One of the benefits of doing a lot of traveling and having a fairly well-developed case of OCD is having plenty of time to ponder ponderables and imponderables (I think it may be more fun than it sounds, but there are days when I’m not at all sure). At any rate, one of the things I’ve been tossing around in my head is the whole deal with the testing of defibrillators, particularly in areas that are not open 24/7. I suspect that, in most, if not all, instances, defibrillators are considered to be in the high-risk/life support category (I don’t think I’ve run into anyone that is managing them otherwise), so the question becomes this: in light of the Joint Commission performance elements indicating that high-risk/life support equipment is to be maintained in accordance with the Original Equipment Manufacturer (OEM) recommendations, if you have defibrillators in your inventory that require daily user testing (or some similarly constructed variation) and have those defibrillators in areas that are not open 24/7, how are you ensuring compliance relative to the OEM recommendations? I know of at least one hospital (which shall remain nameless) that does the user test on a once-monthly basis and I am curious as to how that might play out during a survey. Minimally, I think it would be a good idea to review the defibrillators you have in the inventory and see if there are any funky requirements/recommendations beyond the traditional preventive maintenance cycles. And please include the blogosphere when you figure out what you have; my fear is that this could become a means of generating more unpleasant findings during surveys if we don’t get out ahead of this thing. High risk and life support combine to make a very scary survey scenario in my mind’s eye (can you say immediate jeopardy?) and in the hands of a by-the-book, pain in the keister surveyor (not that there are any of those)…
This year has brought a lot of CMS work this year, both in preparation for impending visits and in response to endured visits. There’s just nothing particularly pleasant about the process, but I guess there’s naught that can be done for it.
One of the interesting, and extra not-pleasant developments in this realm is the use of the Plan for Improvement (PFI) process during CMS surveys to bludgeon facilities professionals into pretty much abandoning any pretense of being able to plan/prioritize the resolution of existing Life Safety Code® (LSC) deficiencies. As I think we’ve discussed, one of the changes in the Joint Commission final report is that (if your surveyor remembers to accept them) it includes a listing of all your PFIs, which gives the CMS LSC surveyors a ready-made starting point for their report (CMS has really never bought in to the whole PFI process for managing LSC deficiencies, which is very unfortunate). Recently, I worked with a client who had to complete all their damper repairs that were being managed through the PFI process and I started thinking about a number of folks who are managing their inaccessible dampers, etc., through the PFI process and then I start thinking, “Wouldn’t that suck a ton of eggs if the PFI report becomes a roadmap for CMS to have their way with folks?”
I guess this is all part of having to deal with the various authorities having jurisdiction (AHJ) and while I suppose not every AHJ is going to be prickly about this stuff, I am reasonably certain that there are those would who be more than happy to give folks a good regulatory thumping. We are in a time of great uncertainty and chaos as we are held to standards that are increasingly best noted as antiquities. But until we can get can somehow suborn a more rapid cycle of code/standard adoption, I guess we’re just going to have to spend far too much time and energy on things other than taking care of our patients.
Last week, I had the opportunity to make a presentation to some members of the Colorado Hospital Association (Many thanks to everyone who attended. It was a great pleasure having the opportunity. You guys rocked!) regarding the whole Physical Environment/Environment of Care focus during regulatory surveys of late. One of the items we discussed was the issue of The Joint Commission’s exhortation of folks to review/revise their smoking policy(s) in light of recent technological innovations in the realm of nicotine delivery systems and how to account for the risks associated therewith.
What I hadn’t planned on was a turn in the conversation towards the legalization of marijuana in Colorado and having to deal with that set of risks (I’m thinking snack sales in the hospital gift shops may get a wee bit of a boost) from a smoking policy perspective. Upon further thought (as I tend to do), while I was bicycling this morning the thought occurred to me that there’s potentially a whole host of risks associated with occupational safety, particularly as a function of impaired employees. We didn’t really talk about this piece of the puzzle last week, but I would assume (and yes, I know exactly what happens when one assumes) that you have to “run” with a general prohibition on consumption during work hours, much akin to a general prohibition of alcohol consumption during work hours. At any rate, I was wondering if any folks out there in radioland had given this much thought and whether anyone is prepared to share any nifty thoughts or plans they might have. I have a sneaking suspicion that as the movement to legalize cannabis gains momentum, this may figure in the future (maybe not so prominently—could be no big deal). Is anybody trying to get out in front on this?
Thanks again to the Colorado Hospital Association for last week’s presentation and for planting the seed for this blog entry (small pun intended).
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?