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Time has come today—but you don’t have much of it!

One thing for your to-do list (if it’s not already on your done list) is to take a few moments (okay, maybe a couple more than a few moments) to look over the proposed changes to the way CMS is going to be requiring hospitals to undertake emergency management activities.

You can get the skinny here. The caveat in all this is that you only have until the end of this month to provide feedback on the requirements. Forgive me for being a doom and gloom kind of guy, but something tells me that this is not going to be merely a kind of realignment of resources, etc. I think there is a fair amount of potential for this to cause a lot of heartburn for facilities/safety folks.

Fortunately, the webpage lays out pretty nicely, with click-through links and such, which allows pretty slick navigation of the requirements. I don’t think I’m going to surprise anyone by saying that while there are some consistent concepts, etc., between the proposed requirements and the Joint Commission’s Emergency Management chapter, the two don’t necessarily dovetail seamlessly. For example, it kind of looks like there will be a mandated tabletop exercise (which is defined as a “group discussion led by a facilitator, using a narrated, clinically relevant emergency scenario, and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan”). In the Training and Testing section of the proposed rule, there are some click-through resources aimed primarily at assisting smaller facilities—those of you in smaller facilities like critical access hospitals and such—may want to pay very close attention to how this is going to impact your organizations. It sounds nice on paper, but only you folks know how workable these “solutions” might be.

Again, there are common elements—risk assessments, community involvement, emergency plans that reflect reality, etc.—but you and I both know that it doesn’t take a great deal of variable language to create almost insurmountable compliance challenges (note the “almost”; failure, as always, not an option on this wagon train). At this point, it’s impossible to say how much influence can be brought to bear on what’s going to come out of this magillah (and I know it can be very unhappy to weigh in and have one’s thoughts ignored), but I think it is most important to speak up when the opportunity is presented. This will take you to the comment page:

ASHE offered the following suggestions to those who are considering making their own comments:

The comments most likely to affect regulatory decisions are ones that are constructive and clear. Comments should be supported by sound reasoning, scientific evidence, or real-world examples of how your hospital or facility will be affected. Copying and pasting comments or information submitted by others decreases the effectiveness of both your comment and the comment of the original submitter. The best comments explain, in your own words, the positive or negative effects of the proposed rule on your facility and others like it. Remember that public comments are not votes—a single well-written public comment can pull more weight than thousands of form letters.

You may also find value in checking with your state hospital associations. I don’t think we can ever underestimate the impact on daily operations when the feds make changes of this nature and intensity and it’s getting towards the 11th hour. Make those comments count!

How long can this go on?

Recently I received a question regarding the use of the risk assessment process to determine whether an environmental condition was being appropriately managed. During survey, these folks were cited for not actively monitoring temperature and humidity in a sterile storage supply room adjacent to the OB surgical procedure room (this is one location that I’ve seen cropping up in recent surveys—please remember to keep an eye on sterile storage locations). The physical layout of the space, including the HVAC equipment, basically provides the “same” environment for the procedure room (where they had been monitoring humidity and temperature), so the question became whether the risk assessment process could be used to indicate that if the temp and  humidity in the procedure room had been fine, then the sterile storage room would be fine as well.

Now if we’d been having this discussion prior to the survey finding, we might have had a little bit of leverage, but I still think it would be a tough sell, both during survey or as part of the clarification process, because up to this point, there was no performance data to support that determination (which doesn’t mean it isn’t the case, just means there’s no supporting data—a very important and useful thing to have). My advice, especially since they’d taken the hit during survey, was to collect data for 12 months (this particular facility is located in an area that has four seasons—if you’re looking at a similar situation, but you only have, say, two seasons, you might be able to get away with fewer than 12 months of data) and then make the determination that monitoring only need be occurring in one location in this space. As an additional protective measure, I also suggested they might consider submitting data to the folks at the Joint Commission Standards Interpretation Group and query whether the consistency of data supports the monitoring conditions in the entire suite and not having to monitor in each space. Surveyors are more frequently arriving with past survey results, so it’s important to make sure you are appropriate and consistently managing past findings—you don’t want to be in a position in which previously noted conditions have not been corrected.

Do you want to know a secret?

Apropos of nothing, on the face of it, I wanted to share with you a cautionary tale relative to the importance of accurate (and complete) communications, particularly in those perilous moments when you have a less than satisfied customer. As you might guess, I travel by air a fair amount of the time (and no, this isn’t a beef about delays. I count myself pretty fortunate in that regard. Delays are an inevitable function of any commute, doesn’t matter what mode, but I digress) and, without getting into too much detail, a process that had always worked in the past suddenly did not “go” the way I expected/had experienced literally tens, if not hundreds, of times in the past.

The initial encounter with the airline folks did not yield much in the way of satisfaction; in fact, I don’t think I would be hyperbolic in describing the handling of that interaction as bordering on indifferent. I try to keep an even keel in such matters, but I will tell you that I was a wee bit frustrated. I also knew that there was a process for airing my concerns, so I elected to save it for another day.

At this point (and yes there is a point to all this and I’m almost there), I had a pretty good idea of what was going on (clearly, at least in my mind, it was a systems issue and one part of the system wasn’t communicating very effectively with another part of the system), so I contacted customer service and explained my plight. The person I spoke with was very empathetic and offered a solution that she guaranteed would resolve the issue; I came away with a very positive feeling, but guess what? The solution didn’t work. There were a few more back and forths with a few more ideas/solutions, but nothing that really addressed what I was convinced was the issue.  The customer service folks promised to investigate and let me know.

Well, it turns out that it was a systems issue and at least some folks at the airline knew of its existence and had been working on it for a couple of weeks. They weren’t sure when the issue would be resolved, but I was okay with that—because I now knew what was going on. The “problem,” as I now see it, is that the folks who knew there was a problem and what the “symptoms” of the problem were, didn’t let everyone in the customer service process know what was going on. There is nothing more effective in answering someone’s questions than being able to speak directly to the issue—even if the resolution is not immediate.

How many times in our work lives have we been less than proactive in providing everyone in the process a complete picture of what’s going on? Inevitably, one can look back and figure out exactly when full disclosure fell by the wayside and frequently results in hard feelings, etc. It all kind of dovetails back to the mantra of “if you see something, say something,” though in this case, it’s more along the lines of “if you know something, say something.” While one may not intend to be secretive, sometimes it’s tough to defend “compartmentalization” or whatever euphemism you might adopt.  When it comes to safety, the more everyone knows, the more effectively risk can be managed.

Hey, how about that new app(liance focus during TJC surveys)?

I don’t know that it represents a significant focus change or if it’s just one of those blips that one might encounter when you hear about survey results, but there is a little groundswell relative to the management of appliances (basically everything that is not clinical equipment, which it appears could extend to utility systems equipment, but there’s no clear sense of that just yet).

I think we can agree than the healthcare environment is chock-a-block full of all manner of devices and appliances from toasters and microwave ovens to refrigerators; from desk lamps to radios and who knows what else. So in that great expanse of possibilities, there have been at least two recent surveys in which the process for managing these types of appliances/devices have come under come scrutiny, resulting in some RFIs for folks.

Now, there are no specific standards or EPs that speak to the management of these appliances/devices, but it appears that where opportunities in this realm are being funneled is our old friend EC.02.01.01, generally a “there was no policy or risk assessment in place to indicate how the risks associated with…” (quotes are mine as I am paraphrasing the general concept). Not that long ago we talked about how far one might need to go when it comes to the ever-present specter of the risk assessment process, and I guess the short answer is: Here’s another instance to flex the ol’ risk assessment muscles.

And so I ask of you: How are you guys managing these pesky appliances? Incoming functional safety inspection (you turn it on and presto, it works) with periodic visual inspections during surveillance rounds? Regularly scheduled preventive maintenance (PM) activities? Re-inspection when something gets busted and is repaired? Inquiring minds (as they are wont to do) await your input!