RSSAll Entries Tagged With: "ligature risk assessment"

I may not be perfect, but I’m perfect for you: CMS rates the accreditation organizations!

Another mixed bag of stuff for you this week, leading off with a quick spin through CMS’ report card to Congress.

While the numbers have shifted around a little, infection control is making a move on the outside, but the physical environment is still the big point of focus, though you can see where the two are starting to cross over at a greater frequency. I think issues relating to ligature risks are going to be a very sharp focus, particularly with CMS surveys. Although it is interesting to note that (at least at the moment) when ligature risks come up in the CMS survey process, those risks have been cited under the Patient Rights Condition of Participation (each patient has a right to receive care in a safe setting), so we may see Patient Rights at the top of the heap next year. One way you can avoid that little dance of ignominy is to make sure that you have completed a comprehensive ligature risk assessment in those areas in which you are managing behavioral health patients, including mitigation strategies for items that cannot be immediately corrected and solid anticipated completion dates. They are taking ligature risks very seriously because of the potential for harm to patients and you don’t want to have a whole lot of open-ended plans of correction. It almost comes down to a sense that everything that exists is a potential risk to be managed and while I am hopeful that cooler heads will prevail, right now this is a very, very hot topic.

One other thing to note with the report card is a section that deals with an analysis of survey disparity relating to Life Safety Code® compliance and health and safety considerations. I’ve looked at the contents of this section, including their conclusions and recommendations, and I have a hard time thinking that this is ever going to go away as a survey focus. While I tend not to rely on absolutes when it comes to periods of time, I can say quite confidently that there will always be stuff to find during a survey. You can look today and find stuff, you can look tomorrow and find different stuff, you can look the day after and—you guessed it! Stuff happens; people do stuff we don’t want them to, including unauthorized field modifications. The list is literally and figuratively endless. I know they have to find something, but as a collective, I think most hospitals are very well maintained and managed as a function of the physical environment. But if the big “C” knocks on the door (and I guess we have to include the minions as well), there’s going to be a list of stuff. Our job is to keep that list to a minimum. Good luck with that!

A quiet week in Lake Forgoneconclusion: Safety Shorts and Sandals!

But hopefully no open-toed sandals—maybe steel toed sandals…

Just a couple of quick items as we head out of the Independence Day holiday and into the heat of the summah (and so far, scorching has been the primary directive up here in the Northeast—hope it’s cooler where you are, but I also hope it didn’t snow where you are either…but I guess if you were in Labrador last week, all bets are off).

When last week’s musings on the ligature risk stuff in the July Perspectives went to press (or when I finished my scribbling), the new materials had not yet made their way to TJC’s Frequently Asked Questions page, though I thought that they might—and that’s exactly what has happened. To the tune of 17 new FAQs for hospitals, so if you haven’t yet laid eyes on the July Perspectives, head on over to the FAQ page and immerse yourself in the bounty (that’s a somewhat weird turn of phrase, but I’m going to stick with it).

While you’re there, you should definitely poke around at some of the other stuff on the FAQ page. There are lots and lots of recommendations for risk assessment types of activities, so if you’re looking for some risk minimization opportunities, you might find some useful thoughts. Of particular note in this regard is the practical application of safety practices in those organizational spaces for which your oversight is somewhat more intermittent; I’m thinking offsite physician practices or medical office buildings and similar care locations. Depending on where you are and where they are, it might not be quite so easy to keep a really close eye on what they’re doing. And while I tend to favor scheduling surveillance rounds with folks in general, I also know that if you don’t stop by from time to time, you might not catch any lurking opportunities (and they do tend to be lurksome when they know you’re coming for a visit). In a lot of the survey results I’ve seen over the last 18 months or so, there’s still a pretty good chunk of survey findings generated during the ambulatory care part of the survey process. Safety “lives” at the point of care/service, wherever that may be—definitely more ground to cover now that in the past. At any rate, I think you could use the FAQ stuff as a jumping off point to increase the safety awareness of folks throughout—and you can do that independently of anyone’s vacation schedule (including your own).

Hope you and yours had a most festive 4th!

While I hate to do anything to muddy the waters…with paper clips!

Or ear buds…

In the absence of anything particularly controversial on the regulatory front, I tend to go back and cover “old” ground just to see if there are any new resources, altered realities, etc. So, last week I was doing some work that involved helping folks with their ligature risk assessment and was pondering the availability of ligature-resistant fire alarm notification appliances. This pondering led me to my usual primary source for such things, The Design Guide for the Built Behavioral Health Environment (now an offering from the Facilities Guidelines Institute); we’ve discussed the particulars of the Design Guide on any number of occasions, most recently back in late 2016, and hopefully by now everyone has obtained a copy for their e-library. At any rate, I was poking around looking for ligature-resistant fire alarm notification appliances and, lo and behold, I couldn’t find any.

So (as I am wont to do) I headed off to the Googlesphere to see what might be out and about and (in yet another lo and behold moment) found the latest edition of the New York State Office of Mental Health’s Patient Safety Standards, Materials and Systems Guide. As near as I can tell from the webpage, this is the 19th edition of this particular guide, though I will tell you that this is my first encounter and I think it’s pretty spiffy (I’m guessing you folks in the Empire State knew about this and kept it to yourselves…). One of the most interesting elements is that it covers what they recommend (including whether they’ve found the products, etc., to be effective based on the acuity of the setting), but they also list stuff that they have tested and found does not work as advertised (I will admit to being fascinated with the idea that some of these ligature-resistant products can be defeated by strategies as simple as paper clips and/or ear buds—I guess necessity remains the mother of invention). Admittedly, there could be different philosophies in other jurisdictions, but I can really appreciate the thought, analysis, and general effort that went in to this resource and I think the risks/benefits/alternatives are sufficiently clear cut that you could communicate the issues very effectively to those reluctant surveyor types. At any rate, I encourage you (yet again) to add this one to your resource library.

I’ve also learned that as folks work through the various and sundry parameters of the regulatory guidance sets floating around, folks have been considering the management of risks in relatively unsecured (at least in terms of ligature-resistance) common areas (lobbies, stairwells, offices), which (surprise, surprise surprise!) got me to thinking…

I think the appropriate strategy for these other areas needs to start with whatever clinical assessment/determination would need to occur before patients would be able to access unsecured common areas; to my mind, patients that are legitimately at risk of self-harm either need to have services come to them on the secured units or they are sufficiently escorted (sufficiently meaning enough folks to control a situation should it start to get out of hand). By nature, every organization has areas of greater and lesser levels of security, so the “burden of the process” (if you will) is to ensure that patients are not unilaterally exposed to risks greater than their (or, indeed, our) capacity to manage them. While the minimization of physical risk is a safety “function,” ensuring that patients are managed in an appropriate environment is a clinical “function” based on the needs/condition, etc., of the patients. For example, if a patient is clinically “well” enough to have access to the advocate beyond the advocate coming to see them on the unit, then my expectation would be that that determination would be made by the clinical folks, with full knowledge of the involved risks. I think (at least until CMS or someone else provides additional/different interpretations) that going with the stratification used by The Joint Commission, which for all intents and purposes parses out into inpatient psychiatric unit environments, acute care inpatient environments and emergency department environments, should remain the focus of your assessment and risk management activities. After all, the clinical management of the patient must work in concert with efforts to decrease risk in the environment and vice versa—everyone working together is the only thing that’s going to bring us success (which is rather a common strategy…).