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Posted At : July 25, 2008 1:04 PM
| Posted By : Steve MacArthur
Related Categories:
The Joint Commission
When it comes to a list of items to monitor in the EC, the starting point is element of performance #1 under EC.9.10:
- Injuries to patients or other coming to the hospital
- Incidents of property damage
- Occupational illnesses and injuries to employees
- Security incidents involving patients, workers, or others
- Hazardous materials and waste spills, exposures, and related incidents
- Fire safety management problems, deficiencies, and failures
- Medical equipment management problems, failures, and user errors
- Utility system management problems, failures, or user errors
Now there's a whole lot of risk that lives in these bullets above. Thus, the acid test becomes one of risk recognition, assessment, intervention, and ongoing performance monitoring.
An increasingly critical function of the survey process is the risk assessment portion and then the quality of the interventions that you choose to manage the risks.
Requirements for improvement in the EC are up, not so much because there are significant program failures, but rather because of a whole bunch of minor deficiencies that are aggregated into serious findings.
Mix this in with each member of the survey team being responsible for finding stuff and you have the oft-cited recipe for disaster.
Ultimately, the onus is on each organization to define what these EC risks mean and then defend the risk management approach they've chosen.
I recently chatted with someone about items you need to monitor in the EC.
There are myriad activities, primarily represented through the "C" elements of performance (EPs) in the EC chapter, that revolve around the "care and feeding" of the care environment--medical equipment, life safety equipment, emergency power equipment, conduction of safety rounds, and the like.
A solid EC program is going to have a process for monitoring compliance with all these "have to" elements, just to ensure that the EC program’s baseline competencies, if you will, are in place and functioning appropriately.
Beyond the activities and processes that you "have to do," things get a whole lot grayer in very short order.
The key standard for the rest of the monitoring expectations is EC.9.10 (the hospital monitors conditions in the environment). These expectations are pretty much a function of the risk management process in the care environment. There are six EPs involved in EC.9.10, pretty much divided into constant activities and periodic (at least annually) evaluations of the whole kit and caboodle.
More on this topic in my next post . . .
Hi, it’s Scott Wallask signing in today. I just got back Tuesday night from the American Society for Healthcare Engineering (ASHE) conference.
Lots happening on The Joint Commission (formerly JCAHO) front, as you can imagine. We’ll be covering this in detail in upcoming issues of Briefings on Hospital Safety and Healthcare Life Safety Compliance.
One thing I did want to mention is that George Mills, senior engineer at The Joint Commission, said he was concerned about the lack of realistic utility contingencies in hospital emergency operations plans.
From Mills view, some utility contingency provisions read great on paper, but are never really tested and thus aren’t reliable.
Mills asked ASHE attendees this: “When was the last time [you] walked through to make sure these things are even operating?” In other words, if your utility contingency plans center of certain equipment working, check this equipment out during down time before a disaster strikes.
Mills would rather have a utility failure occur when hospitals are expecting it during testing than during an emergency when patient lives are at risk, he said.
By the way, if you need help with the 2009 emergency management, life safety, or EC standards and can spare a day away from the office, come to our Environment of Care for 2009 seminar September 5 in Boston.
Posted At : July 18, 2008 8:24 PM
| Posted By : Steve MacArthur
Related Categories:
The Joint Commission
When it comes down to the annual EC evaluation process, what you want to do is formulate responses to some basic questions:
- What got better?
- How do we know it got better? (A measurable indicator is a joy forever.)
- How do we know it will stay better? (And we may not right away, but we do need to figure out how to keep an eye on things.)
- What didn’t get better? (Remember, improvement is about getting better, it is not, I repeat, not about staying the same. Staying the same is one step closer to getting worse than getting better is .Yow, does that even make sense? I think so…)
- What do we have to do to make it better?
- How will we know when it’s better? (There’s got to be some way of knowing.)
Which leads me to our next reconfiguration: the wonderful world of surveillance rounds, safety tours, environmental tours, whatever you call them in your house.
There has been an on-so-subtle alteration in The Joint Commission’s expectations for our annual and semi-annual rounds. The intent of conducting the rounds is to “evaluate the effectiveness of previously implemented activities intended to minimize or eliminate environment of care risks.”
My advice? If you haven’t started aggregating the information (particularly deficiencies) you’re gathering during surveillance rounds, you better get to it quick. In many instances, that’s your most reliable internal data source (i.e., your own two eyes).
Then use that information to identify improvement opportunities, including how you’ll know when they’ve “improved.” All the other stuff is nice, but anything that doesn’t speak to the improved/improving/not yet improved continuum is not going to help you.
If you want to talk about capital projects, talk about them in the context of improvement. You spent eight kazillion bucks – something damn well better have improved.
(BTW, when you identify capital projects, practice coming up with ways to measure the effectiveness. Even reducing the number of complaints, outages, etc. is valid. Figure out something.)
Posted At : July 16, 2008 1:50 AM
| Posted By : Steve MacArthur
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Fortunately, with the release of the revised 2009 Joint Commission standards, there have been no real changes to the important process expectations within the EC standards. We still have to:
- Plan
- Implement
- Ensure staff competence
- Monitor and improve
Those bullets almost form an acronym, as I look at it. PIEM? PIE’M?
At any rate, there has indeed been some shifting of the standards and elements (The Joint Commission is holding off on significant requirement changes until 2010, if the tea leaves are speaking the truth), but it still comes down to appropriately managing the risks in your environment. And remember, that’s YOUR environment--nobody else’s.
It should make for a most interesting 12 to 18 months. Better suit up now!
Posted At : July 7, 2008 11:44 AM
| Posted By : Steve MacArthur
Related Categories:
People often ask me about ideas for safety risk assessments.
In HCPro’s Safety Risk Assessment Tools book published last year, there is a fairly comprehensive list of common risks in the healthcare environment that you could use to get things started.
For example, here are some potential risks to the building itself:
- Age of the structure
- Lack of access for handicapped people
- Eyewash stations and safety shower locations
- Cell phone interference potential
- Electrical dangers
- Paging system “dead zones”
- Suicide potential due to building features
- Suicide potential due to building systems
- Wrong wayfinding signs
- Stairwell design
Once you have your risks, it’s basically a question of plugging in the severity data and coming up with mitigation and improvement strategies.
Did you hear that great sighing sound earlier? In all candor, I have to tell you that I was one of those sighers.
(Is “sighers” a word? Probably not, but the blogosphere can’t rest on such formalities).
The other shoe has dropped, and The Joint Commission 2009 standards changes have (finally!) been posted on the Web.
The question then becomes: Celebration or commiseration? What do we do?
For the moment, it appears that a moderately restrained celebration will suffice. The key words indicating the disposition of the current standards I noted in reviewing the materials are the following:
- Retention--No change in the applicable EP, i.e., the song remains the same.
- Consolidation--A slight change, a blending, if you will, of risk management activities under a general umbrella. For instance, all the safety education elements are now living in one happy house, EC.03.01.01, and, perhaps most controversially, the safety and security standards have become one under EC.02.01.01.
- Split--EPs previously containing multiple component requirements are broken down into the individual components. For instance, EC.3.10, EP #3 under the 2008 standards speaks to the risk management of chemicals, which has been further broken out in the 2009 standards under EC.02.02.01 to reflect the risk management of hazardous chemicals, radiation equipment and lasers, and hazardous gases and vapors.
As near as I can tell (and this has pretty much been the indication as this initiative has rolled out), there are no new requirements, per se. What appears to be changing is more a function of how EPs could be scored during a survey, especially those (banana) splits.
In my client work, I have often compared the current survey process’ arrival at “jeopardy” as not so much death by a sucking chest wound, but more death by a thousand cuts--and the Swiss survey knife appears to have grown a couple more blades. While my obsessive-compulsive disorder has not yet resulted in my counting up the number of EPs in play, rest assured I will.
There is a fundamental constant that every time The Joint Commission deck gets shuffled, there is a likelihood of some resulting confusion, not only in the EC community at large, but also in the surveyor community.
Hi everyone --
It's Scott Wallask at HCPro logging in.
Just a quick FYI, The Joint Commission has posted its 2009 standards, including the revised EC and new life safety and emergency management chapters:
I'm sure Steve Mac will have more to say on this soon on the blog.
Meanwhile, I'd also like to mention that HCPro has an upcoming seminar on September 5 that will dig into all these new standard changes prior to January 1 effective date.
Thanks...Scott W.
Posted At : June 30, 2008 10:01 AM
| Posted By : Steve MacArthur
Related Categories:
Security
I was talking about photography policies and hospital security last week in the blog, and a related concern is media actions during a big news story.
Unfortunately, due to immediate media saturation of almost any event, it is frequently (and to my mind, rightly so) a primary concern of organizations to develop an approach/policy for the management of photography, not only within the walls of the hospital, but also on the grounds of the hospital.
My experience has been that hospitals need to maintain a very strict line on the media, as any precedent-setting "permission" to the media (even for pleasant circumstances) can make it that much more challenging when the media breaches the hospital as they pursue a story that might be considerably less flattering to the hospital.
Thus, it is important to determine ahead of time how much access can be granted, regardless of the situation, and how that access would be managed (preferably in the form of some sort of neutral ground, but that's not always possible).
Yet another interesting risk assessment strategy is to identify a severity score for an unprotected risk, then using a matrix format, identify the interventions you've implemented to manage the risk and determine a score for the "protected" risk.
This works really well with security stuff because of the wide variety of interventions that can come into play (CCTV, access control, panic alarms, alarms, security presence, etc.).
Posted At : June 25, 2008 12:59 PM
| Posted By : Administrator
Related Categories:
Security
I was asked by a grad student last week about hospitals establishing photography policies in light of HIPAA concerns.
There’s a balancing act between maintaining an open care environment (people generally like to take pictures of newborns and other happy events) and the privacy of other patients in the hospital.
That said, fortunately, the types of allowable photo opportunities inside a hospital are pretty limited to those happy moments and so can be isolated to a fair degree. In so doing, it becomes fairly simple to identify those photographic pursuits that would be prohibited.
In the case of photography without permission, it's more a case of regular privacy and, for all intents and purposes, customer relations as opposed to a HIPAA issue. HIPAA, at its fundamental core focuses on “protected health information,” or PHI.
In the first years of HIPAA, there was a lot of angst about what this meant --for instance, some hospitals went to the extreme of not providing any information about patients over the phone, even to verify the patient was actually a patient!
Lately, things have reached more of an even keel as the definition of PHI becomes clearer. Basically PHI involves any information that specifically identifies the patient and his or her diagnosis. If you don't have both elements in place, then you don't have PHI, and if there is no unauthorized release of that combo, there’s no HIPAA violation.
Posted At : June 25, 2008 12:58 PM
| Posted By : Administrator
Related Categories:
The Joint Commission
During our audioconference last week, one listener who called in during our audience Q&A portion asked me about broad risk assessment summaries that go beyond just the environmental safety realm.
When it comes to general risk assessment information, one source that’s been very useful over time is the University of Leeds over in England, which has a Web page devoted to risk assessments.
I can't say that I've done a lot of work with risk assessment summaries (though you can find some fairly extensive information by simply Googling the term “risk assessment summary” from time to time to see what comes up).
That said, what you could do is set up a matrix that identifies the locations within your organization on one axis and identify the most common risks found in your organization on the other axis, and then devise a numerical or color-coded score to indicate the severity of the risk.
Anyone else have good examples of broader-based risk assessments? Click the “Comments” link below to let us know. If any others come to my mind, I’ll post a follow-up.
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