heartburn for folks.

The other piece of this is performance element #2 under the first standard in the Life Safety chapter. (This performance element is not based on anything specifically required by the LSC or the Conditions of Participation—yet another instance of our Chicagoan friends increasing the degree of difficulty for ensuring compliance without having a whole mess of statutory support, but I digress.) The requirement therein is for organizations to perform a building assessment to determine compliance with the Life Safety chapter—and this is very, very important—in time frames defined by the hospital. I will freely admit that this one didn’t really jump out at me until recently, and my best advice is to get going with defining the time frame for doing those building assessments; it kind of “smells” like a combination of a Building Maintenance Program (BMP) and Focused Standards Assessment (FSA), so this might not be that big a deal, though I think I would encourage you to make very sure that you clearly indicate the completion of this process, even if you are using the FSA process as the framework for doing so. In fact, that might be one way to go about it—the building assessment to determine compliance with the Life Safety chapter will be completed as a function of the annual FSA process. I can’t imagine that TJC would “buy” anything less than a triennial frequency, but the performance element does not specify, so maybe, just maybe…

Civilization and its discontents

A bit of a hodge-podge this week, with the thematic element of security being the tie that binds, so to speak. There continues to be a lot of news (or it certainly seems that way to me) lately about various security concerns, from violence in the workplace to incursions by unauthorized persons into restricted and/or sensitive areas. We have spent a fair amount of time on these subjects this year (and I somehow suspect that this won’t be the last time for discussion in this realm), but I did want to share some resources with you in case you missed them in the deluge of this, that, and the other thing. (I sometimes marvel that I manage to capture anything, given the fire hose of information constantly spewing into the ether, but I digress.) So, in (relative) brief:

Hospitals & Health Networks (H&HN) published a very interesting story last week about efforts by Milwaukee-based Aurora Health Care to use a clinical approach to reducing assaults in their workplace, including establishment of a Behavioral Emergency Response Team (BERT)—I think you’re going to become very familiar with this term. At any rate, a lot of valuable information, so if you’ve not yet checked it out, I would encourage you to do so (“Violence in the Hospital: Preventing Assaults Using a Clinical Approach“).

In the comment section at the end of the H&HN article, an individual left a comment regarding a public health film titled “One Punch Homicide” that might be of benefit as a preventive measure. I have yet to watch the documentary in its entirety—the trailer is pretty intense—then again, there’s nothing not brutal about violence. The film runs about 90 minutes, but, as information, if nothing else, it’s worth a look: www.onepunchhomicide.com.

As our final thought for this week’s adventure, our friends in Chicago are covering the dangers of tailgating. (I guess since the featured videos are Massachusetts-sourced, the concept of tailgating takes on a whole ‘nutha dimension.) As you will recall, a few months earlier, there was an incident involving an interloper at a hospital in Boston. Since then, the security folks have been hard at work coming up with inventive ways to get folks to use those eyes in the back of their head.

Since it is impossible to determine how much influence anything from Chicago might have on the survey front, I would encourage you (I’m very encouraging this week, aren’t I?) to check out the blog by Dave Corbin, director of security and parking at Brigham and Women’s Hospital in Boston, and maybe show these videos to your EOC Committee and maybe others in your organization—this is one of those things that is scary because it’s true (“Leading Hospital Improvement: New Campaign Illustrates Need for Staff Training on Dangers of Tailgating”).

Hope the summer is treating you well—keep it cool and keep it tuned to www.hospitalsafetycenter.com.