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Hair Plugs? Heck, No! Shameless Plugs? That’s another story!

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…)

When will the madness stop?

I don’t know how many of you folks subscribe to The Joint Commission’s (TJC) e-notification products, but an interesting bit of news/info came across the airwaves that relates very clearly to some of the conversations we’ve been having (to one degree or the other) over the last, oh let’s say decade or so. Mark Pelletier, the COO of TJC, has taken on the task of “calling out” those healthcare organizations accredited by the Joint to clean up their acts as it relates to the preponderance of EC/LS findings during triennial and associated survey activities. If you’ve not yet seen it, it might be useful for you to be conversant in some of the details.

Now I think that we can absolutely pinpoint when this shift first manifested itself: way back in 2007 when the initial wave of Life Safety surveyors were introduced to the TJC survey process. Since then, there has been a steady increase in EC/LS findings, particularly as the remainder of the survey teams have also been tasked with observing conditions in the physical environment, which brings me back to the age-old dynamic of “Are they looking for it because that’s what they’re finding or are they finding it because that’s what they’re looking for?”

Having pondered this for quite some time, I believe that I fall squarely in the latter camp. One thing I’ve learned over the last 10+ years of working with hospitals is that there are no perfect buildings—and I really don’t think you need any more evidence than the number of findings generated in the survey of the physical environment to be convinced of that. Does this means that we are putting patients/staff/visitors at risk because of the poor conditions in our facilities? I don’t feel that the evidence supports such a draconian interpretation. Is there an opportunity for the management of the physical environment to better resourced, utilize technology better, etc.? I don’t think there’s anyone out there who would disagree that there have always been, and always will be, opportunities to make improvements in the physical environment.

TJC has not yet revealed the final results of most frequently cited standards during 2014 (I have no reason to think that the January to June 2014 results aren’t a good indicator of what we can expect), though I get the sense from Mr. Pelletier’s blog posting that findings relative to the integrity of egress may finally be taking a back seat to findings relating to the management of the surgical procedure environment (temperature/humidity/air pressure relationships). But that said, from the survey results that I’ve seen and the facilities with whom I’ve done on-site work, it is debatable (at least in my mind) that the findings are representative of a significant systems issue. My experiences indicate that the findings are generally related to what I would euphemistically refer to as transient conditions. Sometimes there are legitimate problems that need to be addressed; I recall one decontamination room that had never had an exhaust installed, but that is indeed an exception. But a majority of the time, we are talking about the sundry imperfections that can be encountered in any facility inspection. At this point, you should have a pretty good idea of how long you’d have to tour your building to find a condition that is not quite as it should be. Do you think if you toured for two or three days in a concerted fashion that you wouldn’t be able to find anything at all? Buildings are never more perfect than the moment before you put people in them—and apparently that perfection has somehow become the expectation. Jeez!

More songs about risk assessments…

One of the more common questions that I receive during my travels is “When do you need to do a risk assessment?” I wish that there were a simple response to this, but (as I have learned ad nauseam) there are few things in this safety life that are as simple as I’d like them to be. But I can give you an example of something that you might be inclined to look at as a function of your risk assessment process: restrooms (oh boy oh boy oh boy)!

While I can’t honestly characterize this as a trend (I suspect that, at the moment, this is the provenance of a handful or so of surveyors), there seems to be an increasing amount of attentions paid to restrooms—both public and patient—during surveys. These attentions have included nurse call alarms (or lack thereof), the ability of staff to be able to “enter” restrooms to assist someone in distress, the length of the nurse call cords, etc. Now you might not think that there was a whole heck of a lot of trouble that could result from this type of scrutiny, but I can tell you that things can get a little squirrelly during survey (mostly the rescuing someone from the restroom) if you don’t have your arms around these spaces.

For example (and I think we’ve talked about this as a general observation a while back), there are some surveyors that will almost delight in locking themselves in a restroom, activating the nurse call system and wait to see how long it takes for staff to respond to–and enter!—the restroom (there is a Joint Commission performance element that requires hospitals to be able to access locked, occupied spaces; this would be one of those). Although there is no specific standards-based timeframe for response in these situations, the tacit expectation is that staff will be ready to respond, including emergency entry into the restroom, upon their arrival on the scene. This means that they would either immediately possess the means of entering the restroom or would have an immediate means at their disposal. This, of course, would be subject to the type of lock on the restroom door, etc., but for the purposes of this situation, we must assume that the patient is unable to unlock the door on their own. So, this becomes both a patient safety risk and a potential survey risk.

Stay tuned for some thoughts on how best to manage these types of situations.

Prioritize this…

During a recent survey, an interesting question was posed to the folks in Facilities, a question more than interesting enough to bring to your attention. The folks were asked to produce a policy that describes how they prioritize corrective maintenance work orders and they, in turn, asked me if I had such a thing. In my infinitely pithy response protocol, I indicated that I was not in the habit of collecting materials that are not required by regulatory standard. Now, I’m still not sure what the context of the question might have been (I will be visiting with these folks in the not too distant future and I plan on asking about the contextual applications of such a request), but it did give me cause to ponder the broader implications of the question.

I feel quite confident that developing a simple ranking scheme would be something that you could implement without having to go the whole policy route (I am personally no big fan of policies—they tend to be more complicated than they need to be and it’s frequently tougher to follow a policy 100% of the time, which is pretty much where the expectation bar is set during survey). I think something along the lines of:

Priority 1 – Immediate Threat to Health/Safety

Priority 2 – Direct Impact on Patient Care

Priority 3 – Indirect Impact on Patient Care

Priority 4 – No patient care impact

Priority 5 – Routine repairs

would work pretty well under most, if perhaps not all, circumstances. The circumstance I can “see” that might not quite lend itself to a specific hierarchy is when you have to run things on a “first come, first served” basis. Now I recognize that since our workforces are incredibly nimble (unlike regulatory agencies and the like), we can re-prioritize things based on their impact on important processes, so the question I keep coming back to is how can a policy ever truly reflect the complexities of such a process without somehow ending up with an “out of compliance with your policy” situation? This process works (or I guess in some instances, doesn’t) because of the competence of the staff involved with the process. I don’t see where a policy gets you that, but what do I know?

If only it were a tankless job…

And yet another story from the survey wars, this time regarding the number of oxygen cylinders that are allowed in a smoke compartment. As was the case regarding the eyewash station risk assessment discussion, this one comes from a Focused Standards Assessment (FSA) survey that I did not personally attend, so if you feel the grain of salt is once again needed, I will wait for you to fetch said salt before I start. Ready? Okay.

Anyway, in this particular survey, the FSA surveyor informed the organization that it could only have 12 oxygen cylinders in a smoke compartment, in this case, the ED. But wait, you say, what’s wrong with that? Read on, read on! Further discussion ensued in which the surveyor indicated that the 12 oxygen cylinders included the cylinders that were on, for example, the stretchers in the individual bays in the ED (this particular ED is designated as a suite of rooms). Now this kind of (okay, very much so) flies in the face of the whole “in use” versus “storage” concept where you can have “storage” of no more than 12 cylinders in a smoke compartment, but you can also have a number of cylinders that are considered “in use.” You will find a most excellent examples of how this works (and please try not to focus on the irony of this information source) in the December 2012 issue of Perspectives; on the right hand column of p. 10, George Mills describes a situation that uncannily resembles the condition that the FSA surveyor indicated was not compliant. And says that it’s okay, because the cylinders on the stretchers would be considered “in use.” If that don’t beat all…

I guess this ultimately goes back to the importance of “knowing” where you stand in terms of compliance. “Knowing” that the oxygen cylinders are considered in use and thus, within allowances, then you can respectfully (perhaps even silently) disagree with the surveyor and go back to more important things. And I suppose if you wanted to be fresh, you could suggest the surveyor sign up for a subscription to Perspectives. Unfortunately, they don’t have those little cards that fall out and can be mailed in as a gag…

What’s the frequency, Kenneth?

In our continuing coverage of stories from the survey beat, I have an interesting one to share with you regarding my most favorite of subjects: risk assessments. During a recent FSA survey (what’s that, you ask? Why, that’s the nifty replacement for the “old” PPR process—yet another kicky acronym, in this case standing for Focus Standards Assessment), a hospital was informed by the surveyor that it was required to conduct an annual risk assessment regarding emergency eyewash stations. Now I will admit that I got this information secondhand, so you may invoke the traditional grain of salt. But it does raise an interesting question in regards to the risk assessment process: Is it a one-and-done or is there an obligation to revisit things from time to time?

Now, purely from a contrarian standpoint, I would argue against a “scheduled” risk assessment on some specific recurring basis, unless, of course, there is a concern that the management of the risk (in question) as an operational consideration is not as easily assured as might otherwise serve the purpose of safety. If we take the eyewash equipment as an example, as it deals primarily with response to a chemical exposure, I would consider this topic as being a function of the Hazardous Communications standard, which is, by definition, a performance standard. So as long as we are appropriately managing the involved risks, we should be okay. And I know that we are monitoring the management of those risks as a function of safety rounds and the review of occupational injury reports, etc. If you look at a lot of the requirements relating to monitoring, a theme emerges—that we need to adjust to changes in the process if we are to properly manage the risks. If someone introduces a new chemical product into the workplace, then yes, we need to assess how that change is going to impact occupational safety. But again, if we are monitoring the EC program effectively, this is a process that “lives” in the program and really doesn’t benefit from a specific recurrence schedule. We do the risk assessment to identify strategies to manage risks and then we monitor to ensure that the risks are appropriately managed. And if they aren’t being appropriately managed…then it’s time to get out the risk assessment again.