Experts Assess Implication of Joint Commission's Revised Standards

Abstract

What will the Joint Commission's final revised standards mean to biomeds and clinical engineers? Here, BI&T offers analysis from two experts and former Joint Commission staffers: Britton E. Berek, director of regulatory compliance at ARAMARK Healthcare, and Ode Keil, president of the Ode Keil Consulting Group.The new standards, set to take effect in January 2009, were developed as part of the Joint Commission's Standards Improvement Initiative begun in 2006. This initiative aims to clarify standards language, ensure that standards are program-specific, delete redundant or non-essential standards, and consolidate similar standards. The manuals are also being reorganized and the scoring and the decision process refined, but no new requirements are being added.At a minimum, Berek says that many biomed departments will need to make adjustments in policies and procedures as a result of the revised standards, which have been condensed and reorganized. This will likely mean that biomed departments will have to undertake some clerical activities to realign their plans, policies, and procedures, predicts Berek.Keil agrees. “While the other elements of performance in the Environment of Care (EC) chapter are essentially unchanged, the EC standards have been split into three chapters,” he says. “In addition to the text revisions, the standards have been renumbered. Although the Joint Commission does not require organizations to number policies, procedures, and records to match standards, most departments do so as a matter of convenience when preparing for survey.”Changes will need to go beyond paper, Berek predicts. The survey process itself has been changed significantly since 2004, including use of the tracer methodology, unannounced surveys, and requirements that engineers be part of the survey team at all hospitals. Old survey preparation strategies will no longer work in this new environment. “It's shifted 180° from the approach featuring manager interviews, policy books, and performance graphs. Now, departments are evaluated from the clinical unit's perception of performance and outcome. Consequently, the departments must prepare and operate much differently.”In the old days, says Berek, the policies and graphs were the main focus of the survey, and observations on the floor were secondary. In the current environment it is reversed.“This revision presents a good opportunity to revisit old policies and procedures and make sure they reflect actual practice. From my perspective, we see the surveyors making observations in the units and talking to nurses first.”He recommends that departments look at actual practice first and then the policies and decide if they are accurate, realistic, and doable. Those policies should reflect the latitude now given in the standards, such as options in inventory inclusion, rounds, and maintenance strategies.Both experts see a larger role for clinical engineering departments in the survey process.“The Joint Commission did make a few changes in the language that may be openings to add the voice of clinical engineers to some activities,” says Keil. “The revised elements of performance related to equipment evaluations include language specifically requiring that organizations seek input from individuals who operate and service equipment. Earlier generations of this element of performance did not contain the specific reference to service providers. It is reasonable to conclude that this change requires that accredited organizations demonstrate how they engage the biomedical or clinical engineering staff when considering equipment purchases.”“This may require organizations to rework equipment evaluation programs to include representatives of the biomedical or clinical engineering community early in purchasing decisions or as members of an equipment planning team at the time of major construction or renovation,” Keil says. “One possible complication could arise if the service for equipment is provided by an outside vendor. This could create the potential that the service vendor is a competitor of the equipment vendor. Organizations will have to determine if such situations would create conflicts of interest and find a way to address them.”Berek sees a larger role for clinical engineering as well. “Like it or not, I think the ‘turf’ divisions are eroding,” he says. “Clinical engineering needs to be more involved in infection control (such as cleaning equipment between uses), operator checks, training, patient safety, and reducing user errors. There are not just nursing functions, and a ‘not my job’ approach is not going to be viewed favorably Joint Commission surveyors or hospital administrators.”The clinical engineering function also has a role in emergency management, Berek and Keil say.Keil points out that the Emergency Management standards require that hospitals determine what medical equipment might be shared with other organizations during an emergency situation. These standards also require the hospitals to determine what medical equipment needs to accompany patients transferred to other locations as part of an emergency response.“Emergency resources needed in a 96-hour timeframe may include equipment, supplies, and labor,” says Berek. Clinical engineering staff will need to be involved in making these plans.For more information, see http://www.jointcommission.org/Standards/SII/.