In full recognition that the Internet (including, I daresay, this august space) is a constant barrage of information (okay, information may be a more generous descriptor than some of the Web is entitled to, but…), every once in a while something comes flying through the ether that captures my thoughts and/or imagination (next week I’m going to share with you the latest in fire suppression techniques) and I feel inclined (I never want to think of this as an obligation) to share with you.
Now, some of you may be “old” enough to have experienced the time when Dwight David Eisenhower was president of these United States (as opposed to the “other” United States) and while he is famous for having facilitated the creation of a lot of far-reaching programs (the interstate highway system and NASA, to name but two), there was one productivity initiative that bears his name: the Eisenhower box. This derives from Eisenhower’s observation that “what is important is seldom urgent and what is urgent is seldom important.” I think I was generally familiar with the quote, though I can’t say that I’d ever seen it attributed to him.
At any rate, yesterday’s Flipboard email brought with it (among other things—Flipboard is a very interesting app and provides kind of off-the beaten-path content) an article from the Huffington Post outlining the Eisenhower box concept. I can’t provide the image in this space, so I encourage you to give it a look-see. The “box” is pretty much a 2 x 2 matrix outlining four possible actions—do, decide, delegate, delete—based on the important/not important, urgent/not urgent metric. For those of you in the studio audience with operational responsibilities, I can see where this might be a very useful tool for sorting through the flood of information that is your “day” (and I can’t think of too many folks who are in the position of having to manage the exact right amount of information and tasks every day). So I’d ask you to give a whirl and let the rest of this community know if it helped at all.
Over time, I’ve developed certain thoughts relative to the management of the survey process, one of which relates to the ever-changing (maybe evolution, maybe mutation) regulatory survey process and I think it boils down to a couple of basic expectations (at least on my part):
- You always run the risk of having a surveyor disagree with any (and every) decision you’ve ever made relative to the operational management of risk, particularly as a function of standards-based compliance
- Your (or indeed any) Authority Having Jurisdiction always reserves the right to disagree with anything they, or anyone else, has ever told you was “okay” to put into place (and this includes plan review for new or renovated spaces)
Recent survey experiences are littered with the remains of practices and conditions that were never cited in the past, but in the latest go-round have become representative of a substandard approach to managing whatever risk might be in question. For example, just consider how the survey of the surgical environment has changed (and changed very rapidly, if you ask me) from what was typically a fairly non-impactful experience (there were any number of instances in which the Life Safety surveyor didn’t even dress out to go into the OR proper) to the area generating the top three most frequently cited standards during TJC surveys in 2014. That, my friends, is a whole lot of schwing in the survey process.
The bottom line message is, more or less, based on the adage “Future expectations are not necessarily indicative of past experiences.” You have to look at everything you are doing as a function of how your practices/conditions actually comply with the standards. Just as there are many ways to skin the proverbial catfish (skinning a catfish makes more sense to me in this modern era than skinning a feline), there are many ways to comply with what are typically rather open-ended compliance standards. As long as you can “trace” the practice or condition back to compliance with the standards/performance elements, then, even if you have a surveyor who disagrees with your approach to things, you can feel comfortable that you can “go to the mat” post-survey, using the clarification process to demonstrate how your organization achieves compliance relative to the finding. As a somewhat related aside, it is important to remember that you are only required to respond to what is actually written in the finding. Very often I run into folks who want to respond to more than what is actually in the report, usually because they remember what the surveyor “said” during the survey. Surveyors, like everyone, have opinions about how and what and where, etc., and they certainly have every right to hold those opinions (sometimes in higher regard than is warranted, but I digress). Opinions are rarely based on an absolute standards-based requirement. So, the tip-off comes in different forms: Maybe they say you “should” do something in a certain way or something similarly non-definitive. They typically stay away from things that you “must” or “have to” do. You “have to” comply with the standards and you “have to” comply with your organization’s policies and procedures, but beyond those points, you have to chart your course of compliance. You know best what will work to effectively ensure that you have an appropriately managed care environment (and, presumably, the performance data to back up that knowledge).
While I would never want to be accused of overusing my little bully pulpit, I did want to bend your ears a bit by way of encouraging you to really consider signing on for next week’s webinar, Surgical Environment Compliance: Meet CMS and Joint Commission Requirements. The program is on Friday, May 8 @ 1 p.m. EDT (you can register here). Plus (and this may really sweeten the pot), I’m not the only speaker, so you won’t have to listen to me yap for the whole program. Sounds like a win to me…
To catch up a bit, I haven’t yet given you a rundown on the most frequently standards during TJC surveys in 2014 as there were some other pretty compelling topics (at least in my mind)—mostly because the year-end tally looked so very much like the mid-term results I figured the sense of urgency might not be quite as acute as it could be. But an interesting thing is happening in 2015 and it keys very much on the top three most-cited standards: EC.02.06.01, EC.02.05.01, and IC.02.02.01, all of which figure in the management of environmental conditions in (you guessed it!) in surgery (and other procedural areas). By the way, as a quick aside, who would ever have guessed that the EC-related standard to go to #1 on the charts wouldn’t have been Integrity of Egress (LS.02.01.20), which sits at a lowly #4. It’s almost like a boy band past its sell-by date, but I digress.
TJC is still looking at the issues related to the surgical/procedural environment and, doggone it, they’re still finding stuff that’s getting folks into trouble (that is, if you think, as I do, that having to endure a second visit from the Joint is rather more troublesome than not). I won’t tell you that I have a magic bullet for this, but my colleague Jorge Sosa and I will be discussing how this issue fits into the grand scheme of things as well as hopefully helping identify the potential pitfalls. And, perhaps most useful of all, you’ll have the opportunity to ask questions that may be the difference between sailing through your next survey or getting hung up because one portal in your OR isn’t pressurized in the right direction (and believe me, it happens way more than you probably think). Lots of stuff to consider and the time and place to consider it.
Be there or be somewhere else that won’t be nearly as entertaining (unless you’re not at work…)
My colleague Jorge Sosa and I wanted to take a moment of your time to remind you of our upcoming live webcast Surgical Environment Compliance: Meet CMS and Joint Commission Requirements to be held on Friday May 8 at 1 p.m. EDT. What a way to start the weekend! The 90-minute program will include a presentation of approximately 60 minutes with a 30-minute Q & A session to cover any questions you might have about the program content, or indeed anything else that strikes your fancy.
I really think you’ll find this program of great interest. The Joint Commission just unveiled the most frequently cited standards during 2014 surveys and the top three are all in the mix when it comes to managing conditions in the surgical environment (and beyond…we’ll cover that as well). We’ll be covering steps you can implement to avoid survey findings, as well as strategies for managing the process if you find yourself with some survey deficiencies.
At any rate, I’d like to invite you to join Jorge and me for a discussion of what is probably the most “dangerous” topic in the Environment of Care in maybe ever (this makes the management of Interim Life Safety Measures look like a walk in the park)!
Hope to “see” you on May 8. You can register for the program here.
Every once in a while (and I don’t think I abuse this privilege, but please feel free to disabuse me of that notion), I like to vent a little regarding those annoyances that can impact how the folks in the safety world carry out their duties. In this particular instance, I’d like to rant a bit about those members of the “safety committee” that seem only to attend meetings when there is an opportunity to stonewall/derail/obstruct, etc., the ongoing work of the committee.
Lately it seems a lot of folks are struggling to bring their active shooter response plans past the initial stages and move into the implementation phase. That struggle inevitably seems to revolve around those transient members that always seem to know when you’re committee is just about to “birth” a new policy or process and they glide into the action with reservations/objections/all manner of constipations to set things back, without having participated in the work leading up to that point.
In my heart of hearts, I know that this is not very collegial behavior, but the question I have for the community is: How are you managing these occasions? My philosophy (which can be sorely tested from time to time) is that you have to birth the policy before you can tell for sure how well it will (or won’t) work when you operationalize it. I guess the analog to that is that it is better to have a flawed policy that you can work to improve than it is to have no policy at all, particularly to manage critical functions or risks. It is very, very difficult (certainly bordering on impossible) to come up with perfection without doing some trialing in the real world (maybe it’s possible, but I can honestly say I’ve never encountered it). I suspect this has happened to many (if not most, and probably all) safety professionals. Anybody have any inventive solutions for organizational blockages? Please sing out—let the world in on your secret!
Meet the new Survey Activity Guide, same as the old Survey Activity Guide (with apologies to the ‘Orrible ‘Oo)
Sorry I’m a little tardy on this one. I’ve been juggling a bunch of blog ideas and this one faded to the back of the pack a bit.
Back in January (and it seems so very long ago, perhaps due to the lovely weather we’re experiencing in the Northeast), The Joint Commission released the 2015 Survey Activity Guide, which details the ebb and flow of the survey process. Fortunately, they always identify a means of determining what is new (presumably as a function of 2014 Guides and so on), so I always look for any changes to the EC/EM/LS troika to see if anything funky has come to the fore.
Strangely enough, there are three documents that are indicated as being “new” that I’m pretty sure have been in the mix for at least a little while: your written fire response plan, your Interim Life Safety Measures Policy, and your fire drill evaluations. To fact-check myself, I went back to the 2013 SAG (I was a little lazy and skipped the 2014) and sure enough, all three were identified as “new” to the mix back then (I don’t seem to have a copy of the 2012), so no big surprises on the document front.
Likewise, the EC/EM interview sessions appear to be consistent with survey practice for the last couple of survey cycles. To be honest, I’m not entirely convinced that there’s a lot of exposure for organizations during these sessions, so long as the group is “chatty.” I think a good measure of how well you’re doing is in inverse proportion to the number of questions the surveyor has to ask to keep things moving. Strictly speaking, these sessions are designed to gain information on how organizations manage risk/respond to emergencies and how planning and preparedness activities function as a means of improving the various component programmatic elements. You should be able to discuss how the program has gotten “bettah” (I like to inject a little of the Bostonian vernacular from time to time), with an eye towards the use of data to demonstrate/support the notion that things have improved. I’ve not heard of anyone getting in trouble during these sessions, but I suppose there is always the potential for some misfortune. I think as long as there is recognition that compliance is a journey and not a destination, folks will be comfortable describing that journey (including setbacks) with winning survey results.
In the February 11, 2015 issue of Joint Commission Online, there’s an interesting piece recommending organizations review their smoking policies to ensure that the risks associated with electronic cigarettes are being properly managed. The primary risk identified in the article relates to the potential for fire events, including issues with rechargeable batteries, though it does touch on potential issues with the vapor/smoke generated by the devices (and I can tell you from a close-up encounter with the vapor cloud during a hospital visit, the smell is kind of noxious) and the importance of environmental separation (ventilation, etc.). As a final inclusion, the article reasserts (so to speak) that Joint Commission standards do not require hospitals to be smoke-free (allowing provisions for smoking in specific circumstances), so those of you who have gone that route (and may be experiencing a bit of a struggle—particularly if your community is not quite ready to embrace the smoke-free environment) may be interested in the brochure provided by The Joint Commission (you can find the brochure here). It certainly can’t hurt to check it out; and adopting it as a reference in your policy might be enough to dodge a finding during survey. I mean, come on, it’s all about best practices, n’est-ce pas?
In a February 18 Joint Commission leadership blog post, Mark Crafton, TJC’s executive director of communications and external relations, focuses on the benefits of investigating different approaches for mitigating violence in hospitals. At least that’s where the conversation starts, but it ends up in kind of an interesting (and to my eyes, unexpected) direction: the question of whether hospital security officers are a more effective deterrent/mitigation strategy when they are armed. (N.B.: In Crafton’s post, he refers to security “guards”; call me whatever you like, but I think the term “guard” just doesn’t ring well with me. I’m okay with the terms “security staff” or “security officers,” but “guards” just gives me the vapors—metaphorically speaking, of course.)
In the course of the posting, Crafton points to an article in the Chattanooga Time Free Press that will likely generate some debate among healthcare security professionals, and I tend to agree with that thought. Apparently the article was the result of a healthcare system’s decision to disarm their security staff and adopt the “soft” uniform look (e.g., blazers, etc.) to more effectively emphasize the security officer’s role as a more customer-oriented (my description) countenance. Now we’ve touched on the subject of arming security officers in the past (it’s been a really long time) and it’s probably way past the time for looking at this topic, particularly as the good folks at CMS have some rather strong thoughts on the subject:
CMS does not consider the use of weapons in the application of restraint or seclusion as a safe, appropriate health care intervention. For the purposes of this regulation, the term “weapon” includes, but is not limited to, pepper spray, mace, nightsticks, tazers, cattle prods, stun guns, and pistols. Security staff may carry weapons as allowed by hospital policy, and State and Federal law. However, the use of weapons by security staff is considered a law enforcement action, not a health care intervention. CMS does not support the use of weapons by any hospital staff as a means of subduing a patient in order to place that patient in restraint or seclusion. If a weapon is used by security or law enforcement personnel on a person in a hospital (patient, staff, or visitor) to protect people or hospital property from harm, we would expect the situation to be handled as a criminal activity and the perpetrator be placed in the custody of local law enforcement.
The use of handcuffs, manacles, shackles, other chain-type restraint devices, or other restrictive devices applied by non-hospital employed or contracted law enforcement officials for custody, detention, and public safety reasons are not governed by this rule. The use of such devices are considered law enforcement restraint devices and would not be considered safe, appropriate health care restraint interventions for use by hospital staff to restrain patients. The law enforcement officers who maintain custody and direct supervision of their prisoner (the hospital’s patient) are responsible for the use, application, and monitoring of these restrictive devices in accordance with Federal and State law. However, the hospital is still responsible for an appropriate patient assessment and the provision of safe, appropriate care to its patient (the law enforcement officer’s prisoner).
As you can well imagine, equipping security staff with weapons of almost any stripe can result in the classic slippery slope. My personal practice was to have a clear delineation between security staff and law enforcement responders. Security staff were provided ongoing crisis management education and worked closely with clinical staff to proactively manage at-risk situations. Law enforcement response was summoned when appropriate and the use of weapons was solely at the discretion of those responders. I know those lines can get pretty blurry in the heat of the moment, but specific roles are, I think, the best starting point for an effective security program.
At any rate, Crafton goes on to discuss the following: the cases for armed/not armed security staff; armed staff as authority figures vs. armed staff as a potential for raised anxiety of patients who are already distressed/stressed; and how do you make patients and staff safe, etc. There are, of course, good arguments on both sides, but ultimately (and this is one of the common threads when it comes to TJC standards and expectations), it is the responsibility of each organization to determine how best to manage, in this case, security risks. It doesn’t seem likely that peace, love, and understanding are going to be breaking out any time soon; the role of the security officer has never been more important.
Because someone else will come along and move it—and it’s always been the same…
Returning to the Adding Insult to Injury desk here at the Safety Space plaza (with apologies to the Magliozzi clan), last week we learned of a delightful new development in the ongoing saga of the management of environmental conditions in surgery. You can find the opening salvo in this little skirmish here. To recap, back in January, AHA/ASHE/AHRMM issued a Joint Quality Advisory indicating that there may be supplies and equipment that are not/were not manufactured to tolerate the lower humidity levels (down to 20% relative humidity) that could be in place based on the Categorical Waiver issued back in 2013 (details here). In the Quality Advisory, there was a recommendation for a risk assessment, etc., to ensure that any risks associated with equipment/supplies and the lower humidity levels are being appropriately managed.
But apparently, that was not enough tumult to introduce into the mix (it almost makes me long for those halcyon first days of the relocatable power tap dictum). To wit, CMS (in its way beyond infinite wisdom) has weighed in on the topic of supplies and equipment that may not tolerate the lower temperature and humidity levels allowed by the categorical waiver. The sum and substance of the CMS position echoes the risk assessment process outlined by AHA/ASHE/AHRMM, but does it one step further by indicating that until the assessment has been completed and you know all your “stuff” can appropriately tolerate the lower humidity levels, you have to go back to the pre-waiver humidity levels. By the way, that could mean either the 30% low point indicated by ASHRAE or the 35% low point indicated by NFPA 99-1999. You can find links to the memorandum issued by CMS here. By the way, this memorandum is also notable for the appearance of a kicky new term—IFU (instructions for use)—to add to the pantheon of acronymic stardom. Welcome IFU!
Now, I think we can all agree that looking at all the supplies and equipment being stored in these sensitive areas is going to be a fairly labor-intensive pursuit (Can you say pain in the gluteus maximus? I knew you could!) and it makes me wonder if there’s a way to push back at our vendors to help in at least reducing the number and type of materials we would need to evaluate. The Joint Quality Advisory makes note of some examples of materials that could be in the mix—EKG electrodes are noted—but I can’t help but hope that someone, somewhere is starting to parse this into a more manageable pursuit. I fully recognize that this is probably something of which everyone should already be aware; the CMS memo is rather pointed in mentioning just that: “The CMS expects hospitals, CAHs, and ASCs to follow the current IFUs for supplies and equipment used in their ORs. Failure to adhere to the IFUs must be cited, even if the facility has opted to use the categorical waiver of the [Life Safety Code] RH requirements.”
Sometimes doing the right thing ain’t so easy…
(P.S. If you’re interested in learning more about this topic, Jorge Sosa and I will host a webcast, “Surgical Environment Compliance: Meet Joint Commission and CMS Requirements,” on Friday, May 8 at 1 p.m. Eastern. Find out more and register online here.)
I suspect that the conversations regarding the number of EC and LS findings are likely to continue for the foreseeable future, for all the reasons we’ve discussed in the past and probably some that haven’t occurred to me yet, but surely will. At any rate, I want to encourage you to grab a copy of the February 2015 issue of Joint Commission Perspectives and turn directly to p. 10, on which begins a discussion of the use of dashboards as a means of keeping EC/LS compliance on the front burner. The article (part of George Mills’ ongoing series of Clarifications and Expectations) shows some dashboard examples, as well as providing links to some tools on the Joint Commission Resources website (including a blank form suitable for use in your very own organization). Heck, it even outlines a six-step process for setting up your own dashboard if the one from JCR doesn’t quite fit the bill. All in all (as much because it pretty much reiterates what I’ve been preaching almost since the beginning of time, but I digress), a most worthy addition to the safety canon and a resource that you would be well-advised to consult as you start to formulate your calendar year 2015/fiscal year 2016 activities.
All that said, I would encourage you, particularly as any number of you are embroiled in your annual evaluation process, to look over the information and make a (very, very) good faith effort to adopt at least the dashboard concept, if not an outright adaptation of the formats included in the article. One of the truisms of the compliance game is that anything that shows up in Perspectives is potentially surveyable/enforceable as a standards-based requirement, so there is a pretty fair likelihood that the surveyors are going to start looking for something along these lines when they next stop by your place for a visit. But please don’t look at this as one more thing to do; if you set this up and operationalize this properly, you will gain a great deal of information on where your organization stands on the compliance continuum, plus you will have data that you can use to clarify findings that may come up (okay, probably will come up) during survey. As always, it goes back to the management of imperfections in the environment—you know they’re there, I know they’re there, TJC knows they’re there. Our best “safety net” is to be able to demonstrate an ongoing process for managing those imperfections. Identify those pesky vulnerabilities and you are on your way!
One bit of caveat emptor, p. 13 includes a sample “In-Depth Data Analysis Worksheet,” which in this case is being used to collect data on the Daily Verification of Appropriate Air Pressures for In-Use Rooms. And you might well note that there is no specific requirement for the daily verification of appropriate air pressures for in-use (or indeed any other) rooms. For some strange reason, this one is giving me a bit of the willies as I can certainly see an instance in which a surveyor might interpret this to mean that there is such a requirement. It may be much ado about nothing (and I, for one, hope that is indeed the case), but probably something worth keeping an eye on.